ML18144A064

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Issuance of Amendment to Revise Technical Specification Section 3.7.2, Emergency Equipment Cooling Water/Emergency Equipment Service Water System and Ultimate Heat Sink
ML18144A064
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/17/2018
From: Sujata Goetz
Plant Licensing Branch III
To: Polson K
DTE Electric Company
Goetz S, NRC/NRR/DORL/LPLIII, 415-8004
References
CAC MG0017, EPID L-2017-LLA-0270
Download: ML18144A064 (17)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 July 17, 2018 Mr. Keith J. Polson Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 260 TAC 6400 North Dixie Highway Newport, Ml 48166

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATION SECTION 3.7.2, "EMERGENCY EQUIPMENT COOLING WATER (EECW)/EMERGENCY EQUIPMENT SERVICE WATER (EESW)

SYSTEM AND ULTIMATE HEAT SINK (UHS)" (CAC NO. MG0017 AND EPID L-2017-LLA-0270)

Dear Mr. Polson:

The U.S. Nuclear Regulatory Commission (NRC or Commission) has issued the enclosed amendment No. 209 to Renewed Facility Operating License No. NPF-43 for Fermi 2. The amendment is in response to your application dated July 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17198C829), as supplemented by letter dated January 8, 2018 (ADAMS Accession No. ML18008A061 ). The amendment revises Fermi 2 Technical Specification (TS) 3.7.2, "Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)."

Specifically, the amendment revises TS 3.7.2 conditions and surveillance requirements to reflect a proposed change to the design of the two redundant cross-tie lines that are part of the UHS.

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

Sujata G etz, Pr

  • Plant Li nsing Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 209 to NPF-43
2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 209 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 July 17, 2017, as supplemented by letter dated January 8, 2018, 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 Renewed Facility Operating License No. NPF-43 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Enclosure 1

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION

()0 Q o/~

David J. Wron/'Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: July 17, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 209 FERMI 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DOCKET NO. 50-341 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

REMOVE INSERT Page 4 Page4 Replace the following pages of the 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 3.7-3 3.7-3 3.7-4 3.7-4 3.7-5 3.7-5

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed 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 Consumers Power Company as specified in a letter from The Detroit Edison Company to the Director of Regulation, dated August 13, 1971, and the letter from Richard W. Mclaren, Assistant Attorney General, Antitrust Division, U.S. Department of Justice, to Bertram H. Schur, Associate General Counsel, Atomic Energy Commission, dated August 16, 1971.

(4) Deleted (5) Deleted (6) Deleted (7) Deleted (8) Deleted (9) Modifications for Fire Protection (Section 9.5.1, SSER #5 and SSER #6}*

DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report for the facility through Amendment 60 and as approved in the SER through Supplement No. 5, subject to the following provision:

(a) DTE Electric Company may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-43 Amendment 209

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.l Restore reservoir to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.

B. One EECW/EESW B.1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.

Condition A.

(continued)

FERMI

  • UNIT 2 3.7-3 Amendment No. 164,209

EECW/EESW System and UHS 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.l 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 of Condition A or AND B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both EECW/EESW subsystems inoperable.

OR UHS inoperable for reasons other than Condition A.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify the water level of each UHS In accordance reservoir, and the average water level of with the the two reservoirs. are~ 25 ft. Surveillance Frequency Control Program SR 3.7.2.2 Verify the average water temperature of In accordance each reservoir. and combined average water with the temperature of the two reservoirs, are Surveillance s 80°F. Frequency Control Program (continued)

FERMI

  • UNIT 2 3.7-4 Amendment No.~.~ , 209

EECW/EESW System and UHS 3.7.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.2.3 ------- ----- ----- --NOTE ----------- ----- ----

Fast speed testing not required to be performed during icing periods.

Operate each cooling tower fan on slow In accordance speed and on fast speed, each for with the

~ 15 minutes. Surveillance Frequency Control Program SR 3.7.2.4 ------- -- --- ----- --NOTE ------- -------- -----

Isolation of EECW flow to individual components does not render EECW System inoperable.

Verify each EECW/EESW subsystem manual, In accordance power operated, and automatic valve in the with the flow paths servicing safety related systems Surveillance or components, that is not locked, sealed, Frequency or otherwise secured in position, is in the Control Program correct position.

SR 3.7.2.5 Verify each EECW/EESW subsystem actuates on In accordance an actual or simulated initiation signal. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.7-5 Amendment No. !J4, ~ , 209

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 209 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By application dated July 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17198C829), as supplemented by letter dated January 8, 2018 (ADAMS Accession No. ML18008A061 ), DTE Electric Company {DTE or licensee) submitted a license amendment request (LAR) for Fermi 2. The licensee requested a change to Technical Specification (TS) 3.7.2, "Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)." The proposed change would revise TS 3.7.2 conditions and surveillance requirements (SRs) to reflect a proposed change to the design of the two redundant cross-tie lines that are part of the UHS.

Specifically, the proposed amendment would delete the current TS 3.7.2, CONDITION A, which accounts for inoperability of the reservoir cross-tie lines. The proposed amendment would also make conforming changes to CONDITIONS B through D and to SRs 3.7.2.1 and 3.7.2.4.

The supplement dated January 8, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 26, 2017 (82 FR 44850).

2.0 REGULATORY EVALUATION

2.1 System Description Section 9.2.5 of the Fermi 2 updated final safety analysis report (UFSAR) states that the UHS is provided by the residual heat removal (RHR) complex, which contains the RHR service water system, the EESW system, the diesel generator (DG) service water system, the mechanical draft cooling towers, the DGs, and the reservoirs. The UFSAR also states that the UHS consists of a single highly reliable water source (reservoirs) with fully redundant cooling towers, pumps, and conduits capable of providing sufficient cooling for 7 days to permit safe shutdown and cooldown of the nuclear unit in the event of a design basis accident.

Enclosure 2

The Fermi 2 RHR complex reservoirs consist of two one-half-capacity reinforced-concrete structures each with a capacity of 3.41 x 106 gallons of water at reservoir elevation 583 feet (ft).

The two reservoirs are separated by a 4-foot thick concrete wall and are connected by two redundant cross-tie lines through the wall. Each line contains two motor-operated valves (MOVs) to permit cross-connecting the reservoirs to provide access to the combined inventory to either division of RHR service water system, EESW system, and DG service water system in the event of a failure in one of the divisions.

2.2 Description of the Proposed TS 3. 7 .2 Change

1. The proposed change would delete current CONDITION A regarding cross-tie lines, which states:

CONDITION REQUIRED ACTION COMPLETION TIME A. UHS inoperable due to A.1 Restore UHS cross-tie 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable cross-tie lines to OPERABLE line(s). status.

2. The proposed change would renumber CONDITION B as CONDITION A.
3. The proposed change would renumber TS 3. 7.2 REQUIRED ACTION 8.1 as REQUIRED ACTION A.1.
4. The proposed change would renumber CONDITION C as CONDITION B, would renumber TS 3. 7.2 REQUIRED ACTION C.1 to REQUIRED ACTION 8.1, and would change the words "Conditions A and B" to "Condition A" from current CONDITION C, which reads:

CONDITION REQUIRED ACTION COMPLETION TIME C. One EECW/EESW C. 1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.

Conditions A and B.

To read:

CONDITION REQUIRED ACTION COMPLETION TIME B. One EECW/EESW 8.1 Restore the EECW/EESW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem inoperable subsystem to OPERABLE for reasons other than status.

Condition A.

5. The proposed change would renumber CONDITION D as CONDITION C, would renumber TS 3. 7.2 REQUIRED ACTIONS D.1 and D.2 to REQUIRED ACTIONS C.1

and C.2, would change "A, B, or C," "for reasons other than Condition A," and "Conditions A and B" from current Condition D, which reads:

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.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 of Condition A, AND B, or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both EECW/EESW subsystems inoperable for reasons other than Condition A.

OR UHS inoperable for reasons other than Conditions A and B.

To read:

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 of Condition A or AND B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR Both EECW/EESW subsystems inoperable.

OR UHS inoperable for reasons other than Condition A.

6. The proposed change would delete "each of' from current SR 3.7.2.1, which reads:

Verify the water level of each UHS reservoir, and the average water level of each of the two reservoirs, are .::: 25 ft.

To read:

Verify the water level of each UHS reservoir, and the average water level of the two reservoirs, are .::: 25 ft.

7. The proposed change would delete "and UHS" from current SR 3.7.2.4, which reads:

Verify each EECW/EESW subsystem and UHS manual, power operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

To read:

Verify each EECW/EESW subsystem manual, power operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

2.3 Regulatory Review The NRC staff applied the following NRC regulations and guidance to evaluate the LAR.

Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.36(c)(2)(ii), states, in part:

A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Regulation 10 CFR 50.36(c)(3) states:

Surveillance requirements. Surveillance requirements 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 limiting conditions for operation will be met Regulatory Guide (RG) 1.27, Revision 3, "Ultimate Heat Sink for Nuclear Power Plants" (ADAMS Accession No. ML14107A411 ), states, in part:

The UHS should consist of at least two sources of water, including their retaining structures, each with the capability to perform the safety functions specified in Regulatory Position 1.a, unless it can be demonstrated that there is an extremely low probability of losing the capability of a single source.

Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC) 2, "Design bases for protection against natural phenomena," states, in part:

Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes,

7. The proposed change would delete "and UHS" from current SR 3.7.2.4, which reads:

Verify each EECW/EESW subsystem and UHS manual, power operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

To read:

Verify each EECW/EESW subsystem manual, power operated, and automatic valve in the flow paths servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.

2.3 Regulatory Review The NRG staff applied the following NRG regulations and guidance to evaluate the LAR.

Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.36(c)(2)(ii), states, in part:

A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Regulation 10 CFR 50.36(c)(3) states:

Surveillance requirements. Surveillance requirements 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 limiting conditions for operation will be met Regulatory Guide (RG) 1.27, Revision 3, "Ultimate Heat Sink for Nuclear Power Plants" (ADAMS Accession No. ML14107A411 ), states, in part:

The UHS should consist of at least two sources of water, including their retaining structures, each with the capability to perform the safety functions specified in Regulatory Position 1.a, unless it can be demonstrated that there is an extremely low probability of losing the capability of a single source.

Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC) 2, "Design bases for protection against natural phenomena," states, in part:

Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes,

hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.

GDC 44, "Cooling water," states:

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 redundancy in components and features, and suitable interconnections, 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.

3.0 TECHNICAL EVALUATION

3.1 Technical Review The NRC staff evaluated the LAR using the applicable regulations and guidance.

The water sources for the Fermi 2 UHS are two adjacent reservoirs that are reinforced concrete structures separated by a 4-foot thick concrete wall. The reservoirs have dual pipes through the wall which connect the two reservoirs. The pipes have one MOV on each end of two connecting pipes (for a total of four) that are located near the bottom of the reservoirs and are submerged.

The capacity of each reservoir is 3.41 x 106 gallons.

During an underwater inspection of the UHS, Fermi 2 personnel identified corrosion in the cross-tie piping. Since the piping supports the load of the cross-tie MOVs, continued corrosion and/or a seismic event could cause failure of the cross-tie lines. The licensee identified removal of the MOVs as a desirable resolution.

The reservoirs were originally designed as redundant sources of water for the UHS, in conformance with RG 1.27, which specifies that the UHS should consist of at least two sources of water - each with the capacity to perform the safety functions. Each of the two cross-tie lines which connect the reservoirs has two MOVs. The MOVs were designed to ensure that the UHS reservoirs could be isolated from each other so that the UHS could withstand any single failure of a man-made structure such as a breach of one reservoir, with a single failure of one MOV.

The two cross-tie lines also assured the ability to cross-connect reservoirs for operational and design flexibility.

By letter dated September 30, 1988 (ADAMS Legacy Library Accession No. 8810070058), the licensee submitted an LAR stating that the Fermi 2 UHS consists of two one-half-capacity reservoirs that should be considered a single water source to better reflect the plant design basis and that both reservoirs were needed to perform the safety functions. The licensee justified describing the UHS as a single water source, which would allow unlimited operation with the reservoirs cross-connected, by stating that a below grade breach is extremely unlikely, and if it were to occur, it would not be significant, since 90 percent of the reservoir capacity is below the water table. Furthermore, adequate time for compensatory measures for any such

breach is likely to be available since reservoir level decrease would be easily detectable. By letter dated February 20, 1990, the NRC issued Amendment No. 51 (ADAMS Accession No. ML020700563), which concurred with the licensee's determination that the UHS is a single water source. The NRC staff safety evaluation for the amendment determined that:

  • The below grade breach of the Category I RHR complex structures is extremely unlikely particularly in conjunction with an event which would require the full capacity of the UHS.
  • The additional water loss from the postulated breach when the reservoirs are cross connected is approximately 5 percent of the UHS capacity.
  • The UHS capacity can be easily supplemented by pumping water from Lake Erie or other close by water sources.

The RG 1.27 specifies that an UHS should consist of two water sources; however, RG 1.27 has a provision for one water source if it can be demonstrated that there is an extremely low probability of losing the capability of a single water source. Furthermore, the Fermi 2 reservoirs are seismic category I structures and thus are qualified to maintain integrity during a safe shutdown earthquake. The current Fermi 2 TS Bases state that the UHS is provided by a single highly reliable water supply in the form of the RHR reservoirs. In addition, the current Fermi 2 UFSAR also states that the UHS consists of a single highly reliable water source.

Based on the above, the NRC staff concludes that:

  • The Fermi 2 UFSAR, TS Bases, and Amendment No. 51 specify that the Fermi 2 UHS reservoirs can be viewed as a single water source.
  • Because the Fermi 2 UHS reservoirs can be viewed as a single water source, and because a breach of a reservoir below grade is extremely unlikely and would have limited consequences, the reservoirs can safely be permanently cross-connected, such as by removing the four MOVs. Thus, the UHS reservoirs still meet the design requirements in GDCs 2 and 44 and the guidelines of RG 1.27.
  • After the UHS reservoirs are permanently cross-connected, there would be no need to verify operability of the cross-tie lines. Therefore, the deletion of CONDITION A and any reference to the current CONDITION A from TS 3.7.2, along with conforming changes to the remainder of the TS, is appropriate.
  • The deletion of the words "each of' from SR 3. 7.2.1 is appropriate because the reservoirs can be viewed as a single water source.
  • The deletion of the words "and UHS" from SR 3.7.2.4 to verify the correct position of MOVs is appropriate because there would no longer be MOVs in the UHS.

3.2 Technical Conclusion The NRC staff finds that the licensee's proposed amendment to delete CONDITION A from TS 3. 7 .2, along with making conforming changes to the remainder of the TS, and to revise SRs 3.7.2.1 and 3.7.2.4 to reflect that the Fermi 2 UHS is a single water source that has an extremely low probability of, as well as limited consequences from, a below grade reservoir breach is acceptable. A single water source for the UHS can be approved in accordance with RG 1.27 since there is an extremely low probability of losing the capability of the single source.

In addition, the licensee has procedures in place with operator training to provide makeup water from nearby sources. Therefore, based on these considerations, the NRC staff concludes that the proposed changes to TS 3.7.2 and SRs 3.7.2.1 and 3.7.2.4 are acceptable and meet the regulatory requirements and guidelines of 10 CFR 50.36, GDCs 2 and 44, and RG 1.27.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on May 15, 2018. The State official had no comments.

5.0 ENVIRONMENTALCONSIDERATION The amendment changes requirements with respect to the installation or use of facility components 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 published in the Federal Register on September 26, 2017 (82 FR 44850). 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: G. Purciarello, NRR Date of issuance: Jul Y 1 7, 2 O1 8

ML18144A064 *via email OFFICE LPL3/PM LPL3/LA NRR/DSS/SCPB/BC NRR/DSS/STSB/BC NAME SGoetz SRohrer RDennig VCusumano DATE 7/16/18 5/30/18 5/3/18 7/9/18 OFFICE OGC* LPL3/BC LPL/PM NAME JWachutka (NLO) DWrona SGoetz DATE 6/22/18 7/17/18 7/17/18

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