NRC-18-0040, Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

ML18178A134
Person / Time
Site:	Fermi
Issue date:	06/27/2018
From:	Polson K DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-18-0040
Download: ML18178A134 (12)

Text

Keith J. Polson Senior Vice President and CNO DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.1431 Email: keith.polson@dteenergy.com June 27, 2018 NRC-18-0040 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:

Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

References:

1) DTE Electric Letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-17-0067, dated August 31, 2017 (ML17243A422)

2) DTE Electric Letter to NRC, Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-18-0019, dated April 4, 2018 (ML18094A165)

3) DTE Electric Letter to NRC, Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-18-0032, dated May 17, 2018 (ML18138A149)

In Reference 1, DTE Electric Company (DTE) submitted a license amendment request (LAR) to replace existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. In Reference 2, DTE sent a response to a NRC email request for additional information (RAI) from Ms. Sujata Goetz to Mr. Jason Haas dated March 6, 2018 along with supplemental information in support of the LAR. In

USNRC NRC-18-0040 Page 2 Reference 3, DTE sent a response to a NRC email RAI from Ms. Sujata Goetz to Mr.

Jason Haas dated May 9, 2018. Subsequent to this submittal, supplemental information was identified related to the Reference 3 response. The supplemental information for the RAI response is provided in Enclosure 1. to this letter provides the existing TS pages marked to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provided the existing TS Bases pages marked to show the proposed changes for information only.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

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

Executed on June 27, 2018 Keith J. Polson Senior Vice President and CNO

Enclosures:

1. Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages (Clean)

4. Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only) cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-18-0040 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control to NRC-18-0040 Page 1 By application dated August 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A422), DTE Electric Company (DTE or the licensee),

requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, ML16074A448 which changes the technical specifications (TS) for Fermi 2. Your application was also supplement by letter dated April 4, 2018 (ADAMS Accession No. ML18094A165).

RAI EICB-3 In Enclosure 2 of the LAR, page 3.5-11, you proposed to adopt SR 3.5.2.9 (equivalent to TSTF-542 SR 3.5.2.8), which states, Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.

In Enclosure 4 of the LAR, page 3.5.2-9, you provided the associated Bases for SR 3.5.2.9 (similar to TSTF-542 TS bases for SR 3.5.2.8), which states in part:

The required ECCS subsystem is required to actuate on a manual initiation signal. This Surveillance verifies that a manual initiation signal will cause the required CS [Core Spray] subsystems or LPCI [Low Pressure Coolant Injection] subsystem to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions.

You stated in your letter dated April 4, 2018:

Fermi 2 does not have the capability to actuate an entire subsystem of CS or LPCI by a single manual pushbutton, as described in the response to RAI EICB-1. Instead, a CS or LPCI subsystem is actuated by manually controlling each individual component of that subsystem in accordance with approved plant procedures. In this context, the phrase manual initiation channel in the proposed TS Bases page B 3.3.5.3-3 is used to collectively describe all of the individual components required to manually initiate a subsystem and is not intended to imply that pushing one or two buttons actuates an entire subsystem.

Your design description does not align with the TSTF-542 standard technical specifications design description of manual initiation, which assumes that an entire ECCS subsystem can be started automatically with the press of one button. Adoption of language identical to the Standard Technical Specifications when there is a design difference could potentially cause confusion of the requirements. Conversely, in proposed Fermi 2 TS Table 3.3.5.3-1, functions 1.b and 2.b, the manual initiation for the CS and LPCI systems, respectively, each has a caveat; footnote (c) indicates that the manual initiation occurs through manipulation of individual component controls. (A similar footnote is found in current Fermi 2 TS table 3.3.5.1-1.)

Please revise SR 3.5.2.9, and any associated bases, to reflect the appropriate Fermi 2 ECCS manual initiation design requirements.

to NRC-18-0040 Page 2

RESPONSE

Original Response from DTE in NRC-18-0032, dated May 17, 2018:

DTE proposes to revise Technical Specification (TS) Surveillance Requirement (SR) 3.5.2.9, as indicated in Enclosures 2 and 3, to reflect the existing Fermi 2 Emergency Core Cooling System (ECCS) design that manual initiation occurs by means of individual component controls. The proposed SR 3.5.2.9 requires verification that the required ECCS subsystem can be manually operated. The associated TS Bases has similarly been revised as indicated in Enclosure 4 and clarifies that the SR verifies that manual initiation by means of individual component controls will cause the required CS or LPCI subsystems to start and operate. The proposed SR aligns with TS Table 3.3.5.3-1, RPV Water Inventory Control Instrumentation, footnote (c) which states that the Manual Initiation function of CS and LPCI is by means of individual component control and is an acceptable variation from TSTF-542, Revision 2.

DTE has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Sections 3.1 and 4.0 of Enclosure 1 of the Reference 1 LAR. The supplemental information provided in this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

Supplemental Information:

DTE proposes to revise TS SR 3.3.5.3.3 as indicated in Enclosures 2 and 3 to reflect the existing Fermi 2 ECCS design that manual initiation of CS and LPCI occurs by means of individual component controls. The revision to SR 3.3.5.3.3 was identified while preparing station procedures to incorporate the changes required to adopt TSTF-542, Revision 2. The LOGIC SYSTEM FUNCTIONAL TEST proposed by TSTF-542, Revision 2 for SR 3.3.5.3.3 does not apply to Fermi which initiates CS and LPCI subsystems by individual component controls. The LOGIC SYSTEM FUNCTIONAL TEST applies to stations that utilize a pushbutton to initiate the CS and LPCI subsystems. The proposed SR 3.3.5.3.3 as indicated in Enclosures 2 and 3 requires that a CHANNEL FUNCTIONAL TEST be performed in accordance with the Surveillance Frequency Control Program. The SR 3.3.5.3.3 CHANNEL FUNCTIONAL TEST has a frequency of 18 months which differentiates it from the existing CHANNEL FUNCTIONAL TEST for SR 3.3.5.3.2 which has a frequency of 92 days. The associated TS Bases has similarly been revised as indicated in Enclosure 4 to reflect the SR test required to verify the manual initiation of the ECCS subsystems by individual component controls is the CHANNEL FUNCTIONAL TEST. The proposed SR aligns with existing SR 3.3.5.1.6 which is utilized for the ECCS manual initiation functions in Table 3.3.5.1-1 and is an acceptable variation from TSTF-542, Revision 2.

to NRC-18-0040 Page 3 DTE has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Sections 3.1 and 4.0 of Enclosure 1 of the Reference 1 LAR. The additional information provided in this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

Enclosure 2 to NRC-18-0040 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Proposed Technical Specification Changes (Mark-Up)

Revised Page 3.3-49b (3.3.5.3 RPV Water Inventory Control Instrumentation)

NEWTS 3.3.5.3 RPV Water Inventory Control Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

---

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

Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.3 -m--GG G-TEM-FNGT-IeNAE T - In accordance with the Surveillance Frequency Control Program Perform CHANNEL FUNCTIONAL TEST.

Revised Per NRC-18-0040 FERMI - UNIT 2 3.3-49b Amendment No.

Enclosure 3 to NRC-18-0040 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Revised Technical Specification Changes (Clean)

Revised Page 3.3-49b (3.3.5.3 RPV Water Inventory Control Instrumentation)

RPV Water Inventory Control Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated Immediately associated Completion low pressure ECCS Time of Condition C or injection/spray D not met. subsystem inoperable.

SURVEILLANCE REQUIREMENTS

-.----- . .----... -- --------------NOTE-----------------------------

Refer to Table 3.3.5.3-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.3 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program FERMI - UNIT 2 3.3-49b Amendment No.

Enclosure 4 to NRC-18-0040 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Proposed Technical Specification Bases Changes (Mark-Up)

(For Information Only)

Revised Page 3.3.5.3-7 (B 3.3.5.3 RPV Water Inventory Control Instrumentation)

NEW TS 3.3.5.3 Bases RPV Water Inventory Control Instrumentation B 3.3.5.3 BASES SURVEILLANCE REQUIREMENTS (continued)

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.3.2 and SR 3.3.5.3.3 Rvise0d0 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoiht methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Deleted Per NRC-18-0040 Tho1 TliO4 T'C-LGC l' SYTEM FUCI TIOALA TESCT,a .J..c..Rnoi es te-he1 REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

FERMI - UNIT 2 3.3.5.3-7 Revision