Text

Submittal of Revision 20 Updated Final Safety Analysis Report, 10CFR50.59 and 10CFR72.48 Evaluation Summary Reports, Commitment Management Report & Revisions to Technical Requirements Manual & Technical Specifications Bases,.
	ML16165A441
Person / Time
Site:	Fermi, 07200071
Issue date:	05/26/2016
From:	Colonnello W A; DTE Energy
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML16165A442	List: ML16165A441; ML16165A445; ML16165A446; ML16165A447; ML16165A448; ML16165A449; ML16165A450; ML16165A451; ML16165A452; ML16165A453; ML16165A454; ML16165A455; ML16165A456; ML16165A457; ML16165A458; ML16165A459; ML16165A460; ML16165A461; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 11; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 12; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 13; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 14; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 15; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, Chapter 17; NRC-16-0034, Fermi 2 Revision 20 to Updated Final Safety Analysis Report, List of Effective Pages; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 1, Introduction and General Description of Plant; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 2, Site Characteristics; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 4, Reactor; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 5, Reactor Coolant System and Connected Systems; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 6, Engineered Safety Features; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 7, Instrumentation and Controls; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 8, Electric Power; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report, Chapter 9, Auxiliary Systems; NRC-16-0034, Fermi, Unit 2, Revision 20 to Updated Final Safety Analysis Report. Appendix a; NRC-16-0034, Fermi, Unit 2, Submittal of Revision 20 Updated Final Safety Analysis Report, 10CFR50.59 and 10CFR72.48 Evaluation Summary Reports, Commitment Management Report & Revisions to Technical Requirements Manual & Technical Specifications Base; NRC-16-0034, Revision 20 to Updated Final Safety Analysis Report, Chapter 10, Steam and Power Conversion System;
References
	NRC-16-0034
	Download: ML16165A441 (199)
	v • d • e

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: polsonk@dteenergy.com

.7 DTE Energy* Security-Related Information

-Withhold Under 10 CFR 2.390 May 26, 2016 NRC-16-0034 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 and 72-71 NRC License No. NPF-43 10 CFR 50.7l(e) 10 CFR 50.59(d)(2) 10 CFR 72.48(d)(2)

Subject:

Submittal of Revision 20 to the Fermi 2 Updated Final Safety Analysis Report (UFSAR), 10 CFR 50.59 and 10 CFR 72.48 Evaluation Summary Reports, Commitment Management Report, Revisions to the Technical Requirements Manual and the Technical Specifications Bases, and a Summary of the Excessive Detail Removed from the UFSAR Pursuant to 10 CFR 50.71(e) and 10 CFR 50.4(b)(6), DTE Electric Company (DTE) hereby submits an electronic version on Compact Discs (CDs) of Revision 20 to the Fermi 2 Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.71(e), Revision 20 of the UFSAR reflects changes made as a result of license amendments and other changes made under the provision of 10 CFR 50.59. Revision 20 includes plant configuration changes made through the end of the seventeenth refueling outage which concluded on November 28, 2015. Sections, Tables, and Figures that have been changed in Revision 20 are marked "REV 20 5/16" in the lower right hand comer of each page and are annotated by revision bars in the appropriate margin. ff/)

Based on NRC Regulatory Issue Summary (RIS) 2015-17, "Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents," DTE has reviewed Revision 20 of the UFSAR for Enclosed CD 1 contains Security-Related Information-Withhold Under 10 CFR 2.390. When separated from CD 1, this document is decontrolled.

J/ltL /J tvl 5.5 USNRC NRC-16-0034 Page2 security-related information (SRI). Consequently, Revision 20 of the UFSAR is being provided on two CDs. One version, on CD 1, contains SRI and should be withheld from public disclosure under 10 CFR 2.390. The information that is SRI is designated by .the statement "Security-Related Information-Withhold Under 10 CFR 2.390" at the top of the page. The second version, on CD 2, redacts the information that is SRI and replaces it with the designation "Security-Related Information

-Withheld Under 10 CFR 2.390." The version on CD 2 is suitable for public disclosure.

This submittal also includes*

six enclosures as described below: Enclosure 1 provides the 10 CFR 50.59 Evaluation Summary Report including brief descriptions of 10 CFR 50.59 Evaluations performed since the previous report submitted with UFSAR Revision 19. This report is being submitted in accordance with the requirements of 10 CFR 50.59( d)(2). Enclosure 2 provides the Commitment Management Report which contains brief summaries of commitments that have been deleted or changed since the previous report submitted with UFSAR Revision 19. DTE's Fermi 2 administrative programs and procedures are consistent with the Nuclear Energy lnstitute's (NEI) "Guidelines for Managing NRC Commitment Changes," NEI 99-04, Revision 0, dated July 1999. Enclosure 3 provides revised pages of Volume I of the Technical Requirements Manual (TRM) issued since the previous report submitted with UFSAR Revision 19. The TRM is incorporated by reference in the UFSAR; therefore, these pages are being submitted in accordance with 10 CFR 50.71(e).

Enclosure 4 provides revised pages of the Technical Specifications Bases (TSB) issued since the previous report submitted with UFSAR Revision 19. These pages are being submitted in accordance with the TSB control program in Technical Specification Section 5.5.10. Enclosure 5 provides a summary of changes made to remove excessive detail from the UFSAR. The removed information was determined to be redundant or obsolete and has been removed in accordance with the guidance contained in NEI 98-03, Revision 1, "Guidelines for Updating Final Safety Analysis Reports," and Regulatory Guide 1.181. Enclosure 6 provides the 10 CFR 72.48 Evaluation Summary Report including brief descriptions of 10 CFR 72.48 Evaluations performed in accordance with the general license under docket number 72-71. This report is being submitted in accordance with the requirements of 10 CFR 72.48( d)(2). Should you have any questions or require additional information, please contact Mr. Scott A. Maglio of my staff at (734) 586-5076.

USNRC NRC-16-0034 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on May 26, 2016 Enclosed CDs: Wayne A. Colonnello Director -Nuclear Work Management For Keith Polson J. Fermi 2 UFSAR Revision 20 (Contains SRI, Not For Public Use) 2. Fermi 2 UFSAR Revision 20 (For Public Use) Additional

Enclosures:

1. 10 CFR 50.59 Evaluation Summary Report 2. Commitment Management Report 3. Summary of Revisions to Technical Requirements Manual, Volume I, and the Revised Pages 4. Summary of Revisions to Technical Specifications Bases and the Revised Pages 5. Summary of Excessive Detail Removed from the Fermi 2 UFSAR 6. 10 CFR 72.48 Evaluation Summary Report cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission*

Regulated Energy Division (kindschl@michigan.gov)

To:

US NRC DTE ENERGY -FERMI 2 AUTOMATED RECORDS MANAGEMENT DISTRIBUTION CONTROL LIST DOCUMENT CONTROL DESK WASHINGTON, DC 20555 Media: 8 x 11 Number DTC Doc. Serial Number Page Rev Copies TDFSAR UFSAR 20 1 Cnt Issue Lvl Date Status US 05/27/16 AFC Please destroy or mark all revised, superseded, or cancelled documents as such. "CONTROLLED" stamps must be voided by lining through and initialing.

DTE -Fermi 2, C/O Info Mgmt 140 NOC, 6400 North Dixie Highway, Newport MI 48166. Call (734) 586-4220 OR (734) 586-4554 for questions or concerns.

ENCLOSURE 1 TO NRC-16-0034 10 CFR 50.59 Evaluation Summary Report Enclosure 1 .to NRC-16-0034 Page 1 50.59 Evaluation No: 50.59 EVALUATION

SUMMARY

I 12-0073 Rev. 0 UFSAR Revision No. NIA Reference Document:

EFA-T41-12-002 TCN T12247 Section(s)

Title of Change: Table(s) Figure Change D Yes (E] No Incorporate Compensatory Measures for Loss of Division 2 Emergency Equipment Cooling Water Temperature Control Valve Temperature Control Function The operability evaluation in engineering functional analysis (EFA) EFA-T41-12-002 Rev. 0 evaluated the acceptability of using operator action in place of normal automatic control of the Division 2 Emergency Equipment Cooling Water (EECW) supply temperature.

The EFA concluded this is acceptable under certain restrictions.

These restrictions include identifying a designated operator on each shift to be in a ready condition to manually control Division 2 EECW supply temperature via throttling of the temperature control valve (TCV) bypass valve. These compensatory measures are implemented under temporary change notice (TCN) T12247 to the Reactor Building Closed Cooling Water (RBCCW)/EECW system operating procedure (SOP), and are restricted to Modes 4 and 5. This 10 CFR 50.59 evaluation was written to evaluate the effects of the compensatory action on the plant. The manual action to be accepted in order to maintain Division 2 EECW operability allows EECW supply temperature to be within a fairly broad range. The established limits allow sufficient time for completion such that time pressure or small unforeseen hindrances will not prevent a successful outcome. Therefore, implementation of the subject compensatory measures is not expected to cause an increase in the likelihood of a malfunction of Division 2 EECW I Emergency Equipment Service Water (EESW), or any other system. Because the required design functions of these systems are maintained, there are no adverse impacts on fission product barriers, or the consequences of previously evaluated events. The temporary manual actions conform to the criteria in NRC Information Notice 97-78 and NEI 96-07, Rev. 1. Therefore, implementation of the compensatory measures evaluated in EFA-T41-12-002 Rev. 0 may be performed without prior NRC approval.

[Note that the compensatory measures described in this evaluation have since been removed due to the repair of the relevant equipment and cancellation of the TCN to the RBCCW/EECW SOP.]

Enclosure 1 to NRC-16-0034 Page2 50.59 EVALUATION

SUMMARY

50.59 Evaluation No: 14-0120 Rev. 0 Reference Document:

TSR-37446 Rev. 0 LCR 14-027-UFS UFSAR Revision No. Section(s) 6.3.2.2.2

6.3 References

7.3.1.2.2.2 Table(s) Figure Change D Yes 20 (!]No Title of Change: Update Design Basis for Automatic Depressurization System High Drywell Pressure Bypass Timer Setpoint to Reflect New Analysis The original basis for the Automatic Depressurization System (ADS) high drywell pressure bypass timer (HDPBT) setpoint has been revalidated analytically including consideration of the uprated and measurement uncertainty recapture (MUR) power level of 3486 MW th. The Nominal, Allowable, and Analytical limits for the timer are unchanged.

Design basis documents are updated to reference the new confirmatory analysis as the basis for the acceptability of the analytical limit for the ADS HDPBT setpoint subject to the nominal uprated and MUR power of 3486 MWth using the SAFER/PRIME methodology which replaces the approved SAFER/GESTR model. The analysis provided in a General Electric-Hitachi (GEH) technical report confirms the pipe break outside containment (PBOC) peak clad temperature resulting from the current 480 second ADS HDPBT analytical setpoint does not exceed the 1600°F acceptance criterion established by the original NRC safety evaluation report (SER) that supported the installation of this setpoint (reference Fermi 2 License Amendment No. 35). On the basis that neither the UFSAR nor the original SER stipulate a required analytical model, and the fact that the model currently employed is specifically designed and approved by the NRC for evaluation of reactor accident/tran'sient fuel response, the use of SAFER/PRIME is not a departure from an approved analytical This evaluation was initiated due to a change in methodology, thus the requirement for a I 0 CFR 50.59 evaluation.

It is concluded that prior NRC approval of this activity is not required.

Enclosure 1 to NRC-16-0034 Page 3 50.59 EVALUATION

SUMMARY

50.59 Evaluation No: 15-0045 Rev. 0 Reference Document:

EOP Program EPGs/SAGs . UFSAR Revision No. Section(s)

Table(s) Figure Change D Yes Title of Change: Emergency Operating Procedure Program Changes The following,changes are being evaluated here: NIA (Kl No 1) Modify emergency depressurization (ED) guidance when alternating current (AC) power is not available to stop the depressurization to support steam driven injection systems, 2) Modify system lists and add additional guidance on isolation/interlocks defeats, 3) Add instruction to vent the containment during loss of AC events to remove decay heat, and 4) Modify high pressure coolant injection (HPCI) caution regarding if exhaust is uncovered.

Emergency operating procedure (EOP) program guidance is derived from Boiling Water Reactor Owners Group (BWROG) emergency procedure guideline (EPGs)/severe accident guidelines (SAGs). The BWROG has revised the EPGs/SAGs from Rev. 2 to Rev. 3. The UFSAR does not describe specific guidance in EOPs; therefore, changes in EPGs/SAGs Rev. 3 do not impact any description or evaluation in the UFSAR. This 10 CFR 50.59 evaluation was performed as a prudent task to assess any impact on plant operation or differences from the NRC safety evaluation report (SER) for EPG Rev. 4. Review of the changes from EPG/SAG Rev. 2 to Rev. 3 determined that stopping ED during loss of AC events, providing additional guidance for isolation defeats, adding instruction to vent containment during loss of AC power, and allowing HPCI continued operation if exhaust is uncovered have less than minimal or no impacts on fission product barriers, or the consequences of any previously evaluated events. EOPs provide instructions to mitigate accidents or events which may degrade into emergencies, both within design and licensing basis and beyond design basis. Events within the design basis are required to be reviewed against the UFSAR. Events that extend beyond the plant design basis are reviewed against the EPG Rev. 4 SER and these changes have no impact on the design and licensing basis described and evaluated in the UFSAR. Therefore, implementation ofEPGs/SAGs Rev. 3 into the EOP program may be performed without prior NRC approval.

Enclosure 1 to NRC-16-0034 Page4 50.59 EVALUATION

SUMMARY

50.59 Evaluation No: 15-0209 Rev. 0 Reference Document:

TSR-37586 Rev. 0 TE-Bl 1-15-064 UFSAR Revision No. Section(s)

Table(s) Figure Change D Yes NIA [!)No Title of Change: Irretrievable Screw Dropped into the Reactor Pressure Vessel During Refueling Outage 17 During Refueling Outage 17 (RFl 7) in October 2015, a 1/8 inch diameter, 1 inch long screw with a 3/8 inch head from an underwater light was dropped into the reactor pressure vessel (RPV) and was not recovered.

Extensive search and recovery efforts were unable to locate the subject screw. The presence of this irretrievable foreign material is being treated as a de facto design change per TSR-37586 Rev. 0 "Documenting Lost Part in the Reactor Vessel." BWRVIP-06-A "BWR Vessel and Internals Project, Safety Assessment ofBWRReactor Internals" provides guidance in Section 4 for consideration of loose parts in the RPV. This section of the document is a generic evaluation applicable to various potential small size pieces of foreign material.

The conclusion of this generic evaluation is that the reviewed scope of foreign material (which bounds the subject screw) would not "negatively affect safe shutdown or increase off-site dose." In the included safety evaluation report (SER), "The NRC staff concludes that the generic safety assessment provided in revised Section 4.0 ofBWRVIP-06-A is applicable

[for BWR/4] plants." The NRC also concluded that because the BWRVIP-06-A evaluation is generalized, "a plant specific safety assessment is required to be performed by the licensee in the event of loose parts being detected." Fermi 2 personnel produced a plant-specific evaluation of the potential impacts of this screw in technical evaluation TE-B 11-15-064, "Supplemental Reactor Cavity Work Light Face Plate Screw Dropped Into Reactor Vessel." This evaluation is complimented by a specific General Electric-Hitachi (GER) lost parts analysis.

These evaluations conclude that the screw may cause low probability operational impacts to the plant, but that it will not affect plant response to postulated accidents and transients.

These evaluations support the as-built justification for the screw provided in TSR-37586 Rev. 0. Because the specific location of the screw is unknown, and the subject evaluations conclude that, though improbable, there is a possibility that the screw could impact some UFSAR described design functions, this design change was screened in, and the 10 CPR 50.59 evaluation was performed.

Operation with foreign material in the RPV process fluid is an undesirable confjguration that has the potential to present certain operational challenges.

Industry operational history indicates that significant impacts to safety-related systems, structures, or components (SSCs) is highly Enclosure 1 to NRC-16-0034 Page 5 improbable.

Postulated impacts are within the bounds of the evaluations of accidents, malfunctions, and events already in the UFSAR. The conclusion of the NRC SER contained in BWRVIP-06-A "BWR Vessel and Internals Project, Safety Assessment of BWR Reactor Internals" which states that "there is no safety concern for interference with MSIV s, control rod operation, damage to reactor internals, corrosion or chemical reaction with other reactor materials, interference with HPCI or RCIC operation, RWCU or RHR isolation valves, nuclear instrumentation, and RHR pumps and heat exchangers.

There could be some possible operating concerns from the potential loose part(s) with regard to fuel fretting, bottom head drain plugging, and recirculation system performance, but none of these are expected to negatively affect safe shutdown or increase in off-site dose." Therefore, it is concluded that continued operation with the irretrievable screw is acceptable without prior NRC approval.

ENCLOSURE 2 TO NRC-16-0034 Commitment Management Report Enclosure 2 to NRC-16-0034 Page 1 Commitment Management Report Fermi 2 administrative programs and procedures are consistent with the Nuclear Energy Institute's (NEI) "Guidelines for Managing NRC Commitment Changes," NEI 99-04, Revision 0, dated July 1999. These guidelines discuss the need for a report to be submitted either annually or along with the UFSAR updates required by 10 CFR 50.71(e).

This report involves changes that have been made in the Fermi 2 commitment management database (referred to as the Regulatory Action Commitment and Tracking System or RACTS). The changes being reported do not affect or change commitments or descriptions currently included in the UFSAR; however, some commitments may be incorporated into the UFSAR. Commitment changes are included in the following two tables:

Table 1: Commitments that have been deleted from the Fermi 2 RACTS database because they are no longer applicable.

Table 2: Commitments that have been revised in the RACTS database.

The table includes the original commitment and reference document in addition to a brief description of the change.

Enclosure 2 to NRC-16-0034 Page2 Table 1 Regulatory Commitments Deleted From the Regulatory Commitment Tracking System (RACTS) -1 RACTS ORIG. REFERENCE DESCRIPTION OF COMMITMENT BASIS FOR DELETION NO. DATE DOCUMENT 01084 10/29/1974 Final Safety Conduct a detailed review of preoperational The commitment was changed to one-time Analysis Report and startup procedures to avoid conditions closed. The detailed review was previously Section 3.9.l.2 of water hammer. completed, and the committed action has been incorporated into UFSAR Section 3.9.1.2. The commitment is fulfilled.

08053 09/14/1987 DTE letter Revise the operating, maintenance, and test The commitment was changed to one-time NRC-87-0156 procedures to prevent isolation of the closed. The procedure changes were in-service makeup tank during Emergency previously completed.

The commitment is Equipment Cooling Water (EECW) testing. fulfilled.

20345 04/24/2014 License Renewal Enhance the Reactor Vessel Surveillance The commitment was changed to one-time Application Program to revise program procedures to closed. As discussed in the response (DTE (DTE letter ensure that new fluence projections through letter NRC-15-0020 dated 3/5/15) to an NRC-14-0028) the period of extended operation and the NRC request for additional information latest vessel beltline adjusted reference (RAI) for license renewal, DTE will -, temperature (ART) tables are provided to continue to follow BWRVIP provisions for the Boiling Water Reactor Vessel and data exchange and no additional Internals Project (BWRVIP) prior to the commitment is necessary to ensure this period of extended operation.

activity will be performed.

The commitment is not needed and is deleted.

Enclosure 2 to NRC-16-0034 Page 3 Table 1 Regulatory Commitments Deleted From the Regulatory Commitment Tracking System (RACTS) RACTS ORIG. REFERENCE DESCRIPTION OF COMMITMENT BASIS FOR DELETION NO. DATE DOCUMENT 20362 01/30/2014 DTE letter DTE committed to follow the schedule The commitment was changed to one-time NRC-14-0007 provided in the NEI Open Phase Condition closed. Revision 1 to the NEI OPC (OPC) Initiative for responding to NRC Initiative (ML15075A456) modified the Bulletin 2012-01. Revision 0 of the NEI schedule such that one of the interim OPC Initiative contained several interim milestones was no longer required.

milestones which were tracked separately in Therefore, the commitment for that specific RACTS. This item (RACTS 20362) was for milestone associated with this RACTS item one specific schedule milestone.

is deleted. The overall commitment to the NEI OPC Initiative is maintained.

88271 05/17/1988 NRC Information Address potential problems resulting from The commitment was changed to one-time Notice 85-35, failures in instrument air system check closed. Surveillance procedures 24.137.02 Supplement 1 valves intended to isolate safety-related air and 43.137.002 were previously created. accumulators under accident conditions.

The commitment is fulfilled.

89176 03/01/1989 DTE letter In response to NRC Generic Letter 88-14, The commitment was changed to one-time NRC-89-0046 DTE committed to perform testing of safety-closed. Surveillance procedures 24.13 7 .02 related air accumulators to assure the check and 43.137.002 were previously created. valve leakage rate is acceptable.

The commitment is fulfilled.

Enclosure 2 to NRC-16-0034 Page 4 Table 1 Regulatory Commitments Deleted From the Regulatory Commitment Tracking System (RACTS) RACTS ORIG. REFERENCE DESCRIPTION OF COMMITMENT BASIS FOR DELETION NO. DATE DOCUMENT 89295 05/18/1989 NRC Information Address potential problems with worn or The commitment was changed to one-time Notice 89-47 distorted hose clamps on self-contained closed. The potential problems with worn breathing apparatus.

or distorted hose clamps were previously addressed by procedures.

In addition, Fermi 2 no longer has self-contained breathing apparatus with tube clamps and the procedures are no longer in use. The commitment is deleted. 90415 11/05/1990 DTE letter Perform inventory of security keycards sent The commitment was changed to one-time NRC-90-0161 offsite. closed. This issue was closed per NRC Inspection Report 90019. In addition, the keycard system has been replaced with a proximity card system that requires activation using hand geometry.

Therefore, the keycard inventory is no longer required and this commitment is deleted. 92048 02/13/1992 NRC Inspection-Resolve identified weaknesses in the The commitment was changed to one-time Report 92002 security contingency training and drill closed. The identified weaknesses were program. The details are considered to be previously resolved and have been safeguards information.

incorporated into the Nuclear Training-Security Training Program. The commitment is fulfilled.

Enclosure 2 to NRC-16-0034 Page 5 Table 1 Regulatory Commitments Deleted From the Regulatory CommitmertfTracking System (RACTS) RACTS ORIG. REFERENCE DESCRIPTION OF COMMITMENT BASIS FOR DELETION NO. DATE DOCUMENT 95074 05/23/1995 DTE letter Revise the procedure for initial training, The commitment was changed to one-time NRC-95-0052 requalification, and firearms policy to closed. The committed actions has been include the physical assessment requirement incorporated into the Nuclear Training -for contract officers prior to an officer Security Training Program. The assuming security duties. commitment is fulfilled.

Enclosure 2 to NRC-16-0034 Page 6 Table 2 Regulatory Commitments Revised in the Regulatory Commitment Tracking System (RACTS) RACTS ORIG. REFERENCE DESCRIPTION OF COMMITMENT BASIS FOR COMMITMENT NO. DATE DOCUMENT CHANGE 20321 04/24/2014 License Renewal Revise Boraflex Monitoring Program The commitment was changed to a one-Application procedures to include areal B-10 density time commitment rather than an ongoing (DTE letter measurement testing of the spent fuel commitment.

As discussed in DTE letter NRC-14-0028) storage racks, such as BADGER testing, at NRC-15-0081, dated 9/24/15, DTE will a frequency of at least once every five replace the Boraflex racks such that years. Boraflex will no longer be required to perform a neutron absorption function.

' The commitment has been revised. 95004 01/19/1995 DTE letter Submit Quality Assurance (QA) Program The requirement to submit the QA NRC-99-0112 approval renewal for radioactive material program approval renewal every five packages every five years. years was based on 10 CFR 71. On June 12, 2015, the NRC issued a final rulemaking to amend 10 CFR 71. The form for approving QA program for radioactive material packages no longer has an expiration date. Licensees are now required to submit reports of QA changes -to the NRC every 24 months per 10 CFR 71.106. The commitment has been revised to comply with the revised 10 CFR 71. ! I I ENCLOSURE 3 TO NRC-16-0034 Summary of Revisions to Technical Requirements Manual, Volume I, and Revised Pages Enclosure 3 to NRC-16-0034 Page 1 Revision 109 02/09/2015 Revision 110 11/20/2015 Summary of the Technical Requirements Manual (TRM) Volume I Changes Revised table TR 3.6.3-1 to update the core spray pump flow test valves stroke times. Revised Core Operating Limits Report (COLR) for Cycle 18, Revision 1 *. The following pages are information only copies of the revised TRM pages for the above revisions.

Pages of the COLR from Revision 110 are not attached.

The COLR is included in Volume I of the TRM for convenience and ease ofreference; however, it is not part of the information incorporated by reference into the UFSAR.

i I I . .-: ., ' i ! TABLE TR3.6.3-1 (Page 2 of 22) Primary Containment Isolation Valves FUNCTION 1. Automatic Isolation Valves<aJ (continued)

c. Group 3 -Residual Heat Removal (RHR) System RHR DryWell Spray Isolation Valves Loop A: E1150-F016A E1150-F021A Loop B: E1150-F016B E1150-F021B RHR Containment Cooling/Test Isolation Valves Loop A: E1150-F024A Loop B: E1150-F024B RHR Suppression Pool Spray Isolation Valves Loop A: El150-F027A Loop B: E1150-F027B RHR Suppression Pool Spray/Test Isolation Valves Loop A: E1150-F028A Loop B: E1150-F028B

d. Group 4 -Residual Heat Removal Shutdown Cooling and Head Spray RHR Shutdown Cooling Suction Isolation Valves Inboard: E1150-F009 outboard:

E1150-F008 RHR Reactor Pressure Vessel Head Spray Isolation Valves Inboard: E1150-F022 Outboard:

El150-F023 e . Group 5 -Core Spray Sys tern Core Spray PUinp Flow Test Valves<*!

Loop A: E2150-F015A Loop B: E2150-F015B

To ensure LPCI response time of 72 seconds per OPL-4. TRM Vol. I TRM 3.6-4 *'. PC IVs TR 3.6.3 MAXIMUM ISOLATION TIME (seconds)

<uJ 150 60 150 60 45* 45* 60 60 45* 45* 51 51 36 120 108 108 (continued)

REV 109 02/15 ENCLOSURE 4 TO NRC-16-0034 Summary of Revisions to Technical Specifications Bases and Revised Pages

*.-, ---.... -----------c----------,.,...--___,.------------------

Enclosure 4 to NRC-16-0034 Page 1 Revision 63 04/28/2015 Revision 64 09/29/2015 Summary of Technical Specification Bases (TSB) Changes Revised Sections B 3.8.4 and 3.8.6 to implement License Amendment 199, Revision of Technical Specification Surveillance Requirements for Direct Current Batteries.

Revised Sections B 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.8, 3.9, and 3 .10 to implement License Amendment 201, Revision to . Technical Specifications by Relocating Surveillance Frequencies to Licensee Control in Accordance with TSTF-425, Revision 3. The following pages are information only copies of the revised TSB pages for the above rev1s1ons.

.1 *i *.i **1 :_:: BASES DC Sources -Operating B 3.8.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS . FERMI

UNIT 2 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. SR 3.8.4.1 Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function.

Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations.

The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 7). SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each inter-cell and termim,il connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

The connection resistance limits procedurally established for this SR are no more than 20% above the resistance as measured during i nsta 11 ati on and not above the ceiling va 1 ue** established by the manufacturer.

This provides conservative measures to assure the Technical Specification limit is not exceeded.

For each inter-cell and terminal connection,*

the limit is 150 micro-ohm.

The total resistance of each 130 VDC battery is also monitored.

This resistance is the total aggregate measured resistance of the cell-to-cell and terminal connections of each 130 VDC battery. The limit for total connection resistance of each 130 VDC battery is 2700 ohm. The Frequency for these inspections, which can detect conditions that can cause power losses due to resistance heating, is 92 days.:: This Frequency is considered acceptable based on operating experience related to detecting corrosion trends. B 3.8.4-5 Revision 63 BASES DC Sources-Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.3 FERMI

UNIT 2 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

The presence of physical damage or deterioration does not necessarily represent a failure of this SR, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function).

The 18 month Frequency is based on engineering judgement, taking into consideration the desired plant conditions to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency.

Therefore, the Frequency is considered acceptable from a standpoint of maintaining reliability.

SR 3.8.4.4 and SR 3.8.4.5 Visual inspection and resistance measurements of inter-cell and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition.

The anti-corrosion material is used to help ensure good electrical connections and to reduce terminal deterioration.

The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.

The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance.

The connection resistance limits procedurally established for this SR are no more than 20% above the resistance as measured during installation, and not above the ceiling value established by the manufacturer.

This provides conservative measures to assure the Technical Specification limit is not exceeded.

For each inter-cell and terminal connection, the limit is 150 micro-ohm.

The total resistance of each 130 VDC battery is also monitored.

This resistance is the total aggregate measured resistance of the cell-to-cell and terminal connections of each 130 VDC battery. The limit for total connection resistance of each 130 VDC battery is 2700 ohm. B 3.8.4-6 Revision 63 I I BASES DC Sources-Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.8 FERMI

UNIT 2 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determi n.e over a 11 battery degradation due to age and usage. The battery perform9nce discharge test is acceptable for satisfying SR 3.8.4.7 as noted in SR 3.8.4.7.

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 7) and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating.

A

capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements. The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 7), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is 10% below the manufacturer's rating. All these Frequencies are consistent with the recommendations in IEEE-450 (Ref. 7). This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance.

B 3.8.4-8 Revision 63

- BASES Battery Cell Parameters B 3.8.6 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. Taking into consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable for operation prior to declaring the DC batteries inoperable.

B.1 When any battery parameter is outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding DC electrical power subsystem must be declared inoperable.

Additionally, other potentially extreme conditions, such as not completing the Required Actions of CoDdition A within the required Completion Time or average electrolyte temperature of representative cells falling below 70°F, also are cause for immediately declaring associated DC electrical power subsystem inoperable.

SR This SR verifies that Category A battery cell parameters are consistent with IEEE*450 (Ref. 3), which recommends regular battery inspections (at least one per month) including voltage, specific gravity, and electrolyte temperature of pilot cells. SR 3.8.6.2 The quarterly inspection of specific gravity and voltage is consistent with IEEE-450 (Ref. 3). In addition, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a battery discharge

< 105 V or a battery overcharge>

145 V, the battery must be demonstrated to meet Category B limits. Transients, such as motor starting transients, which may momentarily cause battery voltage to drop 105 V, do not constitute a battery discharge

provided the battery terminal voltage and float current B 3.8.6*3 Revision 63 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.1.2.1 Reactivity Anomalies B 3.1.2 Verifying the reactivity difference between the monitored and predicted reactivity is within the limits of the LCO provides added assurance that plant operation is maintained within the assumptions of the DBA and transient analyses.

A comparison of the monitored reactivity to the predicted reactivity at the same cycle exposure is used to calculate the reactivity difference.

The comparison is required when the core reactivity has potentially changed by a significant amount. This may occur following a refueling in which new fuel assemblies are loaded, fuel assemblies are shuffled within the core, or fuel assemblies are removed and reinserted as when control rods are replaced or shuffled.

Also, core reactivity changes during the cycle. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval after reaching equilibrium conditions following a startup is based on the need for equilibrium xenon concentrations in the core, such that an accurate comparison between the monitored and predicted reactivity can be made. For the purposes of this SR, the reactor is assumed to be at equilibrium conditions when steady state operations (no control rod movement or core flow changes) at 80% RTP have been obtained.

This comparison requires the core to be operating at power levels which minimize the uncertainties and measurement errors, in order to obtain meaningful results. Therefore, the comparison is only done when in MODE 1. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1. 10 CFR 50, Appendix A, GDC 26, GDC 28, and GDC 29. , 2. UFSAR, Chapter 15. B 3.1.2-5 Revision 64 BASES Control RodiOPERABILITY B 3.1.3 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 Condition D is modified by a Note indicating that the Condition is not applicable when> 10% RTP, since the prescribed withdrawal sequence is not required to be followed under these conditions, as described in the Bases for LCO 3.1.6. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is acceptable, considering the low probability of a CRDA occurring.

E.1 If any Required Action and associated Completion Time of Condition A, C, or D are not met, or there are nine or more inoperable rods, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . -This ensures all insertable control rods are inserted and places the reactor in a condition that does not require the active function (i.e., scram) of the control rods. The number of , control rods permitted to be inoperable when operating above 10% RTP (e.g., no CRDA considerations) could be more than the value specified, but the occurrence of a large number of inoperable control rods could be indicative of a generic problem, and investigation and resolution of the potential problem should be undertaken.

The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems. SR 3.1.3.1 The position of each control rod must be determined to ensure adequate information on control rod position is available to the operator for determining CRD OPERABILITY and controlling rod patterns.

Control rod position may be determined by the use of OPERABLE position indicators, by moving control rods to a position with an OPERABLE indicator, or by the use of other appropriate methods. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.1.3-7 Revision 64 BASES Control Rod OPERABILITY B 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.3.2 FERMI

UNIT 2 Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position.

This ensures the control rod is not stuck and _is free to insert on a scram signal. These Surveillances are not required when THERMAL POWER is less than or equal to the actual LPSP of the RWM, since the notch insertions may not be compatible with the requirements of the prescribed withdrawal sequence (LCD 3.1.6) and the RWM (LCD 3.3.2.1).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. At any time, if a withdrawn control rod is immovable, a determination of that control rod's ability to insert on a scram (OPERABILITY) . must be made and appropriate action taken. SR 3.1.3.3 Verifying that the scram time for each control rod to notch position 06 is 7 seconds provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing its shutdown function.

This SR is performed in conjunction with the control rod scram time testing of SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4. The LOGIC SYSTEM FUNCTIONAL TEST in LCD 3.3.1.1, "Reactor Protection System (RPS) Instrumentation, " that over 1 aps this Survei 11 ance and the functional testing of SDV vent and drain valves in LCD 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," provide complete testing of the assumed safety function.

The associated Frequencies are acceptable, considering the more frequent testing performed to demonstrate other aspects of control rod OPERABILITY and operating experience, which shows scram times do not significantly change over an operating cycle. B 3.1.3*8 Revision 64 i *' . *1 *1 I ' BASES Control Rod Scram Times B 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.4.2 FERMI

UNIT 2 Additional testing of a sample of control rods is required to verify the continued performance of the scram function during the cycle. A representative sample contains at least 10% of the control rods 19 control rods tested). The sample remains representative if no more than 7.5% of the control rods in the sample tested are determined to be "slow" or inoperable.

With more than 7.5% of the sample declared to be "slow" or inoperable per the criteria in Table 3.1'.4*1, additional control rods are tested until this 7.5% criterion (e.g., 7.5% of the entire sample size) is satisfied, or until the total number of "slow" and inoperable control rods (throughout the core, from all surveillances) exceeds the LCO limit. For planned testing, the control rods selected for the sample should be different for each test and should be in addition to any scram time testing required to satisfy SR 3.1.4.4 following work on control rods or the CRD System that could affect scram times. Data from scrams should be used whenever possible to avoid unnecessary testing at power, even if the control rods with data may have been previously tested in a sample. If data is captured from a reactor scram, all rods are available for selection in the next required test sample. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.1.4.3 When work that could affect the scram insertion time is performed on a control rod or the CRD System, testing must be done to demonstrate that each affected control rod retains adequate scram performance over the range of applicable reactor pressures from zero to the maximum permissible pressure.

The scram testing must be performed once before declaring the control rod OPERABLE.

The required scram time testing must demonstrate the affected control rod is still within acceptable limits. The limits for reactor pressures

< 800 psig are established and ' maintained within approved plant procedures based on a high probability of meeting the acceptance criteria at reactor B 3.1.4*5 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 SR 3.1.5.1 Control Rod Scram Accumulators B 3.1.5 SR 3.1.5.1 requires that the accumulator pressure be checked periodically to ensure adequate accumulator pressure exists to provide sufficient scram force. The primary indicator of accumulator OPERABILITY is the accumulator pressure.

A minimum accumulator pressure is specified, below which the capability of the accumulator to perform its intended function becomes degraded and the accumulator is considered inoperable.

The minimum accumulator pressure of 940 psig is established to assure a margin of accumulator.OPERABILITY sufficient to scram the associated control rod (Ref; 1). Declaring the accumulator inoperable when the minimum pressure is not maintained ensures that significant degradation in scram times does not occur. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 4.5.2.2.3.

2. UFSAR, Chapter 15. B 3.1.5-5 Revision 64 L_ BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.1.6.1 Rod Pattern Control B 3.1.6 The control rod pattern is periodically verified to be in compliance with the prescribed withdrawal sequence to ensure the assumptions of the CRDA analyses are met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The RWM provides control rod blocks to enforce the required sequence and is required to be OPERABLE when operating at s 10% RTP. 1. NEDE*24011*P*A*9*US, "General Electric Standard Application for Reactor Fuel, Supplement for United States," Section S.2.2.3.1, September 1988. 2. "Modi fi cations to the Requirements for Contra 1 Rod Drop Accident Mitigating System," BWR Owners Group, July 1986. 3. NUREG-0979, Section 4.2.1.3.2, April 1983. 4. NUREG*0800, Section 15.4.9, Revision 2, July 1981. 5. 10 CFR 100.11. 6. NED0*21778*A, "Transient Pressure Rises Affected Fracture Toughness Requirements for Boiling Water Reactors," December 1978. 7. ASME, Boiler and Pressure Vessel Code. 8. NED0-21231, "Banked Position Withdrawal Sequence," January 1977. 83.1.6*5 Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 SR 3.1.7.1, SR 3.1.7.2, and SR 3.1.7.3 SLC System B 3.1.7 SR 3.1.7.1 through SR 3.1.7.3 verify certain characteristics of the SLC System (e.g., the volume and temperature of the borated solution in the storage tank), thereby ensuring SLC System OPERABILITY without disturbing normal plant operation.

These Surveillances ensure that the proper borated solution .volume and temperature, including the temperature of the pump suction piping, are maintained.

Maintaining a minimum specified borated solution temperature is important in ensuring that'the boron remains in solution and does not precipitate out in the storage tank or in the pump suction piping. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.1.7.4 and SR 3.1.7.6 SR 3.1.7.4 verifies the continuity of the explosive charges in the injection valves to ensure that proper operation will occur if required.

Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed .. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.1.7.6 verifies that each manual valve in the system is in its correct position, but does not apply to the squib (i.e., explosive) valves. Verifying the correct alignment for manual valves in the SLC System flow path provides assurance that the proper flow paths will exist for system operation.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position locally by a dedicated operator at the valve control. This. is acceptable since the SLC System is a manually initiated system. This Surveillance also does not apply to valves that are locked, sealed, or otherwise secured in position since they are verified to be in the correct position prior to locking, sealing, or securing.

This verification of valve alignment 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. B 3.1.7-4 Revision 64 BASES SLC System B 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SR* 3.1. 7 .5 FERMI

UNIT 2 This Surveillance requires an examination of the sodium pentaborate solution by using chemical analysis to ensure that the proper concentration of boron exists in the storage tank. SR 3.1.7.5 must be performed anytime boron or water is added to the storage tank solution to determine that the boron solution concentration is within the specified limits. SR 3.1.7.5 must also be performed anytime the temperature is restored to 48°F to ensure that no significant boron precipitation occurred.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.1. 7.7 Demonstrating that each SLC System pump develops a flow rate 41.2 gpm at a discharge pressure 1215 psig ensures that pump performance has not degraded during the fuel cycle. This minimum pump flow rate requirement ensures that, when combined with the sodium pentaborate solution concentration requirements, the rate of negative reactivity insertion from the SLC System will adequately compensate for the positive reactivity effects encountered during power reduction, cooldown of the moderator, and xenon decay. This test confirms one point on the pump design curve and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this Surveillance is in accordance with the Inservice Testing Program. SR 3.1.7.8 and SR 3.1.7.9 These Surveillances ensure that there is a functioning flow path from the boron solution storage tank to the RPV, including the firing of an explosive valve. The replacement charge for the explosive valve shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of that batch successfully fired. B 3.1.7-5 Revision 64 BASES SLC System B 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance may be performed in separate steps to prevent injecting boron into the RPV. An acceptable method for verifying flow from the pump to the RPV is to pump demineralized water from a test tank through one SLC subsystem and into the RPV. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Demonstrating that all piping between the boron solution storage tank and the explosive valve is unblocked ensures that there is a functioning flow path for injecting the sodium pentaborate solution.

An acceptable*method for verifying that the suction piping is unblocked is to pump from the storage tank to the test tank (this is followed by draining and flushing the piping with demineralized water). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This is especially true in light of the temperature verification of this piping required by SR 3.1.7.3. However, if, in performing SR 3.1.7.3, it is determined that the temperature of this piping has fallen below the specified minimum, SR.3.1.7.9 must be performed once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the piping temperature is restored to 48°F. SR 3.1. 7 .10 Enriched sodium pentaborate solution is made by mixing granular, enriched sodium pentaborate with water. Isotopic tests on the granular sodium pentaborate to verify the actual B-10 enrichment must be performed prior to addition to the SLC tank in order to ensure that the proper B-10 atom percentage is being used. B 3.1.7-6 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.1.8.1 SDV Vent and Drain Valves B 3.1.8 During normal operation, the SDV vent and drain valves should be in the open position (except when closed intermittently under administrative control for testing) to allow for drainage of the SDV piping. Verifying that each valve is. in the open position ensures that the SDV vent and drain valves will perform their intended functions during normal operation.

This.SR does not require any testing or valve manipulation; rather, it involves verification that the valves are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.1.8.2 SR 3.1.8.2 is an integrated test of the SDV vent and drain valves to verify total system performance.

After receipt of a simulated or actual scram signal, the closure of the SDV vent and drain valves is verified.

The closure time of 30 seconds after receipt of a scram signal is based on the bounding leakage case evaluated in the accident analysis.

Similarly, after receipt of a simulated or actual scram reset signal, the opening of the SDV vent and drain valves .is verified.

The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1 that overlaps this Surveillance and the scram time testing of control rods in LCO 3.1.3 to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 4.5.2.2.2.3.

2. 10 CFR 100. 3. NUREG-0803, "Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping," August 1981. 4. 10 CFR 50.67 83.1.8-4 Revision 64 BASES ACTIONS SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 A.1 APLHGR B 3.2.1 If any APLHGR exceeds the required limits, an assumption regarding an initial condition of the DBA and transient analyses may not be met. Therefore, prompt action should be taken to restore the APLHGR(s) to within the required limits such that the plant operates within analyzed conditions and within design limits of the fuel rods. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is sufficient to restore the APLHGR(s) to within its limits and is acceptable based on the low probability of a transient or DBA occurring simultaneously with the APLHGR out of specification.

B.1 If the APLHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems. SR 3 .2.1.1 APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter.

They are compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to fuel design limits at 19w power levels. B 3.2.1-3 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.2.2.1 MCPR B 3.2.2 The MCPR is required to be initially calculated within . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter.

It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis.

The Surveillance Frequency is contra 11 ed under the Surveil 1 ance Frequency Control Program. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to the MCPR safety limit at low power levels. SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis.

SR 3.2.2.2 determines the value which is a measure of the actual scram speed distribution compared with the assumed distribution.

> 0, the MCPR operating limit is then determined based on an interpolation between the applicable limits for TRACG Option A (scram times of LCO 3.1.4, "Control Rod Scram Times") and TRACG Option B (realistic scram times) analyses.

The parameter and MCPR operating limit must be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1, SR 3.1.4.2, and SR 3.1.4.4 because the effective scram speed distribution may change during the cycle. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively minor changes expected during the fuel cycle. 1. NUREG-0562, June 1979. 2. NED0*24011*P*A, "General Electric Standard Application for Reactor Fuel" (latest approved version).

3. UFSAR, Chapter 4. 4. UFSAR, Chapter 6. 5. UFSAR, Chapter 15. B 3.2.2*4 Revision 64 BASES APPLICABILITY ACTIONS SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 LHGR B 3.2.3 The LHGR limits are primarily derived from fuel desi"gn and transient analyses that are assumed to occur at high power level conditions.

At core thermal power levels < 25% RTP, the reactor is operating with a substantial margin to the fuel design limits and, therefore, the Specification is only required when the reactor is operating 25% RTP. A.l If any LHGR exceeds its required limit, an assumption regarding an initial condition of the fuel design and transient analyses is not met. Therefore, prompt action should be taken to restore the LHGR(s) to within its required limits such that the plant is operating within analyzed conditions.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is normally sufficient to restore the LHGR(s) to within its limits and is acceptable based on the low probability of a transient or Design Basis Accident occurring simultaneously with the LHGR out of specification.

B.1 . If the LHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER is reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . *The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER TO < 25% RTP in an orderly manner and without challenging plant systems. SR 3.2.3.1 The LHGR is required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter.

It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to operating limits at lower power levels. B 3.2.3*3 Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 RPS Instrumentation B 3.3.1.1 As noted at the beginning of the SRs, the SRs for each RPS instrumentation Function are located in the SRs column of Table 3.3.1.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , provided the associated Function maintains RPS trip capability.

For the case of the APRM Functions 2.a, 2.b, 2.c, and 2.d, RPS trip capability is maintained with any two OPERABLE APRMs remaining.

Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 9) assumption of the average time required to perform channel Surveillance.

That analysis demonstrated that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months testing allowance does not significantly reduce the probability that the RPS will trip when necessary.

SR 3.3.1.1.1 and SR 3.3.1.1.2 Performance of the CHANNEL CHECK ensures that a gross I* failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring B 3.3.l.1-25a Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated' with the channels required by the LCO. SR 3 . 3 . 1. 1. 3 To ensure that the APRMs are accurately indicating the true core average power, the APRMs are calibrated to the reactor power calculated from a heat balance when 25% RTP. The Surveillance Frequency js controlled under the Surveillance Frequency Control Program. A restriction to satisfying this SR when < 25% RTP is provided that requires the SR to be met only 25% RTP because it is difficult to accurately maintain APRM indication of core THERMAL POWER consistent with a heat balance when < 25% RTP. At low power levels, a high degree of accuracy is unnecessary because of the large, inherent margin to thermal .limits (MCPR, LHGR, and APLHGR). At 25% RTP, the Surveillance is required to have been satisfactorily performed in accordance with SR 3.0.2. A Note is provided which allows an increase in THERMAL POWER above 25% if the Frequency is not met per SR 3.0.2. In this event, SR must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reaching or exceeding 25% RTP. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR. B 3 . 3 .

1. 1

26 Revision 64

. BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3. 3 .1.1. 4

FERMI -UNIT 2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

setpoint methodology.

As noted, SR 3.3.1.1.4 is not required to be performed when entering MODE 2 from MODE 1, since testing of the MODE 2 required IRM Functions cannot be performed in MODE 1 without utilizing jumpers, lifted leads, or movable links. This allows entry into MODE 2 if the 7 day Frequency is not met per SR 3.0.2. In this event, the SR must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 2 from MODE 1. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR. The Survei n ance Frequency is* controlled under the .Surveillance Frequency Control Program. SR 3. 3 . 1. 1. 5 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

In accordance with Reference 9, the scram contactors must be tested as part of the Manual B 3.3.1.1-27 Revision 64 BASES RPS Instrumentation B 3.3.1.l SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 Scram Function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.1.6 and SR 3.3.1.1.7 These Surveillances are established to ensure that no gaps in neutron flux indication exist from subcritical to power operation for monitoring core reactivity status. The overlap between SRMs and IRMs is required to be demonstrated to ensure that reactor power will not be increased into a neutron flux region without adequate indication.

This is required prior to fully withdrawing SRMs from the core since indication is being transitioned from the SRMs to the IRMs. The overlap between IRMs and APRMs is of concern when reducing power into the IRM range. On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not maintained.

Overlap between IRMs and APRMs exists when sufficient IRMs and APRMs concurrently have onscale readings such that the transition between MODE 1 and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block. Overlap between SRMs and IRMs similarly exists when,.prior to fully withdrawing the SRMs from the core, IRMs are above the downscale rod block and show increasing flux on range 1 before SRMs have reached 1/2 decade below the upscale rod block. As noted, SR 3.3.1.1.7 is only required to be met during entry into MODE 2 from MODE 1. That is, after the overlap requirement has been met and indication has transitioned to the IRMs, maintaining overlap is not required (APRMs may be reading downscale once in MODE 2). If overlap for a group of channels is not demonstrated (e.g., IRM/APRM overlap), the reason for the failure of the Surveillance should be determined and the appropriate channel(s) declared inoperable.

Only those appropriate channels that are required in the current MODE or condition should be declared inoperable. B 3 . 3 .

1. 1*28 Revision 64 BASES RPS Instrumentation B 3.3.1.l SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under.the Surveillance Frequency Control Program. SR 3 . 3 . 1. 1. 8 LPRM gain settings are determined from the core power distribution calculated by the core monitoring system based on the local flux profiles measured by the Traversing Incore Probe (TIP) System. This establishes the relative local flux profile for appropriate representative input to the APRM System. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.1.9 and SR 3.3.1.1.13 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a cha.nnel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL _ FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3 . 3 .

1. 1-29 Revision 64 BASES RPS Instrumentation B 3.3.1.l SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 SR 3 . 3 . 1. 1. 10 This Surveillance provides a check of the actual trip setpoints.

The channel must be declared inoperable if the . trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.1.1*1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety

analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoi nt met ho.do logy. The Surveillance Frequency is contra 11 ed under the Surveillance Frequency Control Program. SR 3.3.1.1.11 and SR 3.3.1.1.14 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel . responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

SR 3.3.1.1.11 Note 1 states that neutron detectors are excluded from CHANNEL CALIBRATION because they are passive devices, with minimal drift, and because of the difficulty of simulating a meaningful signal. Changes in neutron detector sensitivity are compensated for by performing the calorimetric calibration (SR 3.3.1.1.2 and the LPRM calibration against the TIPs (SR 3.3.1.1.8).

SR 3.3.1.1.11 Note 2 is provided that requires the IRM SR to be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of entering MODE 2 from MODE 1. Testing of the MODE 2 !RM Function cannot be performed in MODE 1 without utilizing jumpers, lifted leads, or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR. B 3.3.1.1*30 Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.1.12 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

For the APRM Functions, this test supplements the automatic self*test functions that operate continuously in the APRM and voter channels.

The APRM CHANNEL FUNCTIONAL TEST covers the APRM channels (including for Function 2.b only, the recirculation flow input function excluding the flow transmitter), the 2*out-of-4 voter channels, and the interface connections to the RPS trip systems from the voter channels.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. (NOTE: The actual voting logic of the 2-out*of *4 voter channels is tested as part of SR 3.3.1.1.19.)

For Function 2.a, a Note that requires this SR to be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of entering MODE 2 from MODE 1 is provided.

Testing of the MODE 2 APRM Function cannot be performed in MODE 1 without utilizing jumpers or lifted leads. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. SR 3.3.1.1.15 and SR 3.3.1.1.19 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The functional testing of control rods (LCO 3.1.3), and SDV vent and drain valves (LCO 3.1.8), overlaps this Surveillance to provide complete testing of the assumed safety function.

For the 2-out-of-4 Voter Function, the LSFT includes simulating APRM and OPRM trip conditions at the APRM channel inputs to the 2*out*of-4 trip voter channel to check all combinations of two tripped inputs to the 2-out*of*4 trip voter logic in the voter channels.

B 3.3.1.1-31 Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.1.16 This SR ensures that scrams initiated from the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure Functions will not be inadvertently bypassed when THERMAL POWER 29.5% RTP. This involves calibration of the bypass channels.

Adequate margins for the instrument setpoint methodologies are incorporated into the actual setpoint.

Additionally,.

consideration is given to the fact that main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure:

where turbine first stage pressure of 161.9 psig conservatively correlates to 29.5% RTP), the main turbine bypass valves must remain closed at THERMAL POWER 29.5% RTP to ensure that the calibration remains valid. If any bypass channel's setpoint is nonconservative (i.e., the Functions are bypassed 29.5% RTP, either due to open main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure Functions are considered inoperable.

Alternatively, the bypass channel can be placed in the conservative condition (nonbypass).

If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.1.1-32 Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.1.17 FERMI -UNIT 2 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.

This test may be performed in one measurement or in overlapping segments, with verification that all components are tested. The RPS RESPONSE TIME acceptance criteria are included in Reference

10. RPS RESPONSE TIME for the APRM 2*out*of*4 Voter Function includes the output re*l ays of the voter and the associated RPS relays and contactors. (The digital portion of the APRM and 2*out-of*4 voter channels are excluded from the RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.)

Confirmation of the time base is adequate to assure required response times are met. As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time. The sensors and relays/logic components for Functions 3 and 4 are assumed to operate at the design response time. This allowance is supported by References 12 and 21, which determined that significant degradation of the channel response time can be detected during perfo'rmance of other Technical Specification SRs.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3 . 3 .

1. 1*33 Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3. 3. 1. 1. 18 FERMI -UNIT 2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology, For the APRM Simulated Thermal Power -Upscale Function, this SR also includes calibrating the associated recirculation loop flow channel. SR 3.3.1.1.18 is modified by a Note that states that neutron detectors are excluded from CHANNEL CALIBRATION because they are passive devices, with minimal drift, and because of the difficulty of simulating a meaningful signal. Changes in neutron detector sensitivity are compensated for by performing the calorimetric calibration (SR 3.3.1.1.3) and the LPRM calibration against the TIPs (SR 3.3.1.1.8).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Surveillance Requirement SR 3.3.1.1.18 for Function 2.b is modified by two Notes as identified in Table 3.3.1.1-1.

The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as*found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology, The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channe 1 to service. For c.hanne 1 s determined to be OPERABLE but degraded, after returning the channel to service the performance of these channe 1 s wi 11 be eva 1 uafed under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance B 3 . 3 .

1. 1-34 Revision 64 BASES RPS Instrumentation B 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint.

This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the NTSPs and the methodologies for calculating the as-left and the as-found tolerances be in the Technical Requirements Manual. SR 3.3.1.1.20 This SR ensures that scrams initiated from OPRM Upscale Function (Function 2.f) will not be inadvertently bypassed when THERMAL POWER, as indicated by the APRM Simulated Thermal Power, is > 27.5% RTP and recirculation drive flow is < 60% rated flow. This normally involves confirming the bypass setpoints.

The bypass setpoint values are considered to be nominal values as discussed in Reference 20, and have been adjusted for power uprate. The surveillance ensures that the OPRM Upscale Function is enabled (not bypassed) for the correct values of APRM Simulated Thermal Power and recirculation .drive flow. If any bypass setpoi nt *is nonconservative ( i . e. , the OPRM Upscale Function is bypassed when APRM Simulated Thermal Power> 27.5% and recirculation drive flow< 60% rated), then the affected channel is considered inoperable for the OPRM Upscale Function.

Alternatively, the bypass setpoint may be adjusted to place the channel in a conservative condition (unbypassed).

If placed in the unbypassed condition, this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.1.1-35 Revision 64 BASES SRM Instrumentation B 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3 . 3 .1. 2 . 2 To provide adequate coverage of potential reactivity changes in the core, one SRM is required to be OPERABLE in the quadrant where CORE ALTERATIONS are being performed, and the other OPERABLE SRM must be in an adjacent quadrant containing fuel. Note 1 states that the SR is required to be met only during CORE ALTERATIONS.

It is not required to be met at other times in MODE 5 since core reactivity changes are not occurring.

This Surveillance consists of a review of plant logs to ensure that SRMs required to be OPERABLE for given CORE ALTERATIONS are, in fact, OPERABLE.

In the event that only one SRM is required to be OPERABLE, per Table 3.3.1.2*1, footnote (b), only the a. portion of this SR is required.

Note 2 clarifies that more than one of the three requirements can be met by the same OPERABLE SRM. The Survei 11 ance Frequency is contra 11 ed under the Surveillance Frequency Control Program. B 3.3.1.2-6 Revision 64 BASES SRM Instrumentation B 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 1. 2 .4 FERMI -UNIT 2 This Surveillance consists of a verification of the SRM instrument readout to ensure that the SRM reading is greater than a specified minimum *count rate, which ensures that the detectors are indicating count rates indicative of neutron flux levels within the core. With few fuel assemblies loaded, the SRMs will not have a high enough count rate to satisfy the SR. Therefore, allowances are made for loading sufficient irradiated fuel assemblies, to establish the minimum count rate. To accomplish this, the SR is modified by a Note that states that the count rate is not required to be met on an SRM that has less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies are in the associated core quadrant.

With four or less fuel assemblies loaded around each SRM and no other fuel assemblies in the associated core quadrant, even with a control rod withdrawn, the configuration will not be critical.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.2.5 and SR 3.3.1.2.6 Performance of a CHANNEL FUNCTIONAL TEST demonstrates the associated channel will function properly.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

SR 3.3.1.2.5 is required in MODE 5, and ensures that the channels are OPERABLE while core reactivity changes could be in progress.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.1.2-7 Revision 64 BASES SRM Instrumentation B 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 SR 3.3.1.2.6 is required in MODE 2 with IRMs on Range 2 or below, and in MODES 3 and 4. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Verification of the signal-to-noise ratio also ensures that the detectors are inserted to an acceptable operating level. In a fully withdrawn condition, the detectors are sufficiently removed from the fueled region of the core to essentially eliminate neutrons from reaching the detector.

Any count rate obtained while the detectors are fully withdrawn is assumed to be "noise" only. The Note to SR 3.3.1.2.5 and Note 1 to SR 3.3.1.2.6 modify this requirement to not require the signal-to-noise ratio to be determined when the associated SRM count rate is 3.0 cps. This is acceptable since there is no limitation on signal* to-noise ratio when the SRM is 3.0 cps. . The Note 2 to SR 3.3.1.2.6 allows the Surveillance to be delayed until entry into the specified condition of the Applicability (THERMAL POWER decreased to IRM Range 2 or . below). The SR must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after IRMs are on Range 2 or below. The allowance to enter the Applicability with the Frequency not met is reasonable, based on the limited time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed after entering the Applicability and the desire not to perform the Surveillance while at higher power levels. Although the Surveillance could be performed while on IRM Range 3, the plant would not be expected to maintain steady state operation at this power level. In this event, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, based on the SRMs being otherwise verified to be OPERABLE (i.e., satisfactorily performing the CHANNEL CHECK) and the time required to perform the Surveillances.

B 3.3.1.2-8 Revision 64 BASES SRM Instrumentation B 3.3.1.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.2. 7 Performance of a CHANNEL CALIBRATION verifies the performance of the SRM associated circuitry.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted.

The detectors are fission chambers that are designed to have a relatively constant sensitivity over the range and with an accuracy specified for a fixed useful life. Note 2 to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the Applicability.

If the surveillance is not met, the SR must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of entering MODE 2 with IRMs on Range 2 or below. The allowance to enter the Applicability with the Frequency not met is reasonable, based on the limited time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed after entering the Applicability and the desire not to perform the Surveillance while at higher power levels. Although the Surveillance could be performed while on IRM Range 3,. the plant would not be expected to maintain steady state operation at this power level. In this event, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, based on the SRMs being otherwise verified to be OPERABLE (i.e., satisfactorily performing the CHANNEL CHECK) and the time required to perform the Surveillances.

REFERENCES None. FERMI

UNIT 2 B 3.3.1.2-9 Revision 64 BASES Control Rod Block Instrumentation B 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 specific sequence developed for power suppression of failed fuel may not allow any deviations).

SR 3.3.2.1.1 is performed during startup. As noted in the SRs, SR 3.3.2.1.1 is not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn at 10% RTP in MODE 2. The SR 3.3.2.1.2 CHANNEL FUNCTIONAL TEST is performed by attempting to insert and withdraw a control rod not in compliance with the prescribed sequence and verifying a selection error is indicated and a control rod insert and withdraw block (respectively) occur. SR 3.3.2.1.2 is performed during a plant shutdown when transitioning to 10% RTP. As noted, SR 3.3.2.1.2 is not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is 10% RTP in MODE 1. This allows entry into MODE 2 for SR 3. 3. 2.1.1, and THERMAL POWER reduction to 10% RTP when in MODE 1 for SR 3.3.2.1.2, to perform the required Surveillance if the Frequency is not met per SR 3.0.2. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is based on operating experience and in consideration of providing

_a reasonab 1 e ti me in which to complete the SRs. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 2 .

1. 3 A CHANNEL FUNCTIONAL TEST is performed for each RBM channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.2.1-9 Revision 64 BASES Control Rod Block fnstrumentation 8 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 2 .

1. 4 FERMI

UNIT 2 A CHANNEL FUNCTIONAL TEST is performed for the Reactor Mode Switch-Shutdown Position Function to ensure that the entire channel will perform the intended function.

The CHANNEL FUNCTIONAL TEST for the Reactor Mode Switch-Shutdown Position Function is performed by attempting to withdraw any control rod with the reactor mode switch in the shutdown position and verifying a control rod block is present. As noted in the SR, the Surveillance is not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after the reactor mode switch is in the shutdown position, since testing of this interlock with the reactor mode switch in any other position cannot be performed without using jumpers, lifted leads, or movable links. This allows entry into MODES 3 and 4 if the Frequency is not met per SR 3.0.2. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance is based on operating experience and in consideration of providing a reasonable time in which to complete the SRs. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 2 .

1. 5 The power at which the RBM is automatically bypassed is based on the APRM signal's input to each RBM channel. Below the minimum power setpoint, the RBM is automatically bypassed.

This power Allowable Value must be verified periodically to be less than 30% RTP. If this setpoint is nonconservative, then the affected RBM channel is considered inoperable; Alternatively, the power range channel can be placed in the conservative condition (i.e., enabling the RBM Function).

If placed in this condition, the SR is met and the RBM channel is not considered inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.2.1-10 Revision 64 BASES Control Rod Block Instrumentation B 3.3.2.1 .SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 2. 1. 6 FERMI -UNIT 2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint met ho do 1 ogy.

As noted, neutron detectors are excluded from the CHANNEL CALIBRATION because they are passive devices, with minimal drift, and because of the difficulty of simulating a meaningful signal. Neutron detectors are adequately surveilled in SR 3.3.1.1.1 and SR 3.3.1.1.7.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 2 .

1. 7 The RWM will only enforce the proper control rod sequence if the rod sequence is properly input into the RWM computer.

This SR ensures that the proper sequence is loaded into the RWM so that it can perform its intended function.

Control rod withdrawal sequences are normally established consistent with the rules of the generic BPWS analysis.

Occasionally, operational limitations (e.g., power suppression of failed fuel) may dictate the insertion of control rods which do not meet the minimum cell separation criteria of the generic ,BPWS analysis.

In such situations, sufficient cycle specific analyses are performed to demonstrate that the resulting control rod worths of the modified control rod withdrawal sequence are bounded by the rod worths allowed by rigorously following the rules* of the generic BPWS analysis, thereby assuring that the 280 cal/gm fuel damage limit will not be violated during a CRDA. The "prescribed withdrawal sequence" is defined as the combination of both the procedurally specified control rod movement sequence and any analytically allowed deviations from this sequence.

Some prescribed withdrawal sequences (e.g., BPWS) have more flexibility in allowed deviations than other prescribed withdrawal sequences (e.g., a cycle-B 3.3.2.1-11 Revision 64 BASES Control Rod Block Instrumentation B 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 specific sequence developed for power suppression of failed fuel may not allow any deviations).

The Surveillance is performed once prior to declaring the RWM OPERABLE following loading of the prescribed withdrawal sequence into the RWM, since this is when rod sequence input errors are possible.

1. UFSAR, Section 7.6.2.13.5.

2. UFSAR, Section 7.6.1.20.

3. General Electric Energy, "Maximum Extended Operating Domain Analysis for Detroit Edison Company Enrico Fermi Energy Center Unit 2," NEDC

31843P, July 1990. 4. NEDE-24011-P-A-lO*US, "General Electric Standard Application for Reload Fuel," Supplement for United States, March 1991. 5. "Modifications to the Requirements for Control Rod Drop Accident Mitigating Systems," BWR Owners' Group, July 1986. 6. NED0-21231, "Banked Position Withdrawal Sequence," January 1977. 7. NRG SER, "Acceptance of Referencing of Licensing Topical Report NEDE*24011*P*A," "General Electric Standard Application for Reactor Fuel, Revision 8, Amendment 17," December 27, 1987. 8. NEDC*3085l*P*A, "Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation," October 1988. B 3.3.2.1-12 Revision 64 BASES Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is sufficient for the operator to take corrective action, and takes into account the likelihood of an event requiring actuation of feedwater and main turbine high water level trip instrumentation occurring during this period. It is also consistent with the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time provided in LCD 3.2.2 for Required Action A.l, since this instrumentation's purpose is to preclude a MCPR violation.

C.l With the required channels not restored to OPERABLE status or placed in trip, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . As discussed in the Applicability section of the Bases, operation below 25% RTP results in sufficient margin to the required limits, and the feedwater and main turbine high water level trip instrumentation is not required to protect fuel integrity during analyzed events. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on operating experience to reduce THERMAL POWER to < 25% RTP from full power conditions in an orderly manner and without challenging plant systems. SR 3.3.2.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument

channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels, or something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the

instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement cri teri a a r*e determined by the p 1 ant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limits. B 3.3.2.2-5 Revision 64 BASES Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.2.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.2.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.2.2-6 Revision 64 I BASES Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.

2.4 REFERENCES

FERMI -UNIT 2 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the feedwater and main turbine valves is included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function.

Therefore, if a valve is incapable of operating, the associated instrumentation would also be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.1.2. 2. UFSAR-, Section 15. 3. B 3.3.2.2-7 . Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 PAM Instrumentation B 3.3.3.1 The following SRs apply to each PAM instrumentation Function in Table 3.3.3.1-1.

SR 3 . 3 . 3 .

1. 1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel against a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability.

If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.3.1-10 Revision 64 BASES PAM Instrumentation B 3.3.3.l SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 3 .

1. 2 REFERENCES FERMI -UNIT 2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CALIBRATION for Primary Containment High Range Radiation Monitor shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source. 1. Regulatory Gui de 1. 97, "Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Rev. 2, December 1980. 2. Detroit Edison Letter NRC-89-0148, "Additional Clarification to Fermi 2 Compliance to Regulatory Guide 1. 97, Revision 2," dated June 19, 1989. 3. Detroit Edison Letter NRC-89-201, "Regulatory Guide 1. 97 Revis ion 2 Design Review, " dated September 12, 1989. B 3.3.3.1-11 Revision 64 BASES Remote Shutdown System B 3.3.3.2 ACTIONS (continued)

B.1 SURVEILLANCE.

REQUIREMENTS . FERMI -UNIT 2 If the Required Action and associated Completion Time of Condition A are not met, the plant must be brought to a MODE in which the LCD does not apply. To achieve this status, the plant must be brought to at least MODE 3 within . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging plant systems. SR 3.3.3.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. the Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.3.2-4 Revision 64 BASES Remote Shutdown System B 3.3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.

2.2 REFERENCES

FERMI

UNIT 2 SR 3.3.3.2.2 verifies each required Remote Shutdown System transfer switch and control circuit performs the intended function.

This verification is performed from the remote shutdown panel and locally, as appropriate.

Operation of the equipment from the remote shutdown panel is not necessary.

The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3 from the remote shutdown panel and the local control stations.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.3.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. 10 CFR 50, Appendix A, GDC 19. B 3.3.3.2-5 Revision 64 BASES ATWS-RPT Instrumentation B 3.3.4.1 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 D.l and D.2 With any Required Action and associated Completion Time not ' met, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (Required Action D.2). Alternately, the associated recirculation pump may be removed from service since this performs the intended function of the instrumentation (Required Action D.1). The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, both to reach MODE 2 from full power conditions and to remove a recirculation pump from service in an orderly manner and without challenging plant systems. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances; entry into the associated Conditions and Required Actions may be delayed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the associated Function maintains ATWS-RPT trip capability.

Upon completion of the Surveillance, or expiration of the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months testing allowance does not significantly reduce the probability that the recirculation pumps will trip when necessary.

SR 3 . 3 .4. 1.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a *comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

B 3.3.4.1-7 Revision 64 BASES ATWS*RPT Instrumentation B 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties,.

including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the required channels of this LCD. SR 3 . 3 . 4. 1. 2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3. 3 .4 .1. 3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

B 3.3.4.1-8 Revision 64 l ' l I ! I ' BASES ATWS*RPT Instrumentation B 3.3.4.1 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 .4. 1. 4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function.

Therefore, if a breaker is . incapable of operating, the associated instrument would be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Figure 7.7*3, Reactor Recirculation System FCD. 8 3.3.4.1-9 Revision 64 j l .I *I I .I ! .i . ; BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 ECCS Instrumentation B 3.3.5.1 As noted in the beginning of the SRs, the SRs for each ECCS instrumentation Function are found in the SRs column of Table 3.3.5.1*1.

The Surveillances are modified by a Note to *indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months as follows: (a) for Function 3.c; and (b) for Functions other than 3.c and 3.f provided the associated Function or redundant Function maintains ECCS initiation capability.

Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 4) assumption of the average time required to perform channel surveillance.

That . analysis demonstrated that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months testing allowance does not significantly reduce the probability that the ECCS will initiate when necessary.

SR 3 . 3 . 5 .

1. 1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value . Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channe 1 -fa i 1 ure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. . Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

B 3.3.5.1-31 Revision 64 BASES ECCS Instrumentation B 3.3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.5.1.2 and SR* 3.3.5.1.6 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.5.1.3 This surveillance provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.1-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the*plant safety analyses.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3 . 3 . 5 .

1-32 Revision 64

' .: .: . BASES ECCS Instrumentation B 3.3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 5 .

1. 4 REFERENCES FERMI

UNIT 2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific *setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 5 .

1. 5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.3. 2. UFSAR, Chapter 15. 3. NEDC-31982-P, "SAFER/GESTR*LOCA, Loss-of-Coolant Accident Analysis, including Errata and Addenda No. 1," April 1992. 4. NEDC-30936-P*A, "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2," December 1988. B 3.3.5.1-33 Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 RCIC System Instrumentation B 3.3.5.2 As noted in the beginning of the SRs, the SRs for each RCIC System instrumentation Function are found in the SRs column of Table 3.3.5.2*1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an*inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 2: and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1 and 3 provided the associated Function maintains RCIC initiation capability.

Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 1) assumption of the average time required to perform channel surveillance.

That analysis demonstrated that the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months testing allowance does not significantly reduce the probability that the RCIC will initiate when necessary.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a parameter on other similar channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. B 3.3.5.2-9 Revision 64 BASES RCIC System Instrumentation B 3.3.5.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 SR 3.3.5.2.2 and SR 3.3.5.2.6 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.5.2.3 This surveillance provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.2-1.

If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.5.2-10 Revision 64 BASES RCIC System Instrumentation B 3.3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.

2.4 REFERENCES

FERMI

UNIT 2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts.between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.5.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific*

channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. Safety Evaluation Report for Fermi Unit*2 Amendment No. 75, dated September 6, 1991. B 3.3.5.2-11 Revision 64 BASES Primary Containment Isolation Instrumentation B 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 6 .

1. 1 FERMI -UNIT 2 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate

properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit". The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.6.1.2 and SR 3.3.6.l.6 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. B 3 .3,, 6.1-32 Revision 64 BASES Primary Containment Isolation Instrumentation B 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is cbntrolled under the Surveillance Frequency Control Program. SR 3.3.6.1.3 This surveillance provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is.not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than that accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.6.1.4.

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.6.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on PCIVs in LCO 3.6.1.3 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.6.1-33 Revision 64

. BASES Primary Containment Isolation Instrumentation B 3.3.6.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.6.1.7 FERMI

UNIT 2 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.

The response time must be added to the PCIV closure times to obtain the ISOLATION SYSTEM RESPONSE TIME. References 10 and 11 provide justification for elimination of Response Time Testing for all Primary Containment Isolation Instrumentation components except the Main Steam Line Isolation Instrumentation DC Output Relays, thus these components are required to be Response Time Tested. The Main Steam Line Isolation Instrumentation DC Output Relays operate in parallel with the Main Steam Line Isolation Instrumentation AC Output Relays and are expected . to have similar performance.

The Main Steam Line Isolation Instrumentation DC Output Relays are common to Table 3.3.6.1*1, Functions 1.a, b, c, d, e, f, and g and may be tested using any of these functions. , ISOLATION SYSTEM RESPONSE TIME acceptance criteria for the instrumentation portion are included in Reference 7, while the acceptance criteria for the PCIV closure times are included in Reference

8. This test may be performed in one measurement, or in overlapping segments, with verification that all components are tested. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.6.1-34 Revision 64

1. I *i ! BASES Secondary Containment Isolation Instrumentation B 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.6.2.1 FERMI -UNIT 2 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel status during normal operational use of the displays associated with channels required by the LCO. SR 3.3.6.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

B 3.3.6.2-10 Revision 64 BASES Secondary Containment Isolation Instrumentation B 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

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

SR 3.3.6.2.3 This surveillance provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2*1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, performance is still within the requirements of the plant safety analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.6.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology, The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.6.2*11 Revision 64 BASES Secondary Containment Isolation Instrumentation B 3.3.6.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.6.

2.5 REFERENCES

FERMI

UNIT 2 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on SCIVs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.3. 2. UFSAR, Chapter 15 ..

3. UFSAR, Section 15.7.4. 4. NEDC*31677P*A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation," July 1990. 5. NEDC*30851P*A Supplement 2, "Technical Specifications Improvement Analysis*

for BWR I sol at ion Instrumentation Common to RPS and ECCS Instrumentation," March 1989. B 3.3.6.2*12 Revision 64 BASES LLS Instrumentation B 3.3.6.3 ACTIONS (continued)

C.1 SURVEILLANCE . REQUIREMENTS . FERMI -UNIT 2 If any Required Action and associated Completion Time of Conditions A or B are not met, or two LLS valves are inoperable due to inoperable channels, the LLS valves may be incapable of performing their intended function.

Therefore, the plarit must be placed in a MODE or other specified condition in which the LCO does not apply. This is done by placing the plant in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . As noted at the beginning of the SRs, the SRs for each LLS instrumentation Function are located in the SRs column of Table 3.3.6.3-1.

SR 3.3.6.3.1 and SR 3.3.6.3.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the int.ended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. A portion of the SRV tailpipe pressure switch instrument channels are located inside the primary containment.

The allowance for SR 3.3.6.3.2 to only perform the CHANNEL FUNCTIONAL TEST for portions of the channel outside of the primary containment is based on the location of these instruments and.ALARA considerations and the requirement for B 3.3.6.3-6

Revision 64 BASES LLS Instrumentation B 3.3.6.3 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 a complete CHANNEL CALIBRATION (SR 3.3.6.3.3) and LSFT (SR 3.3.6.3.4).

SR 3.3.6.3.3 CHANNEL CALIBRATION is a complete check of the instrument loop and sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.6.3.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specified channel. The system functional testing performed in LCO 3.6.1.6, "Low-Low Set (LLS) Safety/Relief Valves (SRVs)," for SRVs overlaps this test to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Figure 7.3*13. 2. UFSAR, Section 5.2.2. B 3.3.6.3-7 Revision 64 BASES CREF System Instrumentation B 3.3.7.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.1.1 FERMI

UNIT 2 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

criteria are determined by the plant staff. based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel status during normal operational use of the displays associated with channels required by the LCO. SR 3.3.7.1.2 and SR 3.3.7.1.3 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay.

clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a .relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

B 3.3.7.1-9 Revision 64 BASES CREF System Instrumentation B 3.3.7.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.7.1.4 This surveillance provides a check of the actual trip setpoints.

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

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.7.1-1.

If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis.

Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.7.1.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency.is controlled under the Surveillance Frequency Control Program. B 3.3.7.1-10 Revision 64 BASES CREF System Instrumentation B 3.3.7.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 3 . 7 .

1. 6 REFERENCES FERMI -UNIT 2 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional performed in LCO 3.7.3, "Control Room Emergency Filtration (CREF) System," overlaps this Survei 11 ance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Figure 9.4.2. 2. UFSAR, Section 9 . 4. 1. 3. UFSAR, Section 6.4.1. 4. UFSAR, Chapter 15. 5. Safety Evaluation for Fermi Unit-2 Amendment No. 75, dated Septem er 6, 1991. B 3.3.7.1-11 Revision 64 BASES LOP Instrumentation B 3.3.8.1 ACTIONS (continued)

SURVEILLANCE . REQUIREMENTS FERMI

UNIT 2 The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of channels.

B.1 If Required Action A.1 and associated Completion Time is not met, or the associated Function is not capable of performing the intended function, the associated EDG(s) is declared inoperable immediately.

This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable EDG(s). As noted at the beginning of the SRs, the SRs for each LOP instrumentation Function are located in the SRs column of Table 3.3.8.1-1.

SR 3 . 3 . 8. 1. 1 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 8. 1. 2 A: CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint

B 3.3.8.1-6 Revision 64 BASES LOP Instrumentation B 3.3.8.1 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 methodology.

This SR also ensures the sum of the degraded voltage time delay and the longest time delay of the four associated bus undervoltage relays remains consistent with the plant specific setpoint methodology.

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

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 3 . 8. 1. 3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LCO 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. .1. . UFSAR, Figure 8.3-8. 2. UFSAR, Section 3.6. 3. UFSAR, Section 6.3. 4. UFSAR, Chapter 15. B 3.3.8.1-7 Revision 64 BASES RPS Electric Power Monitoring B 3.3.8.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Note in the Surveillance is based on guidance provided in Generic Letter 91-09 (Ref. 3). The Surveillance Frequency is controlled under the Surveillance Frequency*

Control Program. SR 3.3.8.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.8.2.3 Performance of a system functional test demonstrates that, with a required system actuation (simulated or actual) . signal, the logic of the system will automatically trip open the associated power monitoring assembly.

Only one signal per power monitoring assembly is required to be tested. This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function.

The system functional test of the Class lE circuit breakers is included as part of this test to provide complete testing of the safety function.

If the breakers are incapable of operating, the associated electric power monitoring assembly would be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.3.8.2-7 Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 SR 3.4.1.1 Recirculation Loops Operating 8 3.4.1 This SR ensures the*recirculation loops are within the allowable limits for mismatch.

At low core flow (i.e., < 70% of rated core flow), the MCPR requirements provide larger margins to the fuel cladding integrity Safety Limit such that the potential adverse effect of early boiling transition during a LOCA is reduced. A larger flow mismatch can therefore be allowed when core flow is < 70% of rated core flow. The recirculation loop jet pump flow, as used in this Surveillance, is the summation of the flows from all of the jet pumps associated with a single recirculation loop. The mismatch is measured in terms of percent of rated core fl ow. If the fl ow mismatch exceeds the specified 1 i mi ts, . the loop with the lower flow is considered "not in operation".

The SR is not required when both loops are not in operation since the mismatch limits are meaningless during single loop or natural circulation operation.

The Surveillance must be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after both loops are in operation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 8 3.4.l*B Revision 64 BASES ACTIONS SURVEILLANCE

REQUIREMENTS

FERMI

UNIT 2 A.1 Jet Pumps B 3.4.2 An inoperable jet pump can increase the blowdown area and reduce the capability of reflooding during a design basis LOCA. If one or more of the jet pumps are inoperable, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power. conditions in an orderly manner and without challenging plant systems. SR 3;4.2.1 This SR is designed to detect significant degradation in jet pump performance that precedes jet pump failure (Ref. 2). This .SR is required to be performed only when the loop has forced recirculation flow since surveillance checks and measurements can only be performed during jet pump operation (this includes performing this SR when the loop is operating but may be declared "not in operation" in accordance with the ACTIONS of LCO 3.4.1). The jet pump failure of concern is a complete mixer displacement due to jet pump beam failure. Jet pump plugging is also of concern since it adds flow resistance to the recirculation loop. Significant degradation is indicated if the specified criteria confirm unacceptable deviations from established patterns or relationships.

The allowable deviations from the

established patterns have been developed based on the variations experienced at plants during normal operation and with jet pump assembly failures (Refs. 2 and 3). Each recirculation loop must satisfy two of. the performance criteria provided.

Since refueling activities (fuel assembly replacement or shuffle, as well as any modifications to fuel support orifice size or core plate bypass flow) can affect the relationship between core flow, jet pump differential pressures, recirculation pump speed, and recirculation loop drive flow, these relationships may need to be re-established each cycle. Similarly, initial entry into extended single loop operation may also require establishment of these relationships.

During the initial weeks of operation under such conditions, while base-lining new "established patterns", engineering judgement of the surveillance results is used to detect significant abnormalities which could indicate a jet pump failure. B 3.4.2-3 Revision 64 BASES Jet Pumps B 3.4.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The recirculation pump speed operating characteristics (loop drive flow versus pump speed and loop drive flow versus total core flow) are determined by the flow resistance from the loop suction through the jet pump nozzles. A change in the relationship indicates a plug, flow restriction, loss in pump hydraulic performance, leakage, or new flow path between the recirculation pump discharge and jet pump nozzle. For criterion a., the loop drive flow versus pump speed relationship must be verified.

For criterion b., the loop drive flow versus total core flow relationship must be verified.

Individual jet pumps in a recirculation loop normally do not have the same flow. The unequal flow is due to the drive flow manifold, which does not distribute flow equally.to all risers. The flow (or jet pump diffuser to lower plenum differential pressure) pattern or relationship of one jet pump to the loop average is repeatable.

An appreciable change in this relationship is an indication that increased (or reduced) resistance has occurred in one of the jet pumps. This may be indicated by an increase in the relative . flow for a jet pump that has experienced beam cracks, failed . beam inletriser crack, or jet pump assembly crack. The deviations from normal are considered indicative of a potential problem in the recirculation drive flow or jet pump system (Ref. 2). Normal flow ranges and established jet pump flow and differential pressure patterns are established by plotting historical data as discussed in Reference

2. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by two Notes. Note 1 allows this Surveillance not to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the associated recirculation loop is in operation, since these checks can only be performed during jet pump operation.

The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is an acceptable time to establish conditions appropriate for data collection and evaluation.

B 3.4.2-4 Revision 64 I I BASES SRVs B 3.4.3 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 5.2.2.3.5.

2. UFSAR, Chapter 15. 3. ASME, Boiler and Pressure Vessel Code,Section XI. B 3.4.3*5 Revision 64 BASES RCS Operational LEAKAGE B 3.4.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 C.1 and C.2 If any Required Action and associated Completion Time of Condition A or B is not met or if pressure boundary LEAKAGE

exists, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant safety systems. SR 3.4.4.1 The RCS LEAKAGE is monitored by a variety of instruments designed to provide alarms when LEAKAGE is indicated and to quantify the various types of LEAKAGE (e.g., Primary Containment Atmospheric Gaseous Radioactivity, RPV head flange leak detection, and sump monitoring systems).

Leakage detection instrumentation is discussed in more detail in the Bases for LCO 3.4.6, "RCS Leakage Detection Instrumentation." Sump level and flow rate are typically monitored to determine actual LEAKAGE rates; however, any method may be used to quantify LEAKAGE within the guidelines of Reference

5. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. 10 CFR 50, Appendix A, GDC 30. 2. GEAP-5620, April 1968. 3. NUREG-76/067, October 1975. 4. UFSAR, Section*5.2.7.4.3.3.

5. Regulatory Guide 1.45. B 3.4.4-5 Revision 64 BASES LCO (continued)

APPLICABILITY ACTIONS FERMI -UNIT 2 RCS Leakage Detection Instrumentation B 3.4.6 unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump level monitoring OPERABILITY.

' The LCO is satisfied when monitors of diverse measurement means are available.

Thus, the drywell floor drain sump flow monitoring system, in combination with the gaseous primary containment atmosphere radioactivity monitor, and the drywell floor drain sump level monitoring system provides an acceptable minimum. In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4. A.l With the drywell floor drain sump flow monitoring system inoperable, the plant has lost one means to quantify leakage. However, the primary containment atmosphere gaseous radioactivity monitoring system and the drywell floor drain sump level monitoring system will provide indication of changes in leakage. . With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE determined via SR 3.4.4.1, operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

B.1 With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information.

Provided a sample is obtained and analyzed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the plant may continue operation since at least one other form of drywell leakage detection (i.e., drywell floor drain sump level monitoring system) is available.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect LEAKAGE. B 3.4.6-4 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 RCS Leakage Detection Instrumentation B 3.4.6 SR 3.4.6.1 This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere gaseous radioactivity monitoring system. The check gives reasonable confidence that the channel is operating proper.ly.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.4.6.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation.

The test ensures that the monitors can perform their function in the desired manner. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.4.6.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrument string, including the instruments located inside containment.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. 10 CFR 50, Appendix A, GDC 30. 2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973. 3. UFSAR, Section 5.2.7.1.3.

4. GEAP-5620, April 1968. 5. NUREG*75/067, October 1975. 6. UFSAR, Section 5.2.7.4.3.3.

7. NUREG/CR*6861, December 2004 B 3.4.6*7 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 SR 3.4.7.1 RCS Specific Activity B 3.4.7 This Surveillance is performed to ensure iodine remains within limit during normal operation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note that requires this Surveillance to be performed only in MODE 1 because the level of fission products generated in other MODES is much less. 1. 10 CFR 100.11. 2. UFSAR, Section 15.6.4. 3. 10 CFR 50.67. B 3.4.7-4 Revision 64 BASES RHR Shutdown Cooling System-Hot Shutdown B 3.4.8 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 8.1, 8.2, and 8.3 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.

SR 3.4.8.1 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. 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

B 3.4.8-5 Revision 64 BASES SURVEILLANCE REQUIREMENTS SR 3.4.9.1 RHR Shutdown Cooling System *Cold Shutdown B 3.4.9 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 BASES RCS P/T Limits B 3.4.10 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 C.l and C.2 Operation outside the P/T limits in other than MODES 1, 2, and 3 (including defueled conditions) must be corrected so that the RCPB is returned to a condition that has been verified by stress analyses.

The Required Action must be initiated without delay and continued until the limits are restored.

Besides restoring the P/T limit parameters to within limits, an evaluation is required to determine if RCS operation is allowed. This evaluation must verify that the RCPB integrity is acceptable and must be completed before approaching criticality or heating up to > 200°F. Several methods may be used, including comparison with pre-analyzed transients, new analyses, or inspection of the components.

ASME Code,Section XI, Appendix E (Ref. 6), may be used to support the evaluation:

however, its use is restricted to evaluation of the beltline.

Condition C is modified by a .Note requiring Required Action A.2 be completed whenever the Condition is entered. The Note emphasizes the need. to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.

SR 3.4.10.1 Verification that operation is within PTLR limits is required when RCS pressure and temperature conditions are undergoing planned changes. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Surveillance for heatup, cooldown, or inservice leakage and hydrostatic testing may be discontinued when the criteria given in the relevant plant procedure for ending the activity are satisfied.

B 3.4.10*6 Revision 64 BASES RCS P/T Limits B 3.4.10 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 increase, or flow increase.

An acceptable means of demonstrating compliance with the temperature differential requirement in SR 3.4.10.4 and SR 3.4.10.6 is to compare the temperatures of the operating recirculation loop and the idle loop. These SRs have been modified by Notes that require the Surveillance to be performed only in certain MODES. In MODE 5, the overall stress on limiting components is lower. Therefore, AT limits are not required for SRs 3.4.10.3 and 3.4.10.4 in MODE 5. In MODES 3, 4, and 5, THERMAL POWER increases are not possible, and recirculation flow increases will not result in additional stresses.

Therefore AT limits are only required for SRs 3.4.10.5 and 3.4.10.6 in MODES 1 and 2. The Notes .also state that the SR is only required to be met during the event of concern (e.g., pump startup, power increase or flow increase) since this is when the stresses occur. SR 3.4.10.7, SR 3.4.10.8, and SR 3.4.10.9 Limits on the reactor vessel flange and head flange temperatures are generally bounded by the other P/T limits during system heatup and cooldown.

However, operations approaching MODE 4 from MODE 5 and in MODE 4 with RCS temperature less than or equal to certain specified values require assurance that these temperatures meet the LCO 1 imits. The flange temperatures must be verified to be above the limits before and while tensioning the vessel head bolting studs to ensure that once the head is tensioned the limits are satisfied.

When in MODE 4 with RCS 80° F, checks of the flange temperatures are required because of the reduced margin to the limits. When in MODE 4 with RCS 100°F, monitoring of the flange temperature is required to ensure the temperature is within the limits specified in the PTLR. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.4.10-8 Revision 64 BASES ACTIONS SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 A.1 Reactor Steam Dome Pressure B 3.4.11 With the reactor steam dome pressure greater than the limit, prompt action should be taken to reduce pressure to below the limit and return the reactor to operation within the bounds of the reactor pressure vessel overpressure analyses.

The 15 minute Completion Time is reasonable considering the importance of maintaining the pressure within limits. This Completion Time also ensures that the probability of a reactor pressure vessel overpressure accident occurring while pressure is greater than the limit is minimized.

If the operator is unable to restore the reactor steam dome pressure to below the limit, then the reactor should be placed in MODE 3 to be operating within the assumptions of the reactor pressure vessel overpressure analyses.

B.1 If the reactor steam dome pressure cannot be restored to within the limit within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach* MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

SR 3.4.11.1 Verification that reactor steam dome pressure is psig ensures that the initial conditions of the reactor pressure vessel overpressure protection analysis are met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 5.2.2.3. B 3.4.11*2 Revision 64 BASES . SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 SR 3.5.1.1 ECCS-Operating B 3.5.1 The LPCI System injection valves, recirculation pump discharge valves, and LPCI cross-tie valve are powered from the LPCI swing bus, which must remain energized to support OPERABILITY of both LPCI subsystems.

Therefore, of proper voltage and correct breaker alignment to the swing bus is required.

The correct breaker alignment ensures the appropriate separation and independence of the electrical power sources are maintained and appropriate sources of electrical power are available, and the appropriate voltage is available to the swing bus, including verification that the swing bus is energized from its normal source (bus 72C). The verification of proper voltage availability ensures that the required voltage is readily available for critical system loads connected to this bus. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.1. 2 The LPCI System injection valves, recirculation pump discharge valves, and LPCI cross-tie valve are powered from the LPCI swing bus, which must remain energized during any single failure, including loss of power from the normal feed to the swing bus. Therefore the automatic throwover scheme is functionally tested (by manually opening position 3C of bus 72C) to verify the capability of the throwover scheme to detect loss of normal power, and initiate an automatic transfer to the swing bus emergency power source. Verification that the LPCI swing bus automatic throwover scheme functions properly demonstrates that AC electrical power is available to ensure proper operation of the associated LPCI injection valves, recirculation pump discharge valves, and LPCI cross-tie valve. The swing bus automatic throwover scheme must be OPERABLE for both LPCI subsystems to be OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.5.1-12 Revision 64

1 I , I i *) BASES ECCS-Operati ng B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 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 fl ow paths wi 11 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

B 3.5.1-13 Revision 64 BASES ECCS-Operati ng B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 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 remova.l with reactor steam dome pressure 1 ess 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. B 3.5.1*14 Revision 64 BASES ECCS-Operating B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.1.6 FERMI

UNIT 2 Verification that the RHR System power operated cross-tie valve is open ensures that each LPCI subsystem remains capable of injection into the selected recirculation loop. A valve that is inaccessible may be verified by administrative controls.

If a RHR System cross-tie valve is not open, both LPCI subsystems must be considered inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 .5.1. 7 Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.

Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem.

Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker. The Surveillance Frequency is controlled under the I Surveillance Frequency Control Program. If the valve is . inoperable and in the open position, both LPCI subsystems must be declared inoperable.

B 3.5.1*15 Revision 64 .

BASES ECCS -Operating B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 Therefore, SR 3.5.1.9 and SR 3.5.1.10 are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The Frequency for SR 3.5.1.8 and SR 3.5.1.9 is in accordance with the Inservice Testing Program requirements.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.1.11 The ECCS subsystems are required to actuate automatically to perform their design functions.

This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions.

This SR also ensures that the HPCI System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.5.1*17 Revision 64 BASES ECCS-Operating B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 This SR is modified by a Note that excludes vessel injection/spray during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

SR 3.5.1.12 The ADS designated SRVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function .(i.e., solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components.

SR 3.5.1.13 and the LOGIC SYSTEM FUNCTIONAL TEST performed in.LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note that excludes valve actuation.

SR 3. 5 .1.13 Valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME Code requirements, prior to valve installation.

Actuation 6f each required ADS valve is performed to verify,that mechanically the valve is functioning properly.

Tests are required to demonstrate:

That each ADS SRV solenoid valve ports pneumatic pressure to the associated SRV actuator when energized;

That each ADS SRV pilot stage actuates to open the associated main stage when the pneumatic actuator is pressurized; and B 3.5.1-18 Revision 64 BASES ECCS-Operati ng B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2

That each ADS SRV main stage opens and passes steam when the associated pilot stage actuates.

The solenoid valves are functionally tested once per cycle as part of the Inservice Testing Program. The actuators and main stages are bench.tested, together or separately, as part of the certification process. Maintenance procedures ensure that the SRV actuators and main stages are correctly installed in the plant, and that the SRV and associated piping remain clear of foreign material that might obstruct valve operation or full steam flow. This approach provides adequate assurance that the required ADS valves will operate when actuated, while minimizing the challenges to the valves and the likelihood of leakage or spurious operation. stage actuator assemblies are not tested in-situ due to a probability of causing unseating or leakage of the pilot stage which can lead to spurious actuation or failure to reclose. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL Test performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

This SR does not preclude manually opening SRVs; for example, in accordance with the IST Program or as corrective action for an SRV with excessive leakage. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.1.14 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.

Response time testing acceptance criteria are included in Reference

16. This SR is modified by a Note stating that the ECCS instrumentation response times are not required to be measured.

The contribution of 'the instrument response times to the overall ECCS response time are assumed based on guidance of Reference

17. B 3.5.1*19 Revision 64 BASES ECCS -Operating B 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.5.1-20 Revision 64 BASES ECCS-Shutdown 8 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 provide adequate makeup if the RPV were completely drained. Therefore, only one CS subsystem is allowed to use the CST. This ensures the other required ECCS subsystem has adequate makeup volume. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.2.3 The LPCI System injection valves, recirculation pump discharge valves, and LPCI cross-tie valve are powered from the LPCI swing bus, which must remain energized to support OPERABILITY of any required LPCI subsystem.

Therefore, verification of proper voltage and correct breaker alignment to the swing bus is required.

The correct breaker alignment ensures the appropriate electrical power sources are available, and the appropriate voltage is available to the swing bus, including verification that the swing bus is energized.

The verification of proper voltage availability ensures that the required voltage is readily available for critical system loads connected to this bus. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.5.2.4, SR 3.5.2.6, and SR 3.5.2.7 The Bases provided for SR 3.5.1.3, SR 3.5.1.8, and SR 3.5.1.11 are applicable to SR 3.5.2.4, SR 3.5.2.6, and SR 3.5.2.7, respectively.

B 3.5.2-5 Revision 64 I BASES ECCS-Shutdown B 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.

2.5 REFERENCES

FERMI -UNIT 2 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. 1. UFSAR, Section 6.3.2. B 3.5.2-6 Revision 64 BASES SURVEILLANCE REQUIREMENTS

FERMI -UNIT 2 SR 3.5.3.l RCIC System B 3.5.3 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. B 3.5.3*5 Revision 64 BASES RCIC System B 3.5.3 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 SR 3.5.3.3 and SR 3.5.3.4 The RCIC pump flow rates ensure that the system can maintain reactor coolant inventory during pressurized conditions with the RPV isolated.

The flow tests for the RCIC System are performed at two.different pressure ranges such that system capability to provide rated flow is tested both at the higher and lower operating ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the RCIC System diverts steam flow. Reactor steam pressure must be 945 psig to perform SR 3.5.3.3 and 150 psig to perform SR 3.5.3.4. Adequate steam flow is represented by the main turbine generator on line or turbine bypass valves open at least 2%. Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these SRs. Reactor startup is allowed prior to performing the low pressure Surveillance because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure Surveillance has been satisfactorily completed*

and there is no indication or reason to believe that RCIC is inoperable.

Therefore, these SRs are modified by Notes that state the Surveillances are not required t'o be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure and flow are adequate to perform the test. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.5.3*6 Revision 64 BASES RCIC System B 3.5.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.

3.5 REFERENCES

. FERMI

UNIT 2 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily.

This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions.

This test also ensures that the RCIC System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3. 3. 5. 2 overlaps this Survei 11 ance to provide. comp 1 ete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note that excludes vessel injection during the Surveillance.

Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

1. 10 CFR 50, Appendix A, GDC 33. 2. UFSAR, Section 5.5.6. 3. Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975. 4. NEDC-32988-A, Revision 2, Technical Justification to Support Risk Informed Modification to Selected Required End States for BWR Plants, December 2002 . B 3.5.3*7 Revision 64 BASES Primary Containment B 3.6.1.1 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI -UNIT 2 Satisfactory performance of this SR can be achieved by establishing a known differential pressure between the drywell and the suppression Ghamber and verifying that the pressure between the suppression chamber and the drywell does not change by more than 0.2 inch of water per minute over a 10 minute period. This leakage is equivalent to that through a 1 inch diameter orifice at a differential pressure of approximately 1 psid. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Two consecutive test failures, however, would indicate unexpected degradation; in this event, as the Note indicates, increasing the Frequency to once every 9 months is required until the situation is remedied as evidenced by passing two consecutive tests. SR 3.6.1.l.3 The primary containment suppression chamber can experience significant hydrodynamic loading during safety/relief valve (SRV) operation with the suppression pool average water temperature 160°F and reactor coolant system pressure > 200 psig. After SRV operation during these conditions, a visual examination of the exterior surface of the suppression chamber will identify any abnormal conditions that may warrant further inspection and review for continued OPERABILITY.

This examination is performed prior to resuming operation in MODES where primary containment is required to be OPERABLE.

1. UFSAR, Section 6.2. 2. UFSAR, Section 15.6.5. 3. 10 CFR 50, Appendix J, Option B. B 3.6.1.1-5 Revision 64 BASES Primary Containment Air Lock B 3.6.1.2 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a OBA. Note 2 has been added to this SR, requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1.1.

This ensures that air lock leakage is properly accounted for in determining the combined Type B and C primary containment leakage rate. SR 3 . 6 .1. 2 . 2 The air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post*accident primary containment pressure, closure of either door will support primary containment OPERABILITY.

Thus, the interlock feature supports primary containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment.

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous inner and outer door opening will not inadvertently occur. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 3.8.2.1.3.4.

2. 10 CFR 50, Appendix J, Option B. 3. UFSAR, Section 6.2. B 3.6.1.2-7 Revision 64 '.

BASES PC I Vs B 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 valves may be opened for inerting, de-inerting, pressure control, AL.ARA or air quality considerations for personnel . entry, or Surveillances that require the valves to be open. The purge valves (6 inch, 10 inch, 20 inch, and 24 inch) and the containment pressure control valves (1 inch) are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 6 . 1. 3 . 2 This SR verifies that each primary containment isolation manual valve and blind flange that is located outside primary containment and is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits. This SR does not require any testing or valve manipulation.

Rather, it involves verification that those PCIVs outside primary containment, and capable of being mispositioned, are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Two Notes have beeri added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls.

Allowing verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1, 2, and 3 for AL.ARA reasons.

Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in the proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during. the time that the PCIVs are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position upon locking, sealing, or securing. B 3 . 6 .

1. 3 -12 Revision 64 BASES PCIVs B 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 6. 1. 3 . 3 FERMI

UNIT 2 This SR verifies that each primary containment isolation manual va 1 ve and blind flange that is 1 ocated inside primary containment and is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits. For PCIVs inside primary containment, the Frequency defined as "prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days" is appropriate since these PCIVs are . operated under administrative controls and the probability of their misalignment is low. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position _upon locking, sealing, or securing.

Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls.

Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during , MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in their proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open. SR 3 . 6. 1. 3 . 4 The traversing incore probe (TIP) shear isolation valves are actuated by explosive charges. Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required.

Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3 . 6 .

1. 3 -13 Revision 64 BASES PCIVs B 3.6.l.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 6 . 1. 3 . 5 FERMI -UNIT 2 Verifying the isolation time of each power operated automatic PCIV is within limits is required to demonstrate OPERABILITY.

MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7.

The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analyses.

The isolation time and Frequency of this SR are in accordance with the requirements of the Inservice Testing Program. SR 3 . 6. 1. 3 . 6 For primary purge valves with resilient seals (6 inch, 10 inch, 20 inch, and 24 inch), additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B (Ref. 3), is required to ensure OPERABILITY.

This will ensure that leakage is 0.05 La when tested at Pa. Operating experience has demohstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Additionally, this SR must be performed once within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened). Thus, performing this SR within 92 days is a prudent measure after a valve has been opened. The primary containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3. (i.e., no isolation instrumentation functions of LCO 3.3.6.1 are required to be OPERABLE for purge system isolation outside of MODES 1, 2, and 3). If a LOCA insj_de primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

B 3. 6. 1. 3

14 Revision 64 BASES PC I Vs B 3.6.1.3

SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 6. 1. 3 . 7 FERMI

UNIT 2 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the OBA analyses.

This ensures that the calculated radiological consequences of these events remain within 10 CFR 100 or 10 CFR 50.67 limits. The minimum stroke time ensures that isolation does not result in a pressure spike more rapid than assumed in the transient analyses.

The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program. SR 3.6.1.3.8 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a OBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.5 overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 6 . 1. 3 . 9 This SR requires a demonstration that a representative sample of reactor instrumentation line excess flow check valves (EFCVs) are OPERABLE by verifying that each tested valve restricts flow on a simulated instrument line break. The representative sample consists of an approximately equal number of EFCVs (about 15), from different plant locations and operating environments, such that each EFCV is periodically tested. The representative sample testing reflects the operability status of all EFCVs in the plant (Ref. 6). This SR provides assurance that the instrumentation line EFCVs will perform so that predicted radiological consequences will not be exceeded during the postulated instrument line break event evaluated in Reference

5. B 3 . 6 .

1. 3

15 Revision 64 BASES PC IVs B 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 6 .1. 3 . 10 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required.

The replacement charge for the explosive squib *shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. No squib will remain in service beyond the expiration of its shelf life or its operating life. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 . 6 .1. 3 . 11 This SR ensures that the leakage rate of secondary containment bypass leakage paths is< 0.10 La. This provides assurance that the assumptions in the radiological evaluations of Reference 1 are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate of the two valves. The frequency is required by the Primary B 3 . 6. 1. 3

16 Revision 64

BASES Primary Containment Pressure B 3.6.1.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS . REFERENCES FERMI

UNIT 2 8.1 and B.2 If primary containment pressure cannot be restored to within limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3 . 6. 1. 4. 1 Verifying that primary containment pressure is within limit ensures that unit operation remains within the limit assumed in the primary containment analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.2. 2. UFSAR, Section 6.2.1.2.1.10.

3. GENE 770*18, "Fermi-2 Containment Analysis Parametric Study," March 1991. B 3.6.1.4-3 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 Drywell Air Temperature B 3.6.1.5 SR 3 . 6 . 1. 5 . 1 Verifying that the drywell average air temperature is within the LCD limit ensures that operation remains within the temperature limits for the primary containment.

Drywell air temperature is monitored in all zones and at various elevations.

Due to the shape of the drywell, a volumetric average is used to determine an accurate representation of the actual average temperature.

This is accomplished by averaging at least one reading at each of the following elevations:

a. 5go ft, 0 inches (azimuth go 0 , 135°, 270°, or 316°) b. 5g7 ft, 0 inches (azimuth 35°, 75°, g3°, 135°, 175°, 200°, 246°, 272°, 306°, or 345°) c. 621 ft, 8 inches (azimuth 0°, go 0 , 180°, 270°) d 648 ft, 6 inches (azimuth 45°, 135°, 225°, 315°) e. 662 ft. 0 inches ( azimuth 0°, .:. goo, 180°, 285°) f. 665 ft, 6 inches (azimuth 0° or 180°) The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.2. 2. UFSAR, Table 6.2-1. Revision 64 BASES LLS Valves B 3.6.1.6 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI -UNIT 2 This SR does not preclude manually opening SRVs; for example, in accordance with the IST Program or as corrective action for an SRV with excessive leakage. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.6.1.6.2 The LLS designated SRVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.4.overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note that excludes valve actuation.

This prevents a reactor pressure vessel pressure blowdown.

1. UFSAR, Section 5.2.2.5. 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. B 3.6.1.6-5 Revision 64 BASES Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 ACTIONS (continued)

E.l SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact. However, in the event of a containment depressurization, the function of the vacuum breakers is lost. Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This Completion Time is consistent with the ACTIONS of LCD 3. 6. 1. 1, which requi res :that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . F.1 and F.2 If the vacuum breakers in one or more lines cannot be closed or restored to OPERABLE status within the required Completion Time, the plant be brought to a MODE in which the LCD not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3 . 6 . 1. 7 . 1 Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker position*

or by verifying a differential pressure of 0.5 psid is maintained between the reactor building and suppression chamber. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Two Notes are added to this SR. The first Note allows reactor-to-suppression chamber vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.

The second Note is included to clarify that vacuum breakers open due to an B 3.6.1.7*6 Revision 64 BASES Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 actual differential pressure are not considered as failing this SR. SR 3.6.1.7.2 Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position.

This ensures that the safety analysis assumptions are valid. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. This verification may be performed by measurement of the equivalent force to move the pullet. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 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. B 3.6.1.7*7 Revision 64 BASES Suppression Chamber-to-Drywell Vacuum Breakers 8 3.6.1.8 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS . FERMI -UNIT 2 D.1 and D.2 If the open suppression chamber-to-drywell vacuum breaker cannot be closed within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3 . 6. 1. 8. 1 Each vacuum bre.aker is verified closed to ensure that this potential large bypass leakage path is not present. This Surveillance is performed by observing the vacuum breaker position indication or by verifying that a differential pressure of 0.5 psid between the suppression chamber and drywell is maintained for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months without makeup. However, if vacuum breaker position indication is not reliable, either due to: 1) dual or open indication while able to establish a torus-to-drywell differential pressure, or 2) closed indication while not able to establish a torus-to-drywell differential pressure, alternate methods of verifying that the vacuum breaker is closed are detailed in Technical Requirements Manual CTRM). If position indication appears reliable (dual or open indication while torus-to-drywell differential pressure is steady at 0 psid), and indicates open, the alternate methods outlined in the TRM can prove the indication to be in error and the vacuum breaker closed. However, in thi.s case the vacuum breaker is assumed open until otherwise proved to satisfy the leakage test, and this confirmation must be performed within the Technical Specification 3.6.1.8 Required Action B.1 Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Notes 1 and 2 are added to this SR which allows suppression chamber-to-drywell vacuum breakers opened in conjunction with the performance of a Surveillance or open while performing their intended function to not be considered as failing this SR. These periods do not represent inoperable vacuum breakers.

8 3.6.1.8-5 Revision 64 BASES Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.8 SURVEILLANCE REQUIREMENTS (continued)

SR 3 . 6 . 1. 8. 2 FERMI -UNIT 2 Each vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position.

This ensures that the safety analysis assumptions are valid. The Frequency of "prior to entering MODE 2 or 3 from MODE 4 if not performed in the previous 92 days" is based upon the demonstrated reliability of the vacuum breakers and the potential for the test to result in a stuck open vacuum breaker, which could be caused by a failure of the pneumatically operated test mechanism.

Since the vacuum breaker is inaccessible in MODES 1, 2, and 3, test induced inoperability would result in a forced shutdown of the unit. In addition, there exists substantial redundancy in that 4 vacuum breakers must fail to open before the safety function is lost. In addition, this functional test is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after a discharge of steam to the suppression chamber from the safety/relief valves. Performing this test concurrent with an evolution or event that has the potential for admitting steam to the suppression chamber (e.g., during Low-Low Set operation of the SRVs) could distract the operators from the recovery evolution that would be in progress, and could to equipment damage. Therefore, the frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after a discharge of steam to the suppression chamber begins when the evolution or event that has the potential for admitting steam to the suppression chamber ends (e.g., after completion of the Low-Low Set operation).

SR 3 . 6 . 1. 8 . 3 Verification of the vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumptjon regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.6.1.8-6 Revision 64 BASES Suppression Pool Average Temperature B 3.6.2.1 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 E.1 and E.2 If suppression pool average temperature cannot be maintained at 120°F, the plant must be brought to a MODE in which the LCD does not apply. To achieve this status, the reactor pressure must be reduced to < 200 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and the plant must be brought to at least MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. Continued addition of heat to the suppression pool with suppression pool temperature

> 120°F could result in exceeding the design basis maximum allowable values for primary containment temperature or pressure.

Furthermore, if a blowdown were to occur when the temperature was > 120°F, the maxi mum a 11 ow able bulk and loca 1 temperatures could be exceeded very quickly. SR 3 . 6 . 2

.1. 1 The suppression pool average temperature is regularly monitored to ensure that the required limits are satisfied.

The average temperature is determined by taking an arithmetic average of OPERABLE suppression pool water temperature channels.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. When heat is being added to the suppression pool by testing, however, it is necessary to monitor suppression pool temperature more frequently.

The 5 minute Frequency during testing is justified by the rates at which tests will heat up the suppression pool, has been shown to be acceptable based on operating experience, and provides assurance that allowable pool temperatures are not exceeded.

The frequency is further justified in view of other indications available in the .control room, including alarms, to alert the operator to an abnormal suppression pool average temperature condition.

1. UFSAR, Section 6.2. 2. , UFSAR, Section 15.1.4. B 3.6.2.1-5 Revision 64 I *I ! I :i I :j BASES Suppression Pool Water Level B 3.6.2.2 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 Drywell Spray System. Therefore, continued operation for a limited time is allowed. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is sufficient to restore suppression pool water level to within limits. Also, it takes into account the low probability of an event impacting the suppression pool water level occurring during this interval.

B.1 and B.2 If suppression pool water level cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SR 3.6.2.2.1 Veri fi cation of the suppression poo 1 water l eve 1 *is to ensure that the required limits are satisfied.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.2. B 3.6.2.2-3 Revision 64

!

BASES RHR Suppression Pool Cooling B 3.6.2.3 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 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. 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. B 3.6.2.3-5 Revision 64 BASES RHR Suppression Pool Spray B 3.6.2.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 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. SR 3.6.2.4.1 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 5'00 gpm while operating in the suppression pool spray mode with flow through the heat exchanger ensures that pump performance ha*s 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, B 3.6.2.4-4 Revision 64 BASES Primary Containment Oxygen Concentration B 3.6.3.1 ACTIONS (continued)

B.1 SURVEILLANCE . REQUIREMENTS . REFERENCES FERMI -UNIT 2 If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, power must be reduced to 15% RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems. SR 3 . 6. 3 . 1. 1 The primary containment must be determined to be inert by verifying that oxygen concentration is < 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.2.5. B 3.6.3.1-3 Revision 64 BASES Secondary Containment B 3.6.4.1 ACTIONS (continued)

SURVEILLANCE . REQUIREMENTS FERMI

UNIT 2 The Required Actions have been modified by a Note stating that LCO 3.0.3 is not applicable.

If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SR 3. 6. 4 .1.1 This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.6.4.1.2 and SR 3.6.4.1.3 Verifying that secondary containment equipment hatches, pressure relief doors, railroad bay access doors, and one access door in each access opening are closed ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur. In this application, the term "sealed" has no connotation of leak tightness.

Maintaining secondary containment OPERABILITY requires verifying one door in each access opening is closed. An access opening contains one inner and one outer door. In some cases, secondary containment access openings are shared such that a secondary containment barrier may have multiple inner or multiple outer doors. The intent is not to breach the secondary containment at any time when secondary containment is required.

This is achieved by maintaining the inner or outer portion of the barrier closed at all times. However, B 3.6.4.1*5 Revision 64 I BASES Secondary Containment B 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 all secondary containment access doors are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. A Note is added to SR 3.6.4.1.2 to allow a secondary containment railroad bay access door to be open for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for entry, exit or testing, and up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for new fuel receipt activiti"es.

These activities do not indicate a problem with a railroad bay access door and the door should not be considered inoperable.

Also, with one railroad bay door remaining closed, secondary containment OPERABILITY is maintained.

The times allowed are reasonable for the activities being performed considering the availability of the redundant door. SR 3 . 6 .4. 1. 4 If the steam tunnel blowout panels are open the integrity of the Secondary Containment is lost. Since the steam tunnel blowout panels are inaccessible during plant operation, this SR is only required to be performed during MODE 4, but only if it has been greater than 31 days since the last verification.

This frequency has been shown to be adequate based on operating experience, and in view of other indications of the status of the steam tunnel blowout panels available to the operator.

SR 3.6.4.1.5 and SR 3.6.4.1.6 The SGT System exhausts the secondary*

containment atmosphere to the environment through appropriate treatment

equipment.

To ensure that all fission products are treated, SR 3.6.4.1.5 verifies that the SGT System will rapidly . establish and maintain a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary.

This is confirmed by demonstrating that one SGT subsystem will draw down the secondary containment to 0.25 inches of vacuum water gauge 12 minutes. *This cannot be accomplished if the secondary containment boundary is not intact.

SR 3.6.4.1.6 demonstrates that one SGT subsystem can B 3.6.4.1*6 Revision 64 BASES Secondary Containment 8 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI -UNIT 2 maintain 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate 3000 cfm. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months test period allows secondary containment to be in thermal equilibrium at steady state conditions.

Therefore, these two tests are used to ensure secondary containment boundary integrity.

Since these SRs are secondary containment tests, they need not be performed with each SGT subsystem.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.6.5. 2. UFSAR, Section 15.7.4. 3. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002. B 3.6.4.1-7 Revision 64 BASES SC IVs B 3.6.4.2 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 containment must be immediately suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position.

Also, if applicable, actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

The Required Actions have been modified by a Note stating that LCD 3.0.3 is not applicable.

If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCD 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SR 3.6.4.2.1 This SR verifies that each secondary containment manual isolation valve and blind flange that is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation.

Rather, it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position upon locking, sealing, or Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high; radiation areas and allows them to be verified by use of administrative controls.

Allowing verification by

administrative controls is considered acceptable, since access to these areas is typically restricted during B 3.6.4.2 -6 Revision 64 BASES SCIVs 8'3.6.4.2 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these SCIVs, once they have been verified to be in the proper position, is low. A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. SR 3.6.4.2.2 Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses.

The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. SR 3 . 6 .4. 2 . 3 Verifying that each automatic SCIV closes on a secondary containment isolation signal is required to prevent leakage of radioactive material from secondary containment following a DBA or other accidents.

This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.6.5. 2. UFSAR, Section 15.7.4. 3. Technical Requirements .Manual. B 3.6.4.2 *7 Revision*64 BASES SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 SR 3.6.4.3.1 SGT System B 3.6.4.3 Operating each SGT subsystem from the control room with flow through the HEPA filters and charcoal adsorbers for 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly.

It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test frequencies and additional information are discussed in detail in the VFTP. SR 3 . 6 .4. 3 . 3 This SR verifies that each SGT subsystem starts and associated dampers open on receipt of an actual or simulated initiation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.6.4.3.4 This SR verifies that the fi'l ter cool er bypass damper can be remote manually opened and the fan remote manually started. This ensures that the ventilation mode of SGT System operation is available.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.6.4.3-7 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.7.1.1 RHRSW System B 3.7.1 Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for RHRSW operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position.

This is acceptable because the RHRSW System is a manually initiated system. 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. 1. UFSAR, Section 9.2.5. 2. UFSAR, Chapter 6. 3. UFSAR, Chapter 9. 4. UFSAR, Chapter 15. 5. UFSAR, Section 6.3.2.14.

6. NEDC*32988*A, Revision 2, Technical Justification to Support Risk* Informed Modification to Selected Required End States for BWR Plants, December 2002. B 3.7.1-7 Revision 64 BASES EECW/EESW System and UHS B 3.7.2 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 D.1 and D.2 If the EECW/EESW subsystem cannot be restored to OPERABLE status within the associated Completion Time, or both EECW/EESW subsystems are inoperable for reasons other than Condition A, or the UHS is determined inoperable for reasons other than Conditions A and B, such as not meeting the combined water volume or average water temperature requirement, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems .. t SR 3.7.2.1 This SR verifies the water level in each RHR reservoir to be sufficient for the proper reservoir heat removal capability and long-term cooling capability (net positive suction head and pump vortexing are considered in determining this *limit). If each reservoir meets the 25 foot level limit (which equates to a water volume of 2,990,000 gal or 580 ft elevation) then the average reservoir level is known to be met without also doing a specific calculation.

If either reservoir does not meet the water level requirement, that reservoir is inoperable.

Verification of the UHS combined water volume is required to assess the OPERABILITY of the entire UHS. This ensures that the heat removal capability of the UHS is within the assumptions of the long-term cooling analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.2.2 Verification of the average water temperature in each reservoir, both individually and combined, ensures that the heat removal capability of the reservoirs and UHS are within the assumptions of the long-term cooling analysis.

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

B 3. 7.2-5 Revision 64 BASES EECW/EESW System and UHS B 3.7.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.2.3 FERMI -UNIT 2 Operating each cooling tower fan from the control room on both fast speed and slow speed, each for 15 minutes, ensures that all fans are OPERABLE and that all associated controls are functioning properly.

It also ensures that fan or motor failure, or excessive vibration, can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note stating that testing at fast speed is not required during icing conditions.

This allowance is as a result of manufacturer recommendations, due to increased stress caused by ice on the fan blades. Icing conditions exist when ambient temperatures are 36°F and water is being returned to the cooling towers from RHRSW, EDG service water, or EESW. SR 3.7.2.4 Verifying the correct alignment for each manual, power operated, and automatic valve-in each EECW/EESW subsystem flow path provides assurance that the proper flow paths will exist for EECW/EESW 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, and yet considered in the correct position, provided it can be automatically realigned to its accident position within the required time. 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. This SR also applies to the RHR Reservoir cross-connect valves. These valves are normally aligned such that each cross-tie line between the reservoirs has at least one valve open, provided any closed valve(s) are OPERABLE for opening. With closed cross-connect valve(s) incapable of being remote-manually cross-connected (i.e., inoperable), the continued OPERABILITY of both reservoirs for the long term cooling function may be maintained by de-energizing open both cross-connect valves in one cross-tie line. B 3.7.2-6 Revision 64 BASES EECW/EESW System and UHS B 3.7.2 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 This SR is modified by a Note indicating that isolation of EECW flow to components or systems may render those components or systems inoperable, but does not necessarily affect the OPERABILITY of the EECW/EESW System. As such, when all EECW pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the EECW/EESW System may still be considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.2.5 This SR verifies that the automatic isolation valves of the EECW/EESW System will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by the use of an actual or simulated initiation signal. This SR also verifies the automatic start capability of the EECW and EESW pumps in each subsystem.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Chapter 9. 2. UFSAR, Chapter 4. 3. UFSAR, Chapter 6. B 3.7.2-7 Revision 64 BASES SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 SR 3.7.3.1 CREF System B 3.7.3 This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate. Standby systems should be checked periodically to ensure that they start and function properly.

Operation with the heaters on for 15 continuous minutes demonstrates

.* OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.3.2 This SR verifies that the required CREF testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

Specific test Frequencies and additional information are discussed in detail in the VFTP. The Note for this SR provides an allowance to delay entry into the associated Conditions and Required Actions for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in MODES 1, 2, and 3. This allowance prevents intentional entry into LCO 3.0.3 that would otherwise be caused by tests required by the VFTP. The tests that may be required while operating in MODE 1, 2, or 3 are: 1) the periodic charcoal sample; and 2) tests and samples required after exposing the filtration system to ventilation from painting, fire, or chemical release. Other VFTP required surveillances can be scheduled when the plant is not operating in MODE 1, 2, or 3. B 3.7.3-10 Revision 64

' i ' l I , I l BASES CREF System B 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.3.3 FERMI -UNIT 2 This SR verifies that on an actual or simulated initiation signal, each CREF subsystem starts, isolation valves close within 5 seconds, and operates.

The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function.

The Surveillance Frequency is contra 11 ed under the Survei 11 ance Frequency Contra 1 Program. SR 3.7.3.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program. The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.

When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status

provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident.

Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 8) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 9). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 10). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, *repairing the CRE boundary, or a combination of these actions. Depending upon the nature of . the problem and the corrective action, a full scope . inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status. B 3.7.3-11 Revision 64 BASES Control Center AC System B 3.7.4 ACTIONS (continued)

REFERENCES FERMI

UNIT 2 E.l and E.2 The Required Actions of Condition E are modified by a Note i ndi cati ng that LCO 3. 0. 3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of recently irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Actions B.1 and B.2 cannot be met within the required Completion Times, action must be taken to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. If applicable, handling of recently irradiated fuel in the secondary containment must be suspended immediately.

Suspension of these activities shall not preclude completion of movement of a component to a safe position.

Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

SR 3. 7.4.1 This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load. The SR consists of a verification of the control room temperature.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 6.4. 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk* Informed Modification to Selected Required End States for BWR Plants, December 2002. 3. UFSAR, Section 9.4.1. B 3.7.4*6 Revision 64 ' j j !1 *! BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 SR 3.7.5.1 and SR 3.7.5.2 Main Condenser Offgas B 3.7.5 This SR requires an isotopic analysis of an offgas sample to ensure that the required limits are satisfied.

The noble gases to be sampled are Xe-133, Xe-135, Xe-138, Kr-85, Kr-87, and Kr-88. If the measured rate of radioactivity increases significantly (by 50% after correcting for expected increases due to changes in THERMAL POWER), an isotopic analysis is also performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.5.1 is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.

Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates. 1. UFSAR, Section 15.7.1. 2. 10 CFR 100. 3. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002. B 3.7.5-4 Revision 64 Main Turbine Bypass System and Moisture Separator Reheater

B 3.7.6 BASES ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 specified in the COLR, are not applied, the assumptions of the design basis transient analysis may not be met. Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System and Moisture Separator Reheater to OPERABLE status or adjust the MCPR limits accordingly.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is reasonable, based on the time to complete the Required Action and the low probability of an event occurring during this period requiring the Main Turbine Bypass System and/or Moisture Separator Reheater.

B.1 If the Main Turbine Bypass System and Moisture Separator Reheater cannot be restored to OPERABLE status or the MCPR limits for an inoperable Main Turbine Bypass System and/or Moisture Separator Reheater are not applied, THERMAL POWER must be reduced to < 25% RTP. As discussed in the Applicability section, operation at < 25% RTP results in sufficient margin to the required limits, and the Main Turbine Bypass System and Moisture Separator Reheater are not required to protect fuel integrity during rapid pressurization transients.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SR 3.7.6.1 and SR 3.7.6.2 Cycling each main turbine bypass valve through at least 5% of full travel demonstrates that the valves are mechanically OPERABLE and will function when required.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.6.2, which cycles each main turbine bypass valve through one complete cycle of full travel, is performed after each entry into MODE 4, since this will not affect operating conditions, and will provide added assurance of valve OPERABILITY.

B 3.7.6-3 Revision 64 BASES Main Turbine Bypass System and Moisture Separator Reheater B 3.7.6 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.

6.3 REFERENCES

FERMI

UNIT 2 The Main Turbine Bypass System and Moisture Separator Reheater are required to actuate automatically to perform its design function.

This SR demonstrates that, with the required system initiation signals, the valves will actuate to their required position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.7.6.4 This SR ensures that the TURBINE BYPASS SYSTEM RESPONSE TIME is in compliance with the assumptions of the appropriate safety analysis.

The response time limits are specified in the Technical Requirements Manual. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 7.7.1.4. 2. UFSAR, Chapter 15. B 3.7.6*4 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 Spent Fuel Storage Pool Water Level B 3.7.7 SR 3.7.7.1 This SR verifies that sufficient water is available in the event of a fuel handling accident.

The water level in the spent fuel storage pool must be checked periodically.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 9 . 1. 2 . 2. UFSAR, Section 15 .7. 4. 3. 10 CFR 100. 4. NUREG-0800, Section 15.7.4, Revision 1, July 1981. 5. Regulatory Guide 1.25, March 1972. 6. UFSAR, Section 15.7.4.1.1.

7. 10 CFR 50.67 8. Regulatory Guide 1.183, June 2000. B 3.7.7-3 Revision 64 1-BASES APPLICABILITY ACTIONS EDGSW System B 3.7.8 The requirements for OPERABILITY of the EDGSW subsystems are governed by the required OPERABILITY of the EDGs (LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, "AC Sources -Shutdown") . A.1 If one or more EDGSW subsystems are inoperable, the OPERABILITY of the associated EDG(s) is affected due to loss of its cooling source. The EDG(s) cannot perform its intended function and must be immediately declared inoperable.

In accordance with LCO 3.0.6, this also requires entering into the Applicable Conditions and Required Actions for LCO 3.8.1 or LCO 3.8.2. SURVEILLANCE SR J.7.8.l .REQUIREMENTS , FERMI -UNIT 2 Verifying the correct alignment for manual, power operated, and automatic valves in the EDGSW System flow path provides assurance that the proper flow paths will exist for EDGSW 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, and yet be considered in the correct position provided it can be automatically realigned to its accident position, within the required time. 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. B 3.7.8-2 Revision 64 BASES EDGSW.System 8 3.7.8 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.

8.2 REFERENCES

FERMI

UNIT 2 This SR ensures that each EOGSW subsystem pump will automatically start to provide required cooling to the EOG when the EOG starts. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 9.2.5. 2. UFSAR, Chapter 6. 3. UFSAR, Chapter 15. B 3.7.8-3 Revision 64 AC Sources-Operating . B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 This value is also bounding for Division II and ensures that adequate voltage is available to the equipment supported by Division I and II of the EDGs. The specified maximum steady state output voltage of 4580 V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages.

The specified minimum and maximum frequencies of the EOG are 58.8 Hz and 61.2 Hz, respectively.

These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Regulatory Guide 1.9 (Ref. 3). SR 3.8.1. l This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite. distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.1.2 and SR 3.8.1.7 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.

To minimize the mechanical stress and wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note 1 for SR 3.8.1.2 and the Note for SR 3.8.1.7) to indicate that all EDG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup prior to loading. B 3.8.1-17 Revision 64 I :I I BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 For the purposes of SR 3.8.1.2 testing, the EOGs are started anywhere from standby to hot conditions by using one of the following signals: Manual, Simulated loss-of-offsite power by itself, Simulated loss-of-offsite power in conjunction with an ESF actuation test signal, or An ESF actuation test signal by itself. In order to reduce stress and wear on diesel engines, the EOG manufacturer recommends a modified start in which the starting speed of EOGs is limited, warmup is limited to this lower speed, and the EOGs are gradually accelerated to . synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only allowed to satisfy SR 3.8.1.2 but are not applicable when performing SR 3.8.1.7. SR 3;8.1.7 requires that the EOG starts from* standby conditions and achieves required voltage and frequency within 10 seconds. Standby conditions for an EOG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.

The 10 second start requirement supports the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (Ref. 13). The 10 second start requirement is not applicable to SR 3.8.1.2. Since SR 3.8.1.7 does require a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. In addition to the SR requirements, the time for the EOG to reach steady state operation, unless the modified EOG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.8.1-18 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.3 FERMI -UNIT 2 This Surveill.ance provides assurance that the EOGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads without the risk of overloading the EOG. The EOG is tested at approximately 90.%' of its continuous load rating, which provides margin to excessive EDG loading, while demonstrating the EOG capability to carry loads near the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the EOG is connected to the offsite source. Although no power factor requirements are established by this SR, the EOG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is an operational limitation to ensure circulating currents are minimized.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EOG OPERABILITY.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.

B 3.8.1-19 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 Note 2 modifies this Surveillance by stating that momentary transients (e;g., because of changing bus loads) do not invalidate this test. Similarly, momentary power factor transients outside the normal range do not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one EOG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.

SR 3.8.1.4 This SR provides verification that there is an adequate inventory of fuel oil in the day tank to support the EOG operation for a minimum of one hour at full load. The volume of fuel oil equivalent to one hour supply is 210 gallons. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation.

There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Periodic removal of water from the fuel oil day tanks eliminates the necessary environment for bacterial survival.

This is.the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during EOG operation.

Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.8.1-20 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3 .8.1.6 FERMI

UNIT 2 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

The design of fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tank during or following EDG testing. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.1. 7 . See SR 3.8.1.2. SR 3.8.1.8 Each EDG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the EDG load response characteristics and capability to reject the largest single load while maintaining a specified margin to the overspeed trip. The largest single load for each EDG is a residual heat removal pump (1684 kW). This Surveillance may be accomplished by: a. b. Tripping the EOG output breaker with the EOG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or Tripping its associated single largest post-accident load with the EDG solely supplying the bus. B 3.8.1-21 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 As required by IEEE-308 (Ref. 15), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower. This represents 66.75 Hz, equivalent to 75% of the difference between nominal speed and the overspeed trip setpoint.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.1. 9 This Surveillance demonstrates the EOG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits. The EOG full load rejection may occur because of a system fault or inadvertent breaker tripping.

This Surveillance ensures proper engine generator load response under the simulated test conditions.

This test simulates the loss of the total connected load that the EOG experiences following a full load rejection and verifies that the EOG does not trip upon loss of the load. These acceptance criteria provide EOG damage protection.

While the EDG is not expected to experience this transient during an event, and continues to be available, this response ensures that the EOG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

The Surveillance Frequency-is controlled under the Surveillance Frequency Control Program. B 3.8.1-22 Revision 64 I BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.10 FERMI

UNIT 2 As required by Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the EOG, including automatic start of the EOG cooling water pump. It further demonstrates the capability of the EOG to automatically achieve the required voltage and frequency within the specified time. ' The EOG auto-start time of 10 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to

satisfactorily show the relationship of these loads to the EOG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.

For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation.

In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the EOG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3 .8. l-23 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 This SR is modified by a Note allowing EOG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EOGs during testing. SR 3.8.1.11 This Surveillance demonstrates that the EOG (including its associated cooling water pump) automatically starts and achieves the required minimum voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates 5 minutes. The 5 minute period provides sufficient time to demonstrate stabi 1 i ty. . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note allowing EOG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EOGs during testing. SR 3.8.1.12 This Surveillance demonstrates that EOG non-critical protective functions (e.g., high jacket water temperature) are bypassed on an actual or simulated emergency start (LOCA or loss of offsite power) signal. The non-critical trips are bypassed during OBAs and provide an alarm on an abnormal engine condition.

This alarm provides the operator with sufficient time to react appropriately.

The EOG availability to mitigate the OBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the EOG. 8 3.8.1-24 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 .8.1.13 Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(3), requires demonstration that the EOGs can start and run continuously at full load capability for an interval of not less than 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s-22 hours of which is at a load equivalent to the continuous rating of the EOG, and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of which is at a load equivalent to 110% of the continuous duty rating of the EOG. Fermi-2 has taken an exception to this requirement and performs the 22 hour2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months run at approximately 90% of the continuous rating (2500 kW-2600 kW), and performs the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months run at approximately the continuous rating (2800 kW-2900 kW). The EOG starts for this Surveillance can be performed either from standby or hot conditions.

The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR. A 1 though no power* factor requirements are es tab 1 i shed by this SR, the EOG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is an operational limitation to ensure circulating currents are minimized.

A load band is provided to avoid routine overloading of the EOG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EOG OPERABILITY.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This Surveillance has been modified by a Note. The Note states that momentary transients due to changing bus loads do not invalidate this test. B 3.8.1-25 Revision 64 I

'BASES AC Sources-Operating B 3.8.l SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.14 FERMI

UNIT 2 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the minimum required voltage and frequency within 10 seconds and maintain a steady state voltage and frequency range. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months near full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.

Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY.

Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all EDG starts to be . preceded by an engine prelube period to minimize wear and tear on the diesel during testing. SR 3.8.1.15 .As required by Regulatory Guide 1.108 (Ref. 10), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and load transfer from the EOG to the offsite source can be made and that the EOG can be returned to standby status when offsite power is restored.

It also ensures that the auto-start logic is reset to allow the EDG to restart and reload if a subsequent loss of offsite power. occurs. The EDG is considered to be in standby status when the EOG is shutdown with the output breaker open, the load sequence timers are reset, and is able to restart and reload on a subsequent bus under voltage. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 8 3.8.1-26 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.16 FERMI

UNIT 2 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequencer.

The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the EDGs due to high motor starting currents.

The 10% load sequence time interval tolerance ensures that sufficient time exists for the EOG to restore frequency and voltage prior to applying the next load and that safety*analysis assumptions regarding ESF equipment time delays are not violated.

Reference 2 provides a summary of the automatic*

loading of ESF buses. The Surveillance Frequency is controlled under the . Surveillance Frequency Control Program. SR 3.8.1.17 In the event of a DBA coincident with a loss of offsite power, the EDGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

This Surveillance demonstrates EDG operation, as discussed in the Bases for SR 3.8.1.10, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the EDG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note allowing EDG starts to be preceded by an*engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing.

B 3.8.1-27 Revision 64 BASES AC Sources-Operating B 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.18 REFERENCES FERMI

UNIT 2 This Surveillance demonstrates that the EOG starting independence has not been compromised.

Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the EDGs are started simultaneously.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note allowing EOG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear on the EOG during testing. 1. 10 CFR 50, Appendix A, GDC 17. 2. UFSAR, Sections 8.2 and 8.3. 3. Regulatory Guide 1.9. 4. UFSAR, Chapter 6. 5. UFSAR, Chapter 15. 6. Regulatory.

Guide 1.93. 7. Generic Letter 84-15. 8. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002. 9. 10 CFR 50, Appendix A, GDC 18. 10. Regulatory Guide 1.108. 11. Regulatory Guide 1.93. 12. Deleted. 13. UFSAR, Section 6.3. 14. ASME Boiler and Pressure Vessel Code,Section XI. 15. IEEE Standard 308. 8 3.8.1-28 Revision 64 BASES Diesel Fuel Oil and Starting Air B 3.8.3 ACTIONS (continued)

A.1 .FERMI

UNIT 2 In this Condition, the 7 day fuel oil supply for a required EDG is not available.

However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply. The fuel oil level equivalent to a 6 day supply is 30,240 gallons. These circumstances may be caused by events such as: a. Full load operation required for an inadvertent start while at minimum required level; or b.

Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required level prior to declaring the EDG inoperable.

This period is acceptable based on the remaining capacity(>

6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. 8.1 This Condition is entered as a result of a failure to meet the acceptance criterion for particulates in one or more required EDG storage tanks. Normally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability.

Poor sample procedures (bottom sampling), contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, since particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and since proper engine performance has been recently demonstrated, it is prudent to allow a brief period prior to declaring the associated EDG inoperable.

The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the EDG fuel oil. B 3.8.3*3 Revision 64 BASES ------------------

Diesel Fuel Oil and Starting Air B 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.3.2 The tests of fuel oil prior to addition to the storage tank are a means of determining whether new fuel oil is of the appropriate grade and has not been contaminated with substances that would have an immediate detrimental impact on diesel engine combustion.

If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s), out in no case is the tjme between sampling (and associated results) of new fuel and addition of new fuel oil to the storage tank to exceed 31 days. The tests, limits, and applicable ASTM Standards for the new fuel oil tests listed in the Emergency Diesel Generator Fuel Oil Testing Program of Specification 5.5 are as follows: a. Sample the new fuel oil in accordance with ASTM D975-07B (Ref. 6); . b. Verify that the sample has an AP! Gravity of within 0.3 degrees at 60°F or a specific gravity of within 0.0016 at 60/60°F, when compared to the suppliers certificate, or an absolute specific gravity at 60/60°F 0.83 and 0.89 or an AP! gravity at 60°F of 27° and 39° when tested in accordance with ASTM Dl298-85 (Ref. 6). Also, verify in accordance with the tests specified in ASTM 0975-078 (Ref. 6) a kinematic viscosity at 40°C of 1.9 centistokes 4.1 centistokes, and a flash point of 125°F; and c. Verify that the new fuel oil has a clear and bright appearance with proper color when tested in accordance with ASTM D4176-86 or a water and sediment content within limits when tested in accordance with ASTM 0975-078 (Ref. 6). Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO since the fuel oil is not added to the storage tanks. Following the initial new fuel oil sample, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-07B (Ref. 6) are met for new fuel oil B 3.8.3-5 Revision 64

. *: Diesel Fuel Oil and Starting Air . B 3.8.3 BASES SURVEILLANCE REQUIREMENTS (continued)

REFERENCES FERMI

UNIT 2 to reflect the lowest value at which the five starts can be accomplished.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.3.4 Microbiological fouling is a major cause of fuel oil degradation.

There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Periodic removal of water from the required EDG fuel storage tanks eliminates the necessary environment for bacterial survival.

This is the most effective means of controlling microbiological fouling. In addition, it.eliminates the potential for water entrainment in the fuel oil during EDG operation.

Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria.

Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. 2. 3. 4. 5. 6. 7. UFSAR, Section 9.5.4. Regulatory Guide 1.137. ANSI Nl95, 1976. UFSAR, Chapter 6. UFSAR, Chapter 15. ASTM Standards:

D975*07B:

D1298*85; D4176*86; D5452*00.

C2 010 US 1, Fairbanks Morse Skidded Heat Exchanger Cooled Diesel Generator Sets B 3.8.3*7 Revision 64 DC Sources-Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources-Operating BASES BACKGROUND FERMI

UNIT 2 The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related . equipment.

As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3). The DC power sources provide both motive and control power to selected safety related equipment, as well as circuit breaker control power for the nonsafety related 480 V loads that are connected to 480 V ESF buses: Two center-tapped 260 VDC batteries are provided for Class lE loads. They are designated 2PA for Division I and 2PB for Division II. Each 260 VDC battery is divided into two 130 VDC batteries connected in series. Each 130 VDC battery section has a battery charger connected in parallel with their respective battery. Each 260 VDC battery has a spare battery charger that can replace either of the normal 130 VDC connected chargers.

Each division's two 130 VDC batteries and their chargers are the source of DC control power for that respective division, including the respective EDG. Each 260 VDC source furnishes power to DC motors necessary for shutdown conditions.

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the In case of loss of normal power to the battery charger, the DC loads are automatically powered from the batteries.

The DC power distribution system is described in more detail in Bases for LCO 3.8.7, "Distribution System-Operating," and LCO 3. 8. 8, "Distribution System-Shutdown. " Each battery has adequate storage capacity to carry the required load continuously for approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (Ref. 11). B 3.8.4-1 Revision 64 I '

BASES DC Sources-Operating B 3.

8.4 BACKGROUND

(continued)

Each DC battery subsystem is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem.

There,is no sharing between redundant Class lE subsystems such as batteries, battery chargers, or distribution panels. The batteries for DC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage limit is 105/210 V. Each battery charger of DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state 1 oads (Ref. 11). APPLICABLE The initial conditions of Design Basis Accident (OBA) and SAFETY transient analyses in the UFSAR, Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume that Engineered Safety Feature (ESF) systems are OPERABLE.

The DC electrical power system provides normal and emergency DC electrical power for the EDGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining sufficient DC sources OPERABLE during accident conditions in the event of: FERMI

UNIT 2 a. An assumed loss of all offsite AC power or all onsite AC power; and b. A worst case single failure. The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

B 3.8.4-2 Revision 64 BASES DC Sources-Operating B 3.8.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2

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. SR 3:8.4.1 Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function.

Float charge is the condition in which the charger supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed, in the battery sizing calculations.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3 .8.4. 2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each inter-cell and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.

The connection resistance limits procedurally established for this SR are no more than 20% above the resistance as measured during installation and not above the ceiling value established by the manufacturer.

This provides conservative measures to assure the Technical Specification limit is not exceeded.

For each inter-cell and terminal connection, the limit is 150 micro-ohm.

The total resistance of each 130 VDC battery is also monitored.

This resistance is the total aggregate measured resistance of the cell-to-cell and terminal connections of each 130 VDC battery. The limit for total connection resistance of each 130 VDC battery is 2700 ohm. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B. 3.8.4-5 Revision 64 BASES DC Sources -Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.3 ' FERMI -UNIT 2 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery per.formance.

The presence of physical damage or deterioration does not necessarily represent a failure of this SR, provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.4.4 and SR 3.8.4.5 Visual inspection and resistance measurements of inter-cell and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition.

The anti-corrosion material is used to help ensure good electrical connections and to reduce terminal deterioration.

The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.

The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance.

The connection resistance limits procedurally established for this SR are no more than 20% above the resistance as measured during installation, and not above the ceiling value established by the manufacturer

.. This provides conservative measures to assure the Technical Specification limit is not exceeded.

For each inter-cell and terminal connection, the limit is 150 micro-ohm.

The total resistance of each 130 VDC battery is also monitored.

This resistance is the total aggregate measured resistance of the cell-to-cell and terminal connections of each 130 VDC battery. The limit for total connection resistance of each 130 VDC battery is 2700 ohm. B 3.8.4-6 Revision 64 BASES DC Sources-Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.4.6 Battery charger capability requirements are based on the design capacity of the chargers (Ref. 3). According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of.the status of the unit during these demand occurrences.

The minimum required amperes and duration ensures that these requirements can be satisfied.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.4.7 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference

4. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. This SR is modified by a Note that allows the performance of a performance discharge test in lieu of a service test. B 3.8.4-7 Revision 64 BASES DC Sources -Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.8 FERMI -UNIT 2 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage. The battery performance discharge test is acceptable for satisfying SR 3.8.4.7 as noted in SR 3.8.4.7. The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 7) and IEEE-485 (Ref. 10). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 7), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is 10% below the manufacturer's rating. All these Frequencies are consistent with the recommendations in IEEE-450 (Ref. 7). This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance.

B 3.8.4-8 Revision 64 BASES REFERENCES FERMI

UNIT 2 1. 2. 3. 4. 5. 6. 7. 8. 10 CFR 50, Appendix A, GDC 17. Regulatory Guide 1.6. IEEE Standard 308, 1978. UFSAR, Chapter 6. UFSAR, Chapter 15. Regulatory Guide 1.93. IEEE Standard 450. DC Sources-Operating B 3.8.4 NEDC*32988*A, Revision 2, Technical Justification to Support Risk* Informed Modification to Selected Required End States for BWR Plants, December 2002. 9. Regulatory Guide 1.32, February 1977. 10. IEEE Standard 485, 1983. 11. UFSAR, Section 8.3.2. B 3.8.4-9 Revision 64 BASES APPLICABILITY ACTIONS FERMI -UNIT 2 Battery Cell Parameters B 3.8.6 The battery cell parameters are required solely for the support of the associated DC electrical power subsystem.

Therefore, battery electrolyte is only required when the DC power source is required to be OPERABLE.

Refer to the Applicability discussions in Bases for LCO 3.8.4 and LCO 3.8.5. A.l, A.2, and A.3 With parameters of one or more cells in one or more batteries not within limits (i.e., Category A limits not met or Category B limits not met, or Category A and B limits not met) but within the Category C limits specified in Table 3.8.6-1, the battery is degraded but there is still sufficient capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of Category A or B limits not met, and continued operation is permitted for a limited period. The pilot cell electrolyte level and float voltage are required to be verified to meet the Category C limits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (Required Action A.1). This check provides a quick indication of the status of the remainder of the battery cells. One hour provides time to inspect the electrolyte level and to confirm the float voltage of the pilot cells. One hour is considered a reasonable amount of time to perform the required verification.

Verification that the Category C limits are met (Required Action A.2) provides assurance that during the time needed to restore the parameters to the Category A and B limits, the battery is still capable of performing its intended function.

A period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to complete the initial verification because specific gravity measurements must be obtained for each connected cell. Taking into consideration both the time required to perform the required verification and the assurance that the battery cell parameters are not severely degraded, this time is considered reasonable.

The verification is repeated*at 7 day intervals until the parameters are restored to Category A and B limits. ' B 3.8.6-2 Revision 64 BASES Battery Cell Parameters B 3.8.6 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. Taking into consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable for operation prior to declaring the DC batteries inoperable.

B.1 When any battery parameter is outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding DC electrical power subsystem must be declared inoperable.

Additionally, other potentially extreme conditions, such as not completing the Required Actions of Condition A within the required Completion Time or average electrolyte temperature of representative cells falling below 70°F, also are cause for immediately declaring the associated DC electrical power subsystem inoperable.

SR 3.8.6.1 This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 3), which recommends regular battery inspections including voltage, specific gravity, and electrolyte temperature of pilot cells. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.6.2 The inspection of specific gravity and voltage is consistent with IEEE-450 (Ref. 3). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. In addition, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a battery discharge

< 105 V or a battery overcharge>

145 V, the battery must be demonstrated to meet Category B limits. Transients, such as motor starting transients, which may momentarily cause battery voltage to drop 105 V, do not constitute a battery discharge provided the battery terminal voltage and float current B 3.8.6-3 Revision 64 BASES Battery Cell Parameters B 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

FERMI -UNIT 2 return to pre-transient values. This inspection is also consistent with IEEE-450 (Ref. 3), which recommends special inspections following a severe discharge or overcharge, to ensure that no significant degradation of the battery occurs as a consequence of such discharge or overcharge.

SR 3.8.6.3 This Surveillance verification that the average temperature of representative cells (i.e., selection of 10 connected cells) is within limits is consistent with a recommendation of IEEE-450 (Ref. 3) that states that the temperature of electrolytes in representative cells should be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Lower than normal temperatures act to inhibit or reduce battery capacity.

This SR ensures that the operating temperatures remain within an acceptable operating range. This limit is based on manufacturer's recommendations.

Table 3.8.6-1 This table delineates the limits on electrolyte level, float voltage, and specific gravity for three different categories.

The meaning of each category is discussed below. Category A defines the normal parameter limit for each designed pilot cell in each battery. The cells selected as pilot cells are those whose temperature, voltage, and electrolyte specific gravity approximate the state of charge of the entire battery. The Category A limits specified for electrolyte level are based on manufacturer's recommendations and are consistent with the guidance in IEEE-450 (Ref. 3), with the extra inch allowance above the high water level indication for operating margin to account for temperature and charge effects. In addition to this allowance, footnote (a) to Table 3.8.6-1 permits the electrolyte level to be above the specified maximum level during equalizing charge, provided B 3.8.6-4 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 SR 3.8.7.1 Distribution Systems-Operating B 3.8.7 This Surveillance verifies that the AC and DC, electrical power distribution systems are functioning properly, with the correct circuit breaker alignment.

The correct breaker alignment ensures the appropriate separation and independence of the electrical subsystems are maintained, and the appropriate voltage is available to each required bus, MPU, DC distribution cabinet, or DC MCC. The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these distribution subsystems.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Chapter 6. 2. UFSAR, Chapter 15. 3. Regulatory Guide 1.93, December 1974. 4. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002. B 3.8.7-9 Revision 64 BASES Di stri buti on Systems -Shutdown B 3.8.8 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made, (i.e., to suspend CORE ALTERATIONS, movement of recently irradiated fuel assemblies in the secondary containment, and any activities that could result in inadvertent draining of the reactor vessel). Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal-shutdown cooling (RHR*SDC) subsystem may be inoperable.

In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR*SDC ACTIONS would not be entered. *Therefore, Required Action A.2:5 is provided to direct declaring RHR*SDC inoperable and not in operation, which results in taking the appropriate RHR*SDC ACTIONS. The Completion Time of immediately is consistent with the required times for actions requiring prompt attention.

The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time* the plant safety systems may be without power. SR 3.8.8.l This Surveillance verifies that the AC and DC electrical power distribution subsystem is functioning properly, with the buses energized.

The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The *s 3.8.8* 4 Revision 64

BASES Di stri buti on Systems -Shutdown 8 3.8.8 SURVEILLANCE REQUIREMENTS (Continued)

REFERENCES FERMI

UNIT 2 Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Chapter 6. 2. UFSAR, Chapter 15. 8 3.8.8-5 Revision 64 BASES SURVEILLANCE REQUIREMENTS

: REFERENCES FERMI

UNIT 2 SR 3. 9.1.1 Refueling Equipment Interlocks B 3.9.1 Performance of a CHANNEL FUNCTIONAL TEST demonstrates each required refueling equipment interlock will function properly when a simulated or actual signal indicative of a required condition is injected into the logic. The CHANNEL 'FUNCTIONAL TEST may be performed by any series of sequential, overlapping, or total channel steps so that the entire channel is tested. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. 10 CFR 50, Appendix A, GDC 26. 2. UFSAR, Section 7.6.l. 3. UFSAR, Section 15.4.1.1.

4. UFSAR, Section 15.4.1.1.2.2.

B 3.9.1-5 Revision 64 BASES ACTIONS SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 A.land A.2 Refuel Position One-Rod-Out Interlock B 3.9.2 With the refueling position one-rod-out interlock inoperable, the refueling interlocks may not be capable of preventing more than one control rod from being withdrawn.

This condition may lead to criticality.

Control rod withdrawal must be immediately suspended, and action must be immediately initiated to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Action must continue until all such control rods are fully inserted.

Control rods in core cells containing no fuel assemblies do not affect the reactivity of the core and, therefore, do not have to be inserted.

SR 3.9.2.1 Proper functioning of the refueling position one*rod-out interlock requires the reactor mode switch to be in Refuel. During control rod withdrawal in MODE 5, improper positioning of the reactor mode switch could, in some instances, allow improper bypassing of required interlocks.

Therefore, this Surveillance imposes an additional level of assurance that the refueling position one-rod-out interlock will be OPERABLE when required.

By "locking" the re.actor mode switch in the proper position (i.e., removing the reactor mode switch key from the console while the reactor mode switch is positioned in refuel), an additional administrative control is in place to preclude operator errors from resulting in unanalyzed operation.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.9.2-3 Revision 64 BASES Refuel Position One-Rod-Out Interlock 8 3.9.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.

2.2 REFERENCES

FERMI -UNIT 2 Performance of a CHANNEL FUNCTIONAL TEST demonstrates the associated refuel position one-rod-out interlock will function properly when a simulated or actual signal indicative of a required condition is injected into the logic. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlapping, or total channel steps so that the entire channel is tested. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. To perform the required testing, the applicable condition must be entered (i.e., a control rod must be withdrawn from its full-in position).

Therefore, SR 3.9.2.2 has been .modified by a Note that states the CHANNEL FUNCTIONAL TEST is not required to be performed until l'hour after any control rod is withdrawn.

1. 10 CFR 50, Appendix A, GDC 26. 2. UFSAR, Section 7.6.1.1. 3. UFSAR, Section 15.4.1.1.

B 3.9.2-4 Revision 64 BASES LCO APPLICABILITY ACTIONS SURVEILLANCE REQUIREMENTS FERMI

UNIT 2 Control Rod Position B 3.9.3 All control rods must be fully inserted during applicable refueling conditions to minimize the probability of an inadvertent criticality during refueling.

During MODE 5, loading fuel into core cells with control rods withdrawn may result in inadvertent criticality.

Therefore, the control rods must be inserted before loading fuel into a core cell. All control rods must be inserted before loading fuel to ensure that a fuel loading error does not result in loading fuel into a core cell with the control rod withdrawn.

In MODES 1, 2, 3, and 4, the reactor pressure vessel head is on, and no fuel loading activities are possible.

Therefore, this Specification is not applicable in these MODES. A.1 With all control rods not fully inserted during the applicable conditions, an inadvertent criticality could occur that is not analyzed in the UFSAR. All fuel loading operatio"ns must be immediately suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position.

SR 3.9.3.l During refue.l i ng, to ensure that the reactor remains subcritical, all control rods must be fully inserted prior to and during fuel loading. Periodic checks of the control rod position ensure this condition is maintained.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.9.3*2 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 Control Rod OPERABILITY

-Refueling B 3.9.5 SR 3.9.5.1 and SR 3.9.5.2 During MODE 5, the OPERABILITY of control rods is primarily required to ensure a withdrawn control rod will automatically insert if a signal requiring a reactor shutdown occurs. Because no explicit analysis exists for automatic shutdown during refueling, the shutdown function is satisfied if the withdrawn control rod is capable of automatic insertion and the associated CRD scram accumulator pressure is 940 psig. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.9.5.1 is modified by a Note that allows 7 days after withdrawal of the control rod to perform the Surveillance.

This acknowledges that the control rod must first be withdrawn before performance of the Surveillance, and therefore avoids potential conflicts with SR 3.0.3 and SR 3.0.4. 1. 10 CFR 50, Appendix A, GDC 26. 2. UFSAR, Section 15.4.1.1.

3. UFSAR, Section 15.4.1.1.2.2.

B 3.9.5*3 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 SR 3.9.6.1 RPV Water Leve 1 B 3.9.6 Verification of a minimum water level of 20 ft 6 inches above the top of the RPV flange ensures that the design basis for the postulated fuel handling accident analysis during refueling operations is met. Water at the required level limits the consequences of damaged fuel rods, which are postulated to result from a fuel handling accident in secondary containment (Ref. 2). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. Regulatory Guide 1.25, March 23, 1972. 2. UFSAR, Section 15.7.4. 3. NUREG-0800, Section 15.7.4. 4. 10 CFR 100. 11. 5. UFSAR, Section 9.1.2.2.1.

6. Regulatory Guide 1.183, June 2000. B 3.9.6*3 Revision 64 BASES SURVEILLANCE REQUIREMENTS SR 3.9.7.1 RHR-High Water Level B 3.9.7 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 BASES RHR-Low Water Level B 3.9.8 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS FERMI -UNIT 2 OPERABILITY of the components.

If, however, any required component is inoperable, then it must be restored to OPERABLE status. In this case, the surveillance may need to be performed to restore the component to OPERABLE status. Actions must continue until all required components are OPERABLE. C.1, C.2, and C.3 If no RHR subsystem -and no recirculation pump is in operation, immediate action must be initiated to restore either an RHR subsystem or a recirculation pump to operation.

In addition, an alternate method of coolant circulation is required to be established within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time 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.

During the period when the reactor coolant is being circulated by an alternate method (other than by the requi.red RHR Shutdown Cooling System or recirculation pump), the reactor coolant temperature must be periodically monitored to ensure proper functioning of the alternate method. The once per hour Completion Time is deemed appropriate.

SR 3.9.8.1 This Surveillance demonstrates that one RHR shutdown cooling subsystem or one 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 remov a 1 capabi 1 i ty. . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. B 3.9.8-4 Revision 64 BASES RHR...:. Low Water Leve 1 B 3.9.8 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 BASES SURVEILLANCE REQUIREMENTS REFERENCES , FERMI

UNIT 2 Reactor Mode Switch Interlock Testing B 3.10.2 SR 3.10.2.1 and SR 3.10.2.2 Meeting the requirements of this Special Operations LCO maintains operation consistent with or conservative to operating with the reactor mode switch in the shutdown position (or the refuel position for MODE 5). The functions of the reactor mode switch interlocks that are not in effect, due to the testing in progress, are adequately compensated for by .the Special Operations LCO requirements.

The administrative controls are to be periodically verified to ensure that the operational requirements continue to be met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Chapter 7. 2. UFSAR, Section 15.4.1.1.

B 3.10.2*5 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI -UNIT 2 Single Control Rod Withdrawal-Hot Shutdown B 3.10.3 SR 3.10.3.1, SR 3.10.3.2, and SR 3.10.3.3 The other LCOs made applicable in this Special Operations LCD are required to have their Surveillances met to establish that this Special Operations LCD is being met. If the local array of control rods is inserted and disarmed (electrically or hydraulically) while the scram function for the withdrawn rod is not available, periodic verification in accordance with SR 3.10.3.2 is required to preclude the possibility of criticality.

SR 3.10.3.2 has been modified by a Note, which clarifies that this SR is not required to be met if SR 3.10.3.1 is satisfied for LCD 3.10.3.d.1 requirements, since SR 3.10.3.2 demonstrates that the alternative LCD 3.10.3.d.2 requirements are satisfied.

Also, SR 3.10.3.3 verifies that all control rods other than the control rod being withdrawn are fully inserted.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.4.1.1.

B 3.10.3-5 Revision 64 ii J *l :i 'j : *, .\ I ' BASES Single Control Rod Withdrawal-Cold Shutdown B 3.10.4 ACTIONS (continued)

SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 B.l, B.2.1, and B.2.2 If one or more of the requirements of this Special Operations LCO are not met with the aff.ected control rod not insertable, withdrawal of the control rod and removal of the associated CRD must be immediately suspended.

If the CRD has been removed, such that the control rod is not insertable, the Required Actions require the most expeditious action be taken to either initiate action to restore the CRD and insert its control rod, or initiate action to restore compliance with this Special Operations LCO. SR 3.10.4.1, SR 3.10.4.2, SR 3.10.4.3, and SR 3.10.4.4 The other LCOs made applicable by this Special Operations LCO are required to have their associated surveillances met to establish that this Special Operations LCO is being met. If the local array of control rods is inserted and disarmed (electrically or hydraulically) while the scram function for the withdrawn rod is not available, periodic verification is required to ensure that the possibility of criticality remains precluded.

Verification that all the other control rods are fully inserted is required to meet the SOM requirements.

Verification that a control rod withdrawal block has been inserted ensures that no other control rods can be inadvertently withdrawn under conditions when position indication instrumentation is inoperable for the affected control rod. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.10.4.2 and SR 3.10.4.4 have been modified by Notes, which clarify that these SRs are not required to be met if the alternative requirements demonstrated by SR.3.10.4.1 are satisfied.

1. UFSAR, Section 15.4.1.1.

B 3.10.4-5 Revision 64 BASES SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 ' I Single CRD Removal-Refueling B 3.10.5 SR 3.10.5.1, SR 3.10.5.2, SR 3.10.5.3, SR 3.10.5.4, and SR 3.10.5.5

Verification that all the control rods, other than the control rod withdrawn for the removal of the associated CRD, are fully inserted is required to ensure the SOM is within limits. Verification that the local five by five array of control rods, other than the control rod withdrawn for removal of the associated CRD, is inserted and disarmed (electrically or hydraulically), while the scram function for the withdrawn rod is not available, is required to ensure that the possibility of criticality remains precluded.

The Surveillance for LCO 3.1.1, which is made applicable by this Special Operations LCO, is required in order to establish that this Special Operations LCO is being met. Verification that a control rod withdrawal block has been inserted and that no other CORE ALTERATIONS are being made is required to ensure the assumptions of the safety analysis are satisfied under conditions when position indication instrumentation is inoperable for the withdrawn control rod. . Periodic verification of the administrative controls established by this Special Operations LCO is prudent to preclude the possibility of an inadvertent criticality.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.4.1.1.

B 3.10.5*5 Revision 64 0 BASES ACTIONS SURVEILLANCE REQUIREMENTS REFERENCES FERMI

UNIT 2 Multiple Control Rod Withdrawal-Refueling B 3.10.6 A.1, A.2, A.3.1, and A.3.2 If one or more of the requirements of this Special Operations LCD are not met, the immediate implementation of these Required Actions restores operation consistent with the normal requirements for refueling (i.e., all control rods inserted in core cells containing one or more fuel assemblies) or with the exceptions granted by this Special Operations LCD. An additional conservative requirement is imposed to suspend loading fuel assemblies.

The Completion Times for Required Action A.1, Required Action A.2, Required Action A.3.1, and Required Action A.3.2 are intended to require that these Required Actions be implemented in a very short time and carried through in an expeditious manner to either initiate action to restore the affected CRDs and insert their control rods, or initiate action to restore compliance with this Special Operations LCO.

SR 3.10.6.1 and SR 3.10.6.2 Periodic verification of the administrative controls established by this Special Operations LCD is prudent to preclude the possibility of an inadvertent criticality.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 1. UFSAR, Section 15.4.1.1.

B 3.10.6*3 Revision 64

' *' . I BASES SOM Test-Refueling B 3.10.7 SURVEILLANCE REQUIREMENTS (continued)

FERMI

UNIT 2 verification (i.e., SR 3.10.7.3) must be performed during control rod movement to prevent deviations from the specified sequence.

These surveillances provide adequate assurance that the specified test sequence is being followed.

SR 3.10. 7.4 Periodic verification that no CORE ALTERATIONS are in progress will ensure that the reactor is operated within the bounds of the safety analysis.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.10. 7.5 Coupling verification is performed to ensure the control rod is connected to the control rod drive mechanism and will perform its intended function when necessary.

The verification is required to be performed any time a control rod is withdrawn to the "full-out" notch position, and prior to withdrawing it for the purpose of performing this Special Operation after work on the control rod or CRD System that could affect coupling.

This Frequency is acceptable, considering the low probability that a control rod will become uncoupled when it is not being moved as well as . operating experience related to uncoupling events. SR 3.10. 7.6 CRD charging water header pressure verification is performed to ensure the motive force is available to scram the control rods in the event of a scram signal. A minimum accumulator pressure is also specified (in LCO 3.9.5), below which the capability of the accumulator to perform its intended function becomes degraded and the accumulator is considered inoperable.

The minimum charging water header pressure of 940 psig is well below the expected pressure of 1100 psig. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program . B 3.10.7*6 Revision 64 ENCLOSURE 5 TO NRC-16-0034 Summary of Excessive Detail Removed from the Fermi 2 UFSAR Enclosure 5 to NRC-16-0034 Page 1 Summary Report of Excessive Detail Removal The following is a summary report of excessive detail that has been removed in Revision 20 to the Fermi 2 UFSAR. These changes are consistent with Nuclear Energy Institute (NEI) 98-03, "Guidelines for Updating Final Safety Analysis Reports", Revision 1, June 1999, as endorsed by the NRC. The Fermi 2 UFSAR continues to adequately describe the design bases, plant safety analyses, and design and operation of structures, systems, and components (SSCs). LCRNo. Excessive Detail Removed Basis for Removal 12-021-UFS Deleted the specific numerical The UFSAR retains the results for evaporation, drift, description of the analysis leakage, and emergency methodology (including loss equipment cooling water terms) and the conclusion that (EECW) makeup in UFSAR the ultimate heat sink system Section 9.2.5.3.3.

capacity is adequate.

The specific numerical values of the loss terms are not required.

ENCLOSURE 6 TO NRC-16-0034 10 CFR 72.48 Evaluation Summary Report Enclosure 6 to NRC-16-0034 Page 1 72.48 EVALUATION

SUMMARY

There were no 10 CFR 72.48 evaluations performed since the previous report submitted with UFSAR Revision 19.

ML16165A441

Contents

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Reference:

Subject:

Enclosures:

SUMMARY

SUMMARY

6.3 References

SUMMARY

SUMMARY

2.4 REFERENCES

2.2 REFERENCES

2.4 REFERENCES

2.5 REFERENCES

2.5 REFERENCES

3.5 REFERENCES

6.3 REFERENCES

8.2 REFERENCES

8.4 BACKGROUND

2.2 REFERENCES

SUMMARY

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ML16165A441

Text

Reference:

Subject:

Enclosures:

SUMMARY

SUMMARY

6.3 References

SUMMARY

SUMMARY

2.4 REFERENCES

2.2 REFERENCES

2.4 REFERENCES

2.5 REFERENCES

2.5 REFERENCES

3.5 REFERENCES

6.3 REFERENCES

8.2 REFERENCES

8.4 BACKGROUND

2.2 REFERENCES

SUMMARY

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