Text

License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
	ML15268A149
Person / Time
Site:	Fermi
Issue date:	09/24/2015
From:	Kaminskas V; DTE Electric Company, DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, NRC-15-0090
	Download: ML15268A149 (61)
	v • d • e

Vito.1 Kainskas Site Vice President DTE Energy Company 6400 N. Dixie Highwa, Nwpor, MI 48166 Tel: 734.586.6515 Fax: 734,586.172 Email: kaminskasv'dteenergycom DTE Energy-September 24, 2015 10 CFR 50.90 NRC-15-0090 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Reference:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated February 20, 2013

3) Notice of Availability of the "TSTF-523, 'Generic Letter 2008-01, Managing Gas Accumulation,' Using the Consolidated Line Item Improvement Process," dated January 15, 2014

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, DTE Electric Company (DTE) is submitting a request for an amendment to the Technical Specifications (TS) for Fermi 2.

The proposed amendment would modify TS requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation (Reference 2)." A Notice of Availability of TSTF-523 was published on January 15, 2014 (Reference 3). provides a description and assessment of the proposed change. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. Enclosure 4 is provided for information only.

USNRC NRC-15-0090 Page 2 DTE requests approval of the proposed License Amendment by March 31, 2016, with the amendment being implemented within 90 days.

No new commitments are being made in this submittal.

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

Should you have any questions or require additional information, please contact Mr.

Christopher R. Robinson of my staff at (734) 586-5076.

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

Executed on September 24, 2015 Vito A. K inskas Site Vice President

Enclosures:

1.

Evaluation of the Proposed License Amendment

2.

Marked-up Pages of Existing Fermi 2 TS

3.

Clean Pages of Fermi 2 TS with Changes Incorporated

4.

Marked-up Pages of Existing Fermi 2 TS Bases (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 (kindschlamichigan.gov) '

to NRC-15-0090 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process Evaluation of the Proposed License Amendment to NRC-15-0090 Page 1 Evaluation of the Proposed License Amendment

1. DESCRIPTION The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with Technical Specification Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation DTE Electric Company (DTE) has reviewed the model safety evaluation, dated December 23, 2013 (ADAMS Accession No. ML13255A169), as part of the Federal Register Notice of Availability. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, DTE has concluded that the justifications presented in the TSTF-523 proposal and the model 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 2 Technical Specifications (TS).

2.2 Optional Changes and Variations DTE is not proposing any variations from the TS changes described in the TSTF-523, Revision 2, or the applicable parts of the NRC staffs model safety evaluation dated December 23, 2013 (ADAMS Accession No. ML13255A169).

The Fermi 2 TS utilizes different numbering than the Standard Technical Specifications on which TSTF-523 was based. These differences do not affect the applicability of TSTF-523 to the Fermi 2 TS.

For those cases where an existing surveillance requirement is not being modified and the insertion of a new surveillance requirement would result in renumbering of other surveillance requirements in a specification, DTE proposes to add the new surveillance requirement at the end of the existing surveillance requirements listing for the specification. This will prevent a large administrative impact requiring the potential renumbering of the existing TS surveillance requirements, revision of the associated surveillance procedures, and the revision of other plant operating procedures that refer to these surveillance requirements. These differences are administrative and do not affect the applicability of TSTF-523 to the Fermi 2 TS.

Table 1 provides a comparison between NUREG-1433 and the Fermi 2 Technical Specifications.

to NRC-15-0090 Page 2 Table 1 - Comparison between NUREG-1433 and Fermi 2 Technical Specifications NUREG-1433 TS/TSTF-523 Markup Fermi 2 Equivalent Technical Specifications Markup Specification Title SRs Affected Fermi 2 Specification Title Equivalent Fermi 2 SRs Notes 3.4.8, RHR Shutdown Cooling System -

Hot Shutdown Added 3.4.8.2 3.4.8, RHR Shutdown Cooling System

- Hot Shutdown Added 3.4.8.2 No differences.

3.4.9, RHR Shutdown Cooling System -

Cold Shutdown Added 3.4.9.2 3.4.9, RHR Shutdown Cooling System

- Cold Shutdown Added 3.4.9.2 No differences.

3.5.1, ECCS -

Operating Revised SR 3.5.1.1 3.5.1, ECCS -

Operating Revised SR 3.5.1.3(1)

Different SR numbers.

3.5.1, ECCS -

Operating Revised SR 3.5.1.2 3.5.1, ECCS -

Operating Revised SR 3.5.1.4(1)

The General Electric BWR/4 STS markup included in TSTF-523 for SR 3.5.1.2 adds a new note, which becomes the only note for this SR. The corresponding Fermi 2 SR 3.5.1.4 already includes an existing note. Therefore, the existing note is retained as Note 1, and the new note is labeled as Note 2.

3.5.2, ECCS -

Shutdown Revised SR 3.5.2.3 3.5.2, ECCS -

Shutdown Revised SR 3.5.2.4(1)

Different SR numbers.

to NRC-15-0090 Page 3 NUREG-1433 TS/TSTF-523 Markup Fermi 2 Equivalent Technical Specifications Markup Specification Title SRs Affected Fermi 2 Specification Title Equivalent Fermi 2 SRs Notes 3.5.2, ECCS -

Shutdown Revised SR 3.5.2.4 3.5.2, ECCS -

Shutdown Revised SR 3.5.2.5(1)

The General Electric BWR/4 STS markup included in TSTF-523 for SR 3.5.2.4 adds a new note, which becomes the only note for this SR. The corresponding Fermi 2 SR 3.5.2.5 already includes an existing note. Therefore, the existing note is retained as Note 1, and the new note is labeled as Note 2.

3.5.3, RCIC System Revised SRs 3.5.3.1 and 3.5.3.2 3.5.3, RCIC System Revised SRs 3.5.3.1 and 3.5.3.2 No differences.

3.6.2.3, RHR Suppression Pool Cooling Added new SR 3.6.2.3.2 3.6.2.3, RHR Suppression Pool Cooling Added new SR 3.6.2.3.3(1)

Different SR numbers. New SR 3.6.2.3.3 added at end of SR listing.

3.6.2.4, RHR Suppression Pool Spray Added new SR 3.6.2.4.2 3.6.2.4, RHR Suppression Pool Spray Added new SR 3.6.2.4.3(1)

Different SR numbers. New SR 3.6.2.4.3 added at end of SR listing.

3.9.8, RHR -

High Water Level Added new SR 3.9.8.2 3.9.7, RHR -

High Water Level(1)

Added new SR 3.9.7.2 (1)

Different Specification and SR numbers.

3.9.9, RHR - Low Water Level Added new SR 3.9.9.2 3.9.8, RHR -

Low Water Level(1)

Added new SR 3.9.8.3 (1)

Different Specification and SR numbers.

(1): The Corresponding Fermi 2 specification number and/or SR number are different from those specified in the BWR/4 Standard Technical Specifications (STS) NUREG-1433 that is marked-up in TSTF-523 for the same or equivalent specification.

to NRC-15-0090 Page 4 All surveillance frequencies for the gas accumulation SRs will be 31 days as per the recommendation in TSTF-523. These surveillance frequencies will be controlled by the Surveillance Frequency Control Program change process going forward.

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration DTE requests adoption of TSTF-523, Rev. 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Fermi 2 technical specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

DTE has evaluated whether or not 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises or adds Surveillance Requirement(s) (SRs) that require verification that the Emergency Core Cooling System (ECCS), the Residual Heat Removal (RHR) System, and the Reactor Core Isolation Cooling (RCIC) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR System, and the RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not to NRC-15-0090 Page 5 involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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 change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR System, and the RCIC System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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.

4. 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. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed 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.

to NRC-15-0090 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process Marked-up Pages of Existing Fermi 2 TS

RHR Shutdown Cooling System-Hot Shutdown 3.4,8 SURVEILLANCE REQUIREMENTS SR 3.4.8.1 FERMI

UNIT 2 SURVEILLANCE

* * * * * * * * * * * * * * * * *

NOTE * * * * * * * * * * * * * * * * * * *

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

Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

FREQUENCY In accordance with the Surveillance Frequency Control Program 3.4*20 Amendment No. -+/-J4. 201 In SR 3.4.8.2 ----------------------------NOTE--------------------------------

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

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

ACTIONS (continued)

CONDITION B.

No RHR shutdown B.1 cooling subsystem in operation.

AND No recirculation pump in operation.

AND B.2 AND B.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE RHR Shutdown Cool i ng System-Cold Shutdown 3.4.9 REQUIRED ACTION COMPLETION TIME Initiate action to Immediately restore one RHR shutdown cooling subsystem or one recirculation pump to operation.

Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from coolant circulating discovery of no by an alternate reactor coolant method.

circulation Monitor reactor Once per hour coolant temperature.

FREQUENCY SR 3.4.9.1 Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

In accordance with the Surveillance Frequency Control Program FERMI

UNIT 2 3.4-22 Amendment No. :+/-J4, 201 SR 3.4.9.2 Verify RHR shutdown cooling subsystem locations In accordance susceptible to gas accumulation are sufficiently with the filled with water. Surveillance Frequency Control Program

ECCS-Operat i ng 3.5.1 SURVEILLANCE REQUIREMENTS SR 3. 5.1.1 SR 3. 5.1.2 SR 3. 5.1. 3 FERMI

UNIT 2 SURVEILLANCE Verify correct voltage and breaker alignment to the LPCI swing bus.

* * * * * * * * * * * * * * * * * *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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for completion of the required testing.

FREQUENCY In accordance with the Surveillance Frequency Control Program Perform a functional test of the LPCI swing In accordance bus automatic throwover scheme.

with the Surveillance Frequency Control Program Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

In accordance with the Surveillance Frequency Control Program (continued) 3.5-4 Amendment No. -1J4, 201 locations susceptible to gas accumulation are sufficiently filled with water.

SURVEILLANCE REQUIREMENTS (continued)

SR 3. 5.1.4 SR 3. 5.1. 5 SR 3. 5.1.6 SR 3. 5.1. 7 SURVEILLANCE

* * * * * * * * * * * * * * * * *

NOTE * * * * * * * * * * * * * * * * * * *

Low pressure coolant injection CLPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, and for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after exceeding the RHR cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem manual, power operated. and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify primary containment pneumatic supply pressure is ~ 75 psig.

Verify the RHR System power operated cross tie valve is open.

Verify each recirculation pump discharge valve cycles through one complete cycle of full travel or is de-energized in the closed position.

ECCS-Operating 3.5.1 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

FERMI

UNIT 2 3.5-5 Amendment No. +/-J4, 201 S

1.

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

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 SURVEILLANCE Verify, for each required core spray (CS) subsystem, the:

a.

Suppression pool water level is

~ -66 inches; or b.

* * * * * * * * * * * * * * * *NOTE* * * * * * * * * * * * * * * *

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

Condensate storage tank water level is

~ 19 ft.

Verify correct voltage and breaker alignment to the LPCI swing bus.

Verify, for each required ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

ECCS - Shutdown 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

FERMI

UNIT 2 3.5-10 Amendment No. +/-J4, 201 locations susceptible to gas accumulation are sufficiently filled with water.

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 SURVEILLANCE

* * * * -* -----* * * -* * -NOTE * * * * * ---* * -* * * * * --* -

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.

Verify each required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify each required ECCS pump develops the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD 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

--* * -* * * -* * * * -* --* NOTE * * * * * -* * * * * * * * * * * * *

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

ECCS-Shutdown 3.5.2 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program In accordance with the Surveillance Frequency Control Program FERMI

UNIT 2

3. 5-11 Amendment No. -lJ4 -184, 201 S

1.

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

SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SR 3.5.3.2 SR 3.5.3.3 SR 3.5.3.4 SURVEILLANCE Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve.

Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position. is in the correct position.

* * * * * * - * * * * * * * * -*

NOTE * * * * * * * * * * * * * * * * * * *

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate t9 perform the test.

Verify, with reactor pressure ~ 1045 psig and ~ 945 psig, the RCIC pump can develop a flow rate ~ 600 gpm against a system head corresponding to reactor pressure.

* * * * * * * * * * * * * * * * * *NOTE * * * * * * * * * * * * * * * * * * *

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

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

~ 600 gpm against a system head corresponding to reactor pressure.

RCIC System 3.5.3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

FERMI

UNIT 2 3.5-13 Amendment No. -+/-J4, 201 locations susceptible to gas accumulation are sufficiently filled with water.

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

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

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SR 3.6.2.3.1 SR 3.6.2.3.2 FERMI - UNIT 2 SURVEILLANCE Verify each RHR suppression pool cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

Verify each RHR pump develops a flow rate

~ 10,000 gpm through the associated heat exchanger while operating in the suppression pool cooling mode.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program 3.6-34 Amendment No. +/-d4 +/-9-+/-, 201 SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SR 3.6.2.4.1 SR 3.6.2.4.2 FERMI - UNIT 2 SURVEILLANCE Verify each RHR suppression pool spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

Verify each RHR pump develops a flow rate

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

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Inservice Testing Program 3.6-36 Amendment No. -134, 201 SR 3.6.2.4.3 Verify RHR suppression pool spray subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program

ACTIONS (continued)

CONDITION B.

Required Action and associated Completion B.l Time of Condition A not met.

AND B.2 AND B.3 AND B.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Suspend loading i rradi ated fue 1 assemblies into the RPV.

Initiate action to restore secondary containment to OPERABLE status.

Initiate action to restore one standby gas treatment RHR-High Water Level 3.9.7 COMPLETION TIME Immediately Immediately Immediately subsystem to OPERABLE status.

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

FREQUENCY SR 3.9.7.1 Verify the RHR shutdown cooling subsystem is capable of decay heat removal.

In accordance with the Surveillance Frequency Control Program FERMI

UNIT 2 3.9-11 Amendment No. +/-a4. 201 SR 3.9.7.2 Verify required RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program

SURVEILLANCE REQUIREMENTS SR 3.9.8.1 SR 3.9.8.2 SURVEILLANCE Verify one RHR shutdown cooling subsystem or recirculation pump is operating.

Verify each RHR shutdown cooling subsystem is capable of decay heat removal.

RHR-Low Water Level 3.9.8 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program FERMI

UNIT 2 3.9*14 Amendment No. -134, 201 SR 3.9.8.3 Verify RHR shutdown cooling subsystem locations In accordance susceptible to gas accumulation are sufficiently with the filled with water. Surveillance Frequency Control Program

to NRC-15-0090 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process Clean Pages of Fermi 2 TS with Changes Incorporated

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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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. 134, 21

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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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. 134, 241

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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. 134, 241

ECCS -Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.4

NOTES-----------------

1. Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, and for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after exceeding the RHR cut-in permissive pressure in MODE 3, 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 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. 134, 201

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. 134, 21

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. 134 184, 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure s 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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. 1-34, 201

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 RHR pump develops a flow rate In accordance

> 10,000 gpm through the associated heat with the exchanger while operating in the Inservice 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. 134 191, 201

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. 434, 201

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. 434, 241

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. 134, 241

to NRC-15-0090 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Using the Consolidated Line Item Improvement Process Marked-up Pages of Existing Fermi 2 TS Bases (For Information Only)

RHR Shutdown Cooling System Hot Shutdown B 3.4.8 BASES LCO (continued) common discharge piping. Thus, to meet the LCO, both pumps in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. Each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 3, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Note 1 permits both RHR shutdown cooling subsystems to be shut down for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. Note 2 allows one RHR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 3 with reactor steam dome pressure below the RHR cut in permissive pressure (i.e., the actual pressure at which the interlock resets) the RHR System may be operated in the shutdown cooling mode to remove decay heat to reduce or maintain coolant temperature. Otherwise, a recirculation pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR cut in permissive pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above this pressure because the RCS pressure may exceed the design pressure of the shutdown cooling piping. Decay heat removal at reactor pressures greater than or equal to the RHR cut in permissive pressure is typically accomplished by condensing FERMI - UNIT 2 B 3.4.8-2 Revision 0 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

No changes on this page.

RHR Shutdown Cooling System-Hot Shutdown B 3.4.8 BASES ACTIONS (continued) 8.1. 8.2. and B.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is applicable separately for each occurrence involving a loss of coolant circulation. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient in view of other visual and audible indications available to the operator for monitoring the RHR subsystem in the control room.

This Surveillance is modified by a Note allowing sufficient, time to align the RHR System for shutdown cooling operation after clearing the pressure interlock that isolates the system, or for placing a recirculation pump in operation.

The Note takes exception to the requirements of the FERMI - UNIT 2 B 3.4.8-5 Revision 0

RHR Shutdown Cooling System Hot Shutdown B 3.4.8 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance being met (i.e., forced coolant circulation is not required for this initial 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period), which also allows entry into the Applicability of this Specification in accordance with SR 3.0.4 since the Surveillance will not be "not met" at the time of entry into the Applicability.

REFERENCES None.

FERMI - UNIT 2 B 3.4.8-6 Revision 0 Insert 1

Insert 1 SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is < the RHR cut in permissive pressure. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Shutdown Cooling System - Cold Shutdown B 3.4.9 BASES LCO (continued) in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive components that are assumed not to fail, they are allowed to be common to both subsystems. In MODE 4, the RHR cross tie valve (E1150-F010) may be opened to allow pumps in one loop to discharge through the opposite recirculation loop to make a complete subsystem. Additionally, each shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. In MODE 4, one RHR shutdown cooling subsystem can provide the required cooling, but two subsystems are required to be OPERABLE to provide redundancy. Operation of one subsystem can maintain or reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation is required.

Note 1 permits both RHR shutdown cooling subsystems to be shut down for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

Note 2 allows one RHR shutdown cooling subsystem to be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillance tests. These tests may be on the affected RHR System or on some other plant system or component that necessitates placing the RHR System in an inoperable status during the performance. This is permitted because the core heat generation can be low enough and the heatup rate slow enough to allow some changes to the RHR subsystems or other operations requiring RHR flow interruption and loss of redundancy.

APPLICABILITY In MODE 4, the RHR Shutdown Cooling System may be operated in the shutdown cooling mode to remove decay heat to maintain coolant temperature below 200°F. Otherwise, a recirculation pump is required to be in operation. However, when decay losses to ambient are sufficient to maintain reactor coolant temperature steady at the existing temperature the requirements for the RHR Shutdown Cooling System are not necessary to assure continued safe operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome pressure greater than or equal to the RHR cut in permissive pressure, this LCO is not applicable. Operation of the RHR System in the shutdown cooling mode is not allowed above FERMI - UNIT 2 B 3.4.9-2 Revision 0 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

RHR Shutdown Cooling System - Cold Shutdown B 3.4.9 BASES SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and circulating reactor coolant. The required flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

FERMI - UNIT 2 B 3.4.9-5 Revision 64 Insert 2

Insert 2 SR 3.4.9.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS Operating B 3.5.1 BASES APPLICABLE SAFETY ANALYSES (continued) b.

Maximum cladding oxidation is 0.17 times the total cladding thickness before oxidation; c.

Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react; d.

The core is maintained in a coolable geometry; and e.

Adequate long term cooling capability is maintained.

The limiting single failures are discussed in Reference 11.

The Design Basis Accident recirculation suction line break with the failure of the Division II battery results in the highest nominal peak cladding temperature. One ADS valve failure is analyzed as a limiting single failure for events requiring ADS operation. The remaining OPERABLE ECCS subsystems provide the capability to adequately cool the core and prevent excessive fuel damage.

The ECCS satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Each ECCS injection/spray subsystem and five ADS valves are required to be OPERABLE. The ECCS injection/spray subsystems are defined as the two CS subsystems, the two LPCI subsystems, and one HPCI System. The low pressure ECCS injection/spray subsystems are defined as the two CS subsystems and the two LPCI subsystems.

With less than the required number of ECCS subsystems OPERABLE, the potential exists that during a limiting design basis LOCA concurrent with the worst case single failure, the limits specified in Reference 10 could be exceeded. All ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 10.

LPCI subsystems may be considered OPERABLE during alignment and operation for decay heat removal when below the actual RHR cut in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. At these low pressures and decay heat levels, a reduced complement of ECCS subsystems should provide the required core cooling, thereby allowing operation of RHR shutdown cooling when necessary.

FERMI - UNIT 2 B 3.5.1-5 Revision 55 Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.

ECCS Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note to indicate that when this test results in LPCI inoperability solely for performance of this required Surveillance, 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 for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months until the required testing is completed.

Upon completion of the Surveillance or expiration of the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance the swing bus must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. The LPCI swing bus automatic throwover scheme is typically not inoperable when EDG-12 is paralleled to the bus for testing purposes.

SR 3.5.1.3 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.1.4 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a non-accident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves FERMI - UNIT 2 B 3.5.1-13 Revision 64 The Surveillance Frequency may vary by locations susceptible to gas accumulation.

Insert 3

Insert 3 The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

ECCS Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.

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

This SR is modified by a Note that allows LPCI subsystems to be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the RHR cut in permissive pressure in MODE 3, and for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after exceeding the RHR cut-in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. This allows operation in the RHR shutdown cooling mode during MODE 3, if necessary and sufficient time to restore the system line up to the LPCI mode of operation.

SR 3.5.1.5 Verification that ADS primary containment pneumatic supply pressure is 75 psig ensures adequate air or nitrogen pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least five valve actuations can occur with the drywell at the long term drywell pressure of the design basis small break LOCA analysis (Ref. 15). The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of 75 psig is provided by the primary pneumatic supply system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

FERMI - UNIT 2 B 3.5.1-14 Revision 64 Note 2 exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

This SR has been modified by two Notes.

Note 1

ECCS Shutdown B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 ECCS Shutdown BASES BACKGROUND A description of the Core Spray (CS) System and the low pressure coolant injection (LPCI) mode of the Residual Heat Removal (RHR) System is provided in the Bases for LCO 3.5.1, "ECCS Operating."

APPLICABLE The ECCS performance is evaluated for the entire spectrum of SAFETY ANALYSES break sizes for a postulated loss of coolant accident (LOCA). The long term cooling analysis following a design basis LOCA (Ref. 1) demonstrates that only one low pressure ECCS injection/spray subsystem is required, post LOCA, to maintain adequate reactor vessel water level in the event of an inadvertent vessel draindown. It is reasonable to assume, based on engineering judgement, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level. To provide redundancy, a minimum of two low pressure ECCS injection/spray subsystems are required to be OPERABLE in MODES 4 and 5.

The low pressure ECCS subsystems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Two low pressure ECCS injection/spray subsystems are required to be OPERABLE. The low pressure ECCS injection/

spray subsystems consist of two CS subsystems and two LPCI subsystems. Each CS subsystem consists of two motor driven pumps, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the reactor pressure vessel (RPV). Each LPCI subsystem consists of two motor driven pumps, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valves are not required to be open provided action is taken to assure that OPERABLE LPCI subsystems are capable of injection to the reactor vessel.

FERMI - UNIT 2 B 3.5.2 1 Revision 0 Management of gas voids is important to ECCS injection/

spray subsystem OPERABILITY.

ECCS Shutdown B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

In MODES 4 and 5, the RHR System may operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Therefore, RHR valves that are required for LPCI subsystem operation may be aligned for decay heat removal.

Therefore, this SR is modified by a Note that allows one or both LPCI subsystems of the RHR System to be considered OPERABLE for the ECCS function if all the required valves in the LPCI flow path can be manually realigned (remote or local) to allow injection into the RPV, and the system is not otherwise inoperable. This will ensure adequate core cooling if an inadvertent RPV draindown should occur.

REFERENCES 1.

UFSAR, Section 6.3.2.

FERMI - UNIT 2 B 3.5.2 6 Revision 64 Note 2 exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

This SR has been modified by two Notes.

Note 1

RCIC System B 3.5.3 BASES BACKGROUND (continued)

The RCIC pump is provided with a minimum flow bypass line, which discharges to the suppression pool. The valve in this line automatically opens to prevent pump damage due to overheating when other discharge line valves are closed. To ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is kept full of water. The RCIC System is normally aligned to the CST. The height of water in the CST is sufficient to maintain the piping full of water up to the first isolation valve. The relative height of the feedwater line connection for RCIC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water. Therefore, RCIC does not require a "keep fill" system.

APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no credit is taken in the safety analyses for RCIC System operation. Based on its contribution to the reduction of overall plant risk, however, the system is included in the Technical Specifications, as required by 10 CFR 50.36(c)(2)(ii).

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure

> 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

FERMI - UNIT 2 B 3.5.3-2 Revision 0 Management of gas voids is important to RCIC System OPERABILITY.

RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge line of the RCIC System full of water ensures that the system will perform properly, injecting its full capacity into the Reactor Coolant System upon demand. This will also prevent a water hammer following an initiation signal. One acceptable method of ensuring the line is full is to vent at the high points. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the RCIC System, this SR also includes the steam flow path for the turbine and the flow controller position.

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

FERMI - UNIT 2 B 3.5.3-5 Revision 64 Insert 4 The Surveillance Frequency may vary by locations susceptible to gas accumulation.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

Insert 4 The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a self-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths. The review is supplemented by verification that installed high-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RCIC Systems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

RHR Suppression Pool Cooling B 3.6.2.3 BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break LOCAs. The intent of the analyses is to demonstrate that the heat removal capacity of the RHR Suppression Pool Cooling System is adequate to maintain the primary containment conditions within design limits. The suppression pool temperature is calculated to remain below the design limit.

The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Ref. 1).

To ensure that these requirements are met, two RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies.

Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool cooling subsystem is OPERABLE when one of the pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment and cause a heatup and pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.

ACTIONS A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the 2

FERMI - UNIT 2 B 3.6.2.3 2 Revision 59 Management of gas voids is important to RHR Suppression Pool Cooling System OPERABILITY.

RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE REQUIREMENTS (continued) manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate 9,250 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance required by ASME Code,Section XI (Ref. 3). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

REFERENCES 1.

UFSAR, Section 6.2.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

3.

ASME, Boiler and Pressure Vessel Code,Section XI.

5 FERMI - UNIT 2 B 3.6.2.3 5 Revision 64 Insert 5

Insert 5 SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool cooling subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Suppression Pool Spray B 3.6.2.4 BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break loss of coolant accidents. The intent of the analyses is to demonstrate that the pressure reduction capacity of the RHR Suppression Pool Spray System is adequate to maintain the primary containment conditions within design limits. The time history for primary containment pressure is calculated to demonstrate that the maximum pressure remains below the design limit.

The RHR Suppression Pool Spray System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO In the event of a DBA, a minimum of one RHR suppression pool spray subsystem is required to mitigate potential bypass leakage paths and maintain the primary containment peak pressure below the design limits (Ref. 1). To ensure that these requirements are met, two RHR suppression pool spray subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool spray subsystem is OPERABLE when one of the RHR pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining RHR suppression pool spray subsystems OPERABLE is not required in MODE 4 or 5.

ACTIONS A.1 With one RHR suppression pool spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE RHR suppression pool spray subsystem is adequate to perform the primary containment bypass leakage mitigation function.

However, the overall reliability is reduced because a single FERMI - UNIT 2 B 3.6.2.4 2 Revision 0 Management of gas voids is important to RHR Suppression Pool Spray System OPERABILITY.

RHR Suppression Pool Spray B 3.6.2.4 BASES ACTIONS (continued) that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

SR 3.6.2.4.2 Verifying each RHR pump develops a flow rate 500 gpm while operating in the suppression pool spray mode with flow through the heat exchanger ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by Section XI of the ASME Code (Ref. 3). This test confirms one point on the pump design curve and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, FERMI - UNIT 2 B 3.6.2.4 4 Revision 64 Insert 6

Insert 6 SR 3.6.2.4.3 RHR Suppression Pool Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool spray subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Suppression Pool Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Suppression Pool Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR High Water Level B 3.9.7 BASES LCO (continued) line may be used to allow pumps in one loop to discharge into the opposite loop's recirculation line to make a complete subsystem.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required.

APPLICABILITY One RHR shutdown cooling subsystem must be OPERABLE in MODE 5, with irradiated fuel in the reactor pressure vessel, with the water level 20 ft 6 inches above the top of the RPV flange, and heat losses to ambient not greater than or equal to heat input to the reactor coolant to provide decay heat removal. RHR System requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS); Section 3.5, Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System; and Section 3.6, Containment Systems. RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the reactor pressure vessel and with the water level < 20 ft 6 inches above the RPV flange are given in LCO 3.9.8.

ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, the availability of an alternate method of decay heat removal must be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In this condition, the volume of water above the RPV flange provides adequate capability to remove decay heat from the reactor core.

However, the overall reliability is reduced because loss of water level could result in reduced decay heat removal capability. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is based on decay heat removal function and the probability of a loss of the available decay heat removal capabilities. Furthermore, FERMI - UNIT 2 B 3.9.7 2 Revision 0 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

RHR High Water Level B 3.9.7 BASES SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This Surveillance demonstrates that the RHR shutdown cooling subsystem is capable of decay heat removal.

The verification includes assuring that the shutdown cooling subsystem is capable of taking suction from the reactor vessel and discharging back to the reactor vessel through an RHR heat exchanger with available cooling water. This SR does not require any testing or valve manipulation, rather, it involves verification that those valves not locked, sealed, or otherwise secured in the correct position, can be aligned to the correct position for shutdown cooling operation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None FERMI - UNIT 2 B 3.9.7 4 Revision 64 Insert 7

Insert 7 SR 3.9.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR shutdown cooling subsystem(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Low Water Level B 3.9.8 BASES LCO (continued) opposite loop's recirculation line to make a complete subsystem.

Additionally, each RHR shutdown cooling subsystem is considered OPERABLE if it can be manually aligned (remote or local) in the shutdown cooling mode for removal of decay heat. Operation (either continuous or intermittent) of one subsystem can maintain and reduce the reactor coolant temperature as required. However, to ensure adequate core flow to allow for accurate average reactor coolant temperature monitoring, nearly continuous operation of either an RHR pump or a recirculation pump is required.

Note 1 is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception to shut down the operating subsystem every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Note 2 is provided to allow a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months exception for a single subsystem inoperability due to surveillance testing.

APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one RHR pump or recirculation pump must be in operation in MODE 5, with irradiated fuel in the RPV, with the water level < 20 ft 6 inches above the top of the RPV flange, and heat losses to ambient not greater than or equal to heat input to the reactor coolant to provide decay heat removal. RHR System requirements in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS);

Section 3.5, Emergency Core Cooling Systems (ECCS) and Reactor Core Isolation Cooling (RCIC) System; and Section 3.6, Containment Systems. RHR Shutdown Cooling System requirements in MODE 5 with irradiated fuel in the RPV and with the water level 20 ft 6 inches above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR-High Water Level."

FERMI - UNIT 2 B 3.9.8 2 Revision 0 Management of gas voids is important to RHR Shutdown Cooling System OPERABILITY.

RHR Low Water Level B 3.9.8 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.8.2 This Surveillance demonstrates that the RHR shutdown cooling subsystem is capable of decay heat removal. The verification includes assuring that the shutdown cooling subsystem is capable of taking suction from the reactor vessel and discharging back to the reactor vessel through an RHR heat exchanger with available cooling water. This SR does not require any testing or valve manipulation, rather, it involves verification that those valves capable of being mispositioned are in the correct position.

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

REFERENCES None FERMI - UNIT 2 B 3.9.8 5 Revision 64 Insert 8

Insert 8 SR 3.9.8.3 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

The Surveillance Frequency may vary by location susceptible to gas accumulation.

v t e Letter Sequence Request
CAC:MF6756, Generic Letter 2008-01, Managing Gas Accumulation (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2015-09-24 [Table View]

ML15268A149

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