ML23227A221

Emergency Application to Revise Technical Specifications to Adopt TSTF 568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2

ML23227A221
Person / Time
Site:	Fermi
Issue date:	08/15/2023
From:	Peter Dietrich DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-23-0055
Download: ML23227A221 (1)

Text

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 August 15, 2023 10 CFR 50.90 NRC-23-0055 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:

Emergency Application to Revise Technical Specifications to Adopt TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" Pursuant to 10 CFR 50.90, DTE Electric Company (DTE) is submitting an Emergency request for an amendment to the Technical Specifications (TS) for Fermi Unit 2 (Fermi 2).

DTE requests adoption of TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2."

TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

The enclosure provides a description and assessment of the proposed change. Attachment 1 provides the existing TS pages marked to show the proposed change. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

DTE requests review of this amendment request under Emergency circumstances as defined in 10 CFR 50.91(a)(5). Fermi has been troubleshooting increased unidentified Reactor Coolant System leakage since 1/2/2023 when leakage was 0.33 gpm, Technical Specification limit is 5 gpm. This leakage has remained steady and it was anticipated that a containment entry would not be necessary until the next refueling outage starting March 2024. However, since 8/8/23 the unidentified leakage has increased to 1.92 gpm on 8/14/23. Troubleshooting efforts to identify the leak outside of containment have been exhausted and internal containment inspections are required.

DTE further requests approval of the proposed license amendment as soon as possible, but no later than Friday, August 18, 2023, at 12:00. This request will provide DTE the ability to address an emergent plant condition related to unidentified leakage within primary containment.

The current leakage rate is projected to approach the Technical Specification limit of 5 gallons-per-minute within 2 weeks. Implementation of this license amendment would allow additional

USNRC NRC-23-0055 Page 2 time above 15% Reactor Thermal Power (RTP) to identify and correct the leakage without requiring a shutdown of the plant or operation below 15% RTP after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of exceeding the oxygen concentration limit. Shutdown and/or operation at less than 15% RTP is undesirable due to (1) unnecessary stresses from a shutdown and restart of the main generator based on known degradation of the stator and (2) historical operating experience of stresses on the turbine when operated at less than 15% RTP. If repairs cannot be completed in the revised 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time, the plant will continue to Mode 3 to allow for the completion of repairs.

Approval of the proposed amendment is requested by August 18, 2023. Once approved, the amendment shall be implemented within 1 day.

There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Michigan Official.

Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager Nuclear Licensing, at (734) 586-4772.

I declare under penalty of perjury that the foregoing is true and correct.

Peter Dietrich Senior Vice President and Chief Nuclear Officer

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases Changes (Mark-Up)-For Information Only

USNRC NRC-23-0055 Page 3 cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure to NRC-23-0055 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Emergency Application to Revise Technical Specifications to Adopt TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" Description and Assessment

Enclosure to NRC-23-0055 Page 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

DTE requests adoption of TSTF-568, "Revise the Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation DTE has reviewed the safety evaluation for TSTF-568 provided to the Technical Specifications Task Force in a letter dated December 17, 2019. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-568. DTE has concluded that the justifications presented in TSTF-568 and the safety evaluation prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of the changes to the Fermi TS.

2.2 Optional Changes and Variations DTE is proposing the following variations from the TS changes described in TSTF-568 or the applicable parts of the NRC staffs safety evaluation:

The Fermi TS utilize different numbering than the Standard Technical Specifications on which TSTF-568 was based. Specifically, Fermi 2 TS 3.6.3.1, Primary Containment Oxygen Concentration corresponds to STS 3.6.3.2 Primary Containment Oxygen Concentration.

This difference is administrative and does not affect the applicability of TSTF-568 to the Fermi 2 TS.

The proposed change to TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," in TSTF-568 is not applicable to Fermi and is not included.

2.3 Basis for Emergency Processing In 10 CFR 50.91(a)(5), the NRC refers to emergency situations as those in which failure to act in a timely way would result in derating or shutdown of a nuclear power plant, or in prevention of either resumption of operation or of increase in power output up to the plants licensed power level. Under such a situation, the Commission may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or public comment.

DTE requests approval of the proposed license amendment as soon as possible, but no later than Friday, August 18, 2023, at 12:00. This request will provide DTE the ability to address an emergent plant condition related to unidentified leakage within primary containment. The current leakage rate is projected to approach the Technical Specification limit of 5 gallons-per-

Enclosure to NRC-23-0055 Page 2 minute within 2 weeks. Implementation of this license amendment would allow additional time above 15% Reactor Thermal Power (RTP) to identify and correct the leakage without requiring a shutdown of the plant or operation below 15% RTP after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of exceeding the oxygen concentration limit. Shutdown and/or operation at less than 15% RTP is undesirable due to (1) unnecessary stresses from a shutdown and restart of the main generator based on known degradation of the stator and (2) historical operating experience of stresses on the turbine when operated at less than 15% RTP. If repairs cannot be completed in the revised 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time, the plant will continue to Mode 3 to allow for the completion of repairs.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis DTE requests adoption of TSTF-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2."

TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

DTE has evaluated if a significant hazards consideration is involved with the proposed amendment(s) 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 The proposed change revises the Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. Primary containment oxygen concentrations are not initiators to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not affected by the proposed change.

Primary Containment Oxygen Concentrations are assumptions in the mitigation of some accidents previously evaluated. The Applicability of TS 3.6.3.1 is changed from Mode 1 when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident.

The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The consequences of an event that could affect the primary containment oxygen concentration are no different during the proposed Completion Time than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.

Enclosure to NRC-23-0055 Page 3 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed).

No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the UFSAR are created because the Nuclear Regulatory Commission has determined that hydrogen generation is not risk significant for design basis accidents.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.1, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. No safety limits are affected. No Limiting Conditions for Operation or Surveillance limits are affected. The Primary Containment Oxygen Concentration Technical Specification requirements assure sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis.

The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, DTE concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Enclosure to NRC-23-0055 Page 4 3.2 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 Commissions 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 change.

Attachment 1 to NRC-23-0055 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Emergency Application to Revise Technical Specifications to Adopt TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" Proposed Technical Specification Changes (Mark-Up)

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be

< 4.0 volume percent.

MODES 1 and 2.

APPLICABILITY: 110~ iHg t~e time pe, i! d.

a. i;:rom 24 hob!i::s after TWE;RMAL POl.~hR is > 15°& RTP following sta1 ttJf) , te

---

NOTE------------

LCO 3.0.4.c is Applicable 19 . 24 19etirs f)l°i er te reEltJci A!3 Tl IERMAL PrnJER te ~ 15,6 RTP 0

f3Pi or ts tl:1e Rm(t reactor sh1::1tEl01,JR .

ACTIONS CONDITION COMPLETION TIME A. Primary containment A.1 Restore oxygen oxygen concentration concentration to not within limit. within limit. 72 B. Required Action and 8.1 ReEluce Tl lERHAL PQ!,JER associated Completion te .s 153/4 RTP .

Time not met. 12 Be in MODE 3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen In accordance concentration is within limits. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.6-39 Amendment No. 12i, +/-9-9, 9-+/-

Attachment 2 to NRC-23-0055 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Emergency Application to Revise Technical Specifications to Adopt TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" Revised Technical Specification Changes

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE------------

LCO 3.0.4.c is Applicable A. Primary containment A.1 Restore oxygen 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> oxygen concentration concentration to not within limit. within limit.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen In accordance concentration is within limits. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.6-39 Amendment No. 134, 159, 201

Attachment 3 to NRC-23-0055 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Emergency Application to Revise Technical Specifications to Adopt TSTF 568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2" Proposed Technical Specification Bases Changes (Mark-Up) -

For Information Only

Primary Containment Oxygen Concentration B 3.6.3.1 BASES LCO The primary containment (both drywell and suppression chamber) oxygen concentration is maintained< 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary or 2 containment. Change comma to period APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, TSTF-568 changed the except as allowed by the relaxations during startup and Completion Time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to shutdown addressed below. The primary containment must be 72 based on the following inert in MODE 1, since this is the condition with the sequence of options: allow 24 highest probability of an event that could produce hydrogen.

hours to de-inert the containment to permit safe personnel access, Inerting I

the primary containment is an operational problem allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the because I

it prevents containment access without an required maintenance or repair appropriate I

breathing apparatus. Therefore, the primary work, and allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to inert containment J

is inerted as late as possible in the plant the containment. The NRC staff startup and de-inerted as soon as possible in the plant determined that the presence of a shutdown. As long as reactor power is< 15% RTP, the higher oxygen concentration for potential for an event that generates significant hydrogen the 72-hour Completion Time is is low and the primary containment need not be inert.

appropriate considering the low Furthermore, the probability of a event that generates safety significance of the change hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, for potential for accidents and the or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a shutdown, is low enough additional restrictions and that these "windows," when the primary containment is not conservatisms in the revised inerted, are also justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a applicability. reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

ACTIONS A. l or 2 If oxygen concentration is 4.0 v/o at any time while operating in MODE 1, with the exception of the relaxations 72 allowed during startup and shutdown, oxygen concentration must be restored to< 4.0 v/o within 24 hGurs. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is allowed when oxygen concentration is 4.0 v/o because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

I A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Modes 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

FERMI - UNIT 2 B 3.6.3.1-2 Revision 25

Primary Containment Oxygen Concentration B 3.6.3.1 BASES ACTIONS (continued) 12 MODE 3 B.1 If oxygen concent ion cannot be restored to ithin limits within the req

• ed Co letion Time, the plan must be brought to a DE in w ich the LCO does not ly. To achieve *s status, wer must be reduced t ~ 15% RTP within ours. The g. hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE . SR 3 . 6. 3 . 1. 1 REQUIREMENTS .

The primary containment must be determined to be inert by verifying that oxygen concentration is< 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 6.2.5.

FERMI

• UNIT 2 B 3.6.3.1-3 Revision 64