Text

Issuance of Amendment Revision to Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF 542, Revision 2, Reactor Pressure Vessel Water Inventory Control (CAC No. MG0208; EPID L-2017-LLA-0282)
	ML18247A452
Person / Time
Site:	Fermi
Issue date:	09/17/2018
From:	Sujata Goetz; Plant Licensing Branch III
To:	Polson K; DTE Electric Company
	Goetz S, 415-8004
References
	CAC MG0208, EPID L-2017-LLA-0282
	Download: ML18247A452 (86)
	v • d • e

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

SUBJECT:

FERMI 2 - ISSUANCE OF AMENDMENT RE: REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NO. MG0208; EPID L-2017-LLA-0282)

Dear Mr. Polson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed amendment No. 211 to Renewed Facility Operating License No. NPF-43 for Fermi 2. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated August 31, 2017, as supplemented by letters dated April 4, May 17, June 27, and August 7, 2018.

This amendment replaces existing TSs requirements related to "operations with a potential for draining the reactor vessel" with new requirements on reactor pressure vessel water inventory control to protect Safety Limit 2.1.1.3, which requires the reactor vessel water level to be greater than the top of active irradiated fuel.

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

Sincerely, ed:iZ Plant Li nsing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 211 to NPF-43

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 Renewed License No. NPF-43

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by DTE Electric Company (DTE, the licensee),

dated August 31, 2017, as supplemented by letters dated April 4, May 17, June 27, and August 7, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act}, and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-43 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

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

FOR THE NUCLEAR REGULATORY COMMISSION OJ ~- v .....-----

David J ..Wrona, hief Plant Licensing ranch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-43 and Technical Specifications Date of Issuance: Sep tern be r 1 7, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 211 RENEWED FACILITY OPERATING LICENSE NO. NPF-43 FERMI 2 DOCKET NO. 50-341 Replace the following pages of the Renewed Facility Operating License No. NPF-43 and Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. NPF 43 REMOVE INSERT Technical Specifications REMOVE INSERT REMOVE INSERT i 3.5-10 3.5-10 ii ii 3.5-11 3.5-11 iii iii 3.5-12 3.5-12 1.1-3 1.1-3 3.6-13 3.6-13 1.1-3a 3.6-40 3.6-40 1.1-3b 3.6-41 3.6-41 3.3-35 3.3-35 3.6-43 3.6-43 3.3-36 3.3-36 3.6-45 3.6-45 3.3-41 3.3-41 3.6-47 3.6-47 3.3-42 3.3-42 3.6-48 3.6-48 3.3-49a 3.6-49 3.6-49 3.3-49b 3.7-6 3.7-6 3.3-49c 3.7-7 3.7-7 3.3-52 3.3-52 3.7-8 3.7-8 3.3-58 3.3-58 3.7-11 3.7-11 3.3-62 3.3-62 3.7-12 3.7-12 3.3-70 3.3-70 3.7-13 3.7-13 3.5-1 3.5-1 3.8-11 3.8-11 3.5-8 3.5-8 3.8-12 3.8-12 3.5-9 3.5-9 3.8-20 3.8-20 3.5-9a 3.8-29 3.8-29 3.5-9b

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 211, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions DTE Electric Company shall abide by the agreements and interpretations between it and the Department of Justice relating to Article I, Paragraph 3 of the Electric Power Pool Agreement between DTE Electric Company and Consumers Power Company as specified in a letter from The Detroit Edison Company to the Director of Regulation, dated August 13, 1971, and the letter from Richard W. McLaren, Assistant Attorney General, Antitrust Division, U.S. Department of Justice, to Bertram H. Schur, Associate General Counsel, Atomic Energy Commission, dated August 16, 1971.

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

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

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

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

Renewed License No. NPF-43 Amendment No. 211

TABLE OF CONTENTS

1. 0 USE AND APPLICATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-1 1.1 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-1

1. 2 Logical Connectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. 2-1

1. 3 Completion Times . . . . . * . . . . * . * . . * . . * . * . . . . . . . . . . . . . * * . . . . 1. 3 -1 1.4 Frequency 1.4-1 2.0 SAFETY LIMITS (SLs) . . . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . . * . . . 2.0-1 2.1 SLs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

0 -1 2.2 SL Violations ...........*...*.*.*.**.................... 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .....*... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ...............*.. 3.0-4 3.1 REACTIVITY CONTROL SYSTEMS *.*........................... 3.1-1 3 .1.1 SHUTDOWN MARGIN ( SDM) . . . . . . . . . . . . . . . . . . * . . . . . . . . . . * . 3 . 1-1 3 .1.2 Reactivity Anomalies . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . .

3.1-5 3 .1.3 Control Rod OPERABILITY *..*....................*.... 3.1-7 3 .1.4 Control Rod Scram Times . . . . . . . . . . . . . . . . * * . * . . . . . . . . . 3. 1. 12 3 .1. 5 Control Rod Scram Accumulators .*.*..............*... 3.1-15 3 .1. 6 Rod Pattern Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1-18 3 .1. 7 Standby Liquid Control (SLC) System ...*...........*. 3.1-20 3 .1. 8 Scram Discharge Volume (SDV) Vent and Drain Valves .. 3.1-24 3.2 POWER DISTRIBUTION LIMITS ..*.....................*...... 3.2-1 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.2-1 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) . . . . . . . . . . . . . . . . . 3.2-2 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) *.............*... 3.2-4 3.3 INSTRUMENTATION 3.3-1 3.3.1.1 Reactor Protection System (RPS) Instrumentation ..... 3.3-1 3.3.1.2 Source Range Monitor (SRM) Instrumentation ....*..... 3.3-11 3.3.2.1 Control Rod Block Instrumentation ......*............ 3.3-17 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrumentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 3-22 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation ...... 3.3-24 3.3.3.2 Remote Shutdown System . . . . . . . . . . . . . . . . . . . . . . . . . . . . * . 3.3-28 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation . . . . . . . . . . . . . . 3.3-31 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation 3.3-34 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation . . . . . . . . . . . . * . . . . . . . . . . . . . . . . . . * . . . 3. 3-46 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.3-49a 3.3.6.1 Primary Containment Isolation Instrumentation ....... 3.3-50 3.3.6.2 Secondary Containment Isolation Instrumentation ...*. 3.3-59 3.3.6.3 Low-Low Set (LLS) Instrumentation *.................* 3.3-63 (continued)

FERMI - UNIT 2 i Amendment No. 34, 211

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.7.1 Control Room Emergency Filtration (CREF)

System Instrumentation .......*.....*.....*.....*... 3.3-67 3.3.8.1 Loss of Power (LOP) Instrumentation . . . . . . . . . . . . . . . . . . . . . 3. 3-71 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . . . . 3.3-74 3.4 REACTOR COOLANT SYSTEM (RCS) ...*........*.....*.....*...... 3.4-1 3.4.1 Recirculation Loops Operating . . . * . . . . . . . . . . . . . . . . . . . . . . . 3.4-1 3.4.2 Jet Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.4-5 3.4.3 Safety Relief Valves (SRVs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.4-7 3.4.4 RCS Operational LEAKAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 4- 9 3.4.5 RCS Pressure Isolation Valve (PIV) Leakage .....*........ 3.4-11 3.4.6 RCS Leakage Detection Instrumentation . . . . . . . . . . . . . . . . . . . 3. 4-13 3.4.7 RCS Specific Activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.4-16 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown . . . . . . . * . . . . . . . . . . . . . * . . . . . . . . . . 3. 4-18 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown .......*.....*.......*....*.... 3.4-21 3.4.10 RCS Pressure and Temperature (P/T) Limits ........*...... 3.4-23 3.4.11 Reactor Steam Dome Pressure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.4-29 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM .. 3.5-1 3.5.1 ECCS-Operating . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . 3.5-1 3.5.2 RPV Water Inventory Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.5-8 3.5.3 RCIC System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . . 3.5-12 3.6 CONTAINMENT SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 6-1 3.6.1.1 Primary Containment * . . . . . . . . . . . . . * . . . . . * . . . . . . . . . . . . . . . . 3. 6 -1 3.6.1.2 Primary Containment Air Lock . . . . . . . . . . . . . . . . . . . . * . . . . . . . 3.6-3 3.6.1.3 Primary Containment Isolation Valves (PCIVs) ............ 3.6-7 3.6.1.4 Primary Containment Pressure . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 6-18 3.6.1.5 Drywell Air Temperature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.6-19 3.6.1.6 Low-Low Set (LLS) Valves .*........*.....*.....*......... 3. 6-20 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 6-22 3.6.1.8 Suppression-Chamber-to-Drywell Vacuum Breakers .......... 3.6-25 3.6.1.9 Deleted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3. 6-27 3.6.2.1 Suppression Pool Average Temperature . . . . . . . . . . . . . . . . . . . . 3.6-29 3.6.2.2 Suppression Pool Water Level . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.6-32 (continued)

FERMI - UNIT 2 ii Amendment No. 34-, ~ ' 211

TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling .................................*...*...... , 3.6-3 3 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray ............................................... 3.6-35 3.6.3.1 Primary Containment Oxygen Concentration ................ 3.6-39 3.6.4.1 Secondary Containment ................................... 3.6-40 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) ......... 3.6-43 3.6.4.3 Standby Gas Treatment (SGT) System ...................... 3.6-47 3.7 PLANT SYSTEMS ........................................... 3.7-1 3.7.1 Residual Heat Removal Service Water (RHRSW) System ...*.. 3.7-1 3.7.2 Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS) ........................ 3.7-3 3.7.3 Control Room Emergency Filtration (CREF) System ......... 3.7-6 3.7.4 Control Center Air Conditioning (AC)System .............. 3.7-11 3.7.5 Main Condenser Offgas .................................. , 3.7-14 3.7.6 The Main Turbine Bypass System and Moisture Separator Reheater .*......*...*.*......*... 3.7-16 3.7.7 Spent Fuel Storage Pool Water Level .................... , 3.7-18 3.7.8 Emergency Diesel Generator Service Water (EDGSW)

System .............................................. 3.7-19 3.8 ELECTRICAL POWER SYSTEMS ...............................*.* 3.8-1 3.8.1 AC Sources-Operating .................................. , 3.8-1 3.8.2 AC Sources-Shutdown .................................... 3.8-10 3.8.3 Diesel Fuel Oil, and Starting Air ....................... 3.8-13 3.8.4 DC Sources-Operating ...................*................ 3.8-16 3.8.5 DC Sources-Shutdown .................................... 3.8-19 3.8.6 Battery Cell Parameters ................................ , 3.8-22 3.8.7 Distribution Systems-Operating ........................ , 3.8-26 3.8.8 Distribution Systems-Shutdown ......................... , 3.8-28 3.9 REFUELING OPERATIONS ...............................*...*.* 3.9-1 3.9.1 Refueling Equipment Interlocks .......................... 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock ................... 3.9-3 3.9.3 Control Rod Position .................................... 3.9-5 3.9.4 Control Rod Position Indication .......................... 3.9-6 3.9.5 Control Rod OPERABILITY-Refueling ...................... 3.9-8 3.9.6 Reactor Pressure Vessel (RPV) Water Level ............... 3.9-9 3.9.7 Residual Heat Removal (RHR)-High Water Level ........... 3.9-10 3.9.8 Residual Heat Removal (RHR)-Low Water Level ............ 3.9-12

{continued)

FERMI - UNIT 2 iii Amendment No. 34, *5-9, 211

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and

, isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g .. seismic event. loss of normal power. single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths; (continued)

FERMI - UNIT 2 1.1-3 Amendment No. -lJ4. 2-07, 211

Definitions 1.1 1.1 Definitions (continued)

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task.

who in continuous communication with the control room. is stationed at the controls. and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated. and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e .. the valves travel to their required positions. pump discharge pressures reach their required values. etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential.

overlapping, or total steps so that the entire response time is measured.

(continued)

FERMI - UNIT 2 1. l-3a Amendment No. 211

Definitions 1.1 1.1 Definitions (continued)

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued)

FERMI - UNIT 2 l.1-3b Amendment No. 211

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by B.l --------NOTE ----- ---

Required Action A.l Only applicable for and referenced in Funct i ans 1. a, l.b, Table 3 .3. 5.1-1. 2.a, 2.b, 2.d, and 2.g.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions AND B.2 ---------NOTE ------ --

Only applicable for Functions 3.a and 3.b .

Declare High Pressure 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Coolant Injection discovery of (HPCI) System loss of HPCI inoperable. initiation capability AND B.3 Place channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

(continued)

FERMI - UNIT 2 3.3-35 Amendment No.~. 211

ECCS Instrumentation 3.3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. As required by C.l --------NOTE -- ------

Required Action A.l Only applicable for and referenced in Functions 1.c. 2.c.

Table 3.3.5.1-1. 2.e. and 2.f.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions AND C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

(continued)

FERMI - UNIT 2 3.3-36 Amendment No. +/-J4. 211

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A. l REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Vessel Water 1.2.3 B SR 3.3.5.1.1 ~ 24.8 inches Level - Low Low Low. SR 3.3.5.1.2 Level 1 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. Drywell Pressure-High 1.2.3 B SR 3.3.5.1.1 s; 1.88 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

c. Reactor Steam Dome 1.2.3 4 C SR 3.3.5.1.1 ~ 441 psig Pressure - Low SR 3.3.5.1.2 (Injection Permissive) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Manual Initiation 1.2.3 C SR 3.3.5.1.6 NA (continued)

(a) Not Used.

(b) Also required to initiate the associated emergency diesel generator (EDG).

(c) Individual component controls.

FERMI - UNIT 2 3.3-41 Amendment No. +/-d4, 211

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A. l REQUIREMENTS VALUE

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Vessel Water 1.2.3 4 B SR 3.3.5.1.1 ~ 24.8 inches Level - Low Low Low. SR 3.3.5.1.2 Level 1 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

b. Drywe 11 Pressure - High 1.2.3 4 B SR 3.3.5.1.1 ~ 1.88 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 C. Reactor Steam Dome 1.2.3 4 C SR 3.3.5.1.1 ~ 441 psig Pressure - Low SR 3.3.5.1.2 (Injection Permissive) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

d. Reactor Vessel Water 1.2.3 4 B SR 3.3.5.1.1 ~ 103.8 inches Level - Low Low, Level SR 3.3.5.1.2 2 (Loop Select Logic) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

e. Reactor Steam Dome 1.2.3 4 C SR 3.3.5.1.1 ~ 886 psig Pressure - Low (Break SR 3.3.5.1.2 Detection Logic) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

f. Riser Differential 1.2.3 4 C SR 3.3.5.1.1 ~ 0.927 psid Pressure- High (Break SR 3.3.5.1.2 Detection) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

g. Recirculation Pump 1.2.3 4 per pump B SR 3.3.5.1.1 ~ 1. 927 psid Differential Pressure - SR 3.3.5.1.2 High (Break Detection) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5

h. Manual Initiation 1.2.3 2\CJ C SR 3.3.5.1.6 NA (continued)

(c) Individual component controls.

FERMI - UNIT 2 3.3-42 Amendment No. +/-J4, 211

RPV Water Inventory Control Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.l Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by B.l Declare associated Immediately Required Action A.1 penetration flow and referenced in path(s) incapable of Table 3.3.5.3-1. automatic isolation.

-AND B.2 Calculate DRAIN TIME. Immediately C. As required by C.1 Place channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.l trip.

and referenced in Table 3.3.5.3-1.

(continued)

FERMI - UNIT 2 3.3-49a Amendment No. 211

RPV Water Inventory Control Instrumentation 3.3.5.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by D.l Declare associated Immediately Required Action A.l low pressure ECCS and referenced in injection/spray Table 3.3.5.3-1. subsystem inoperable.

OR Required Action and associated Completion Time of Condition C not met.

SURVEILLANCE REQUIREMENTS

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

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

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.3 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program FERMI - UNIT 2 3.3-49b Amendment No. 211

RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3*1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Steam Dome 4,5 4(a) C SR 3.3.5.3.1 ~ 441 psig Pressure - Low SR 3.3.5.3.2 (Injection Permissive)

b. Manual Initiation 4,5 1 per D SR 3.3.5.3.3 NA subsystem (a). (c)

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam Dome 4,5 4Ca) C SR 3.3.5.3.1 ~ 441 psig Pressure - Low SR 3.3.5.3.2 (Injection Permissive)

b. Manual Initiation 4,5 1 per D SR 3.3.5.3.3 NA subsystem (a), (c)

3. RHR System Isolation

a. Reactor Vessel Water (b) 2 in one B SR 3.3.5.3.1 ~ 171.9 inches Level - Low. Level 3 trip SR 3.3.5.3.2 system

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water (b) 2 in one B SR 3.3.5.3.1 ~ 103.B inches Level - Low Low, Level trip SR 3.3.5.3.2 2 system (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Individual component controls.

FERMI - UNIT 2 3.3-49c Amendment No. 211

Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. As required by H.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Required Action C.l and referenced in -AND Table 3.3.6.1-1.

H.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

-OR Required Action and associated Completion Time for Condition F or G not met.

I. As required by I.1 Declare associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action C.l standby liquid and referenced in control subsystem Table 3.3.6.1-1. (SLC) inoperable.

-OR I.2 Isolate the Reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Water Cleanup System.

J. As required by J.l Initiate action to Immediately Required Action C.l restore channel to and referenced in OPERABLE status.

Table 3.3.6.1-1.

FERMI - UNIT 2 3.3-52 Amendment No. +/-J4. 211

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 4 of 5)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.l REQUIREMENTS VALUE

5. Reactor Water Cleanup (RWCU) System Isolation

a. Differential 1.2.3 1 F SR 3.3.6.1.1 ~ 63.4 gpm Flow - High SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Area Temperature - 1.2.3 1 per F SR 3.3.6.1.1 ~ 183°F High area SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 C. Area Ventilation 1,2,3 (d) F SR 3.3.6.1.1 ~ 53°F Differential SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.4 SR 3.3.6.1.5

d. SLC System Initiation 1.2 2(b) I SR 3.3.6.1.5 NA

e. Reactor Vessel Water 1,2,3 2 F SR 3.3.6.1.1 ~ 103.8 inches Level - Low Low. SR 3.3.6.1.2 Level 2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

f. Manual Initiation 1,2,3 1 per G SR 3.3.6.1.6 NA valve

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1,2,3 1 F SR 3.3.6.1.1 ~ 95.5 psig Pressure - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Reactor Vessel Water 3 2 J SR 3.3.6.1.1 ~ 171.9 inches Level - Low, Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 C. Manual Initiation 1.2.3 1 ~er G SR 3. 3.6.1.6 NA va ve (continued)

(b) SLC System Initiation only inputs into one of the two trip systems.

(c) Not Used.

(d) For Function 5.c. Reactor Water Cleanup (RWCU) System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room.

FERMI - UNIT 2 3.3-58 Amendment No. +/-64, ~ +/-89, 211

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)

Secondary Containment Isolation Instrumentation APPLICABLE MOOES OR REQUIRED OTHER CHANNELS SPECIFIED PER SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS TRIP SYSTEM REQUIREMENTS VALUE

1. Reactor Vessel Water 1.2.3 2 SR 3.3.6.2.1 ;,: 103.8 inches Level - Low Low. Level 2 SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5

2. Drywell Pressure-High 1,2,3 2 SR 3.3.6.2.1 ~ 1.88 psig SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.4 SR 3.3.6.2.5

3. Fuel Pool Ventilation 1.2.3, 2 SR 3.3.6.2.1 ~ 6 mR/hr Exhaust Radiation-High Ca) SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.5

4. Manual Initiation 1.2.3, 1 SR 3.3.6.2.5 NA (a)

(a) During movement of recently irradiated fuel assemblies in secondary containment.

FERMI - UNIT 2 3.3-62 Amendment No. +/-J4, +/-44. 211

CREF System Instrumentation 3.3.7.1 Table 3.3.7.1*1 (page 1 of 1)

Control Room Emergency Filtration System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION A.1 REQUIREMENTS VALUE

1. Reactor Vessel Water 1.2.3 2 B SR 3.3.7.1.1 ~ 103.8 inches Level - Low Low. Level 2 SR 3.3.7.1.3 SR 3.3.7.1.4 SR 3.3.7.1.5 SR 3.3. 7.1.6

2. Drywe11 Pressure - High 1.2.3 2 B SR 3.3.7.1.1 s; 1.88 psig SR 3.3.7.1.3 SR 3.3.7.1.4 SR 3.3.7.1.5 SR 3.3. 7.1.6

3. Fuel Pool Ventilation 1.2,3, 2 B SR 3.3. 7.1.1 s; 6 mR/hr Exhaust Radiation - High SR 3.3. 7.1.3 (a) SR 3.3.7.1.5 SR 3.3.7.1.6

4. Control Center Normal 1,2,3. 1 C SR 3.3.7 .1.1 s 5 mR/hr Makeup Air Radiation- SR 3.3.7.1.2 High Ca) SR 3.3.7.1.5 (a) During movement of recently irradiated fuel assemblies in the secondary containment.

FERMI

UNIT 2 3.3-70 Amendment No. -1J4, 144, 211

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM

3. 5.1 ECCS-Operati ng LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure~ 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.l Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. One LPCI pump in both B.1 Restore both LPCI 7 days LPCI subsystems pumps to OPERABLE inoperable. status.

C. One CSS subsystem C.1 Restore CSS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

-AND -OR One LPCI subsystem C.2 Restore LPCI 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. subsystem to OPERABLE status.

(continued)

FERMI - UNIT 2 3.5-1 Amendment No. !J4, ~ . 211

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCD 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.l Initiate action to Immediately associated Completion establish a method of Time of Condition A water injection not met. capable of operating without offsite electrical power.

(continued)

FERMI - UNIT 2 3.5-8 Amendment No. !J4., 211

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

FERMI - UNIT 2 3.5-9 Amendment No.~.~. 211

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME D. DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.l --------NOTE --------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power .

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level> TAF for

~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to Immediately establish secondary containment boundary.

AND D.3 Initiate action to Immediately isolate secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to Immediately verify one standby gas treatment subsystem is capable of being placed in operation.

FERMI - UNIT 2 3.5-9a Amendment No. 211

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME E. Required Action and E.l Initiate action to Immediately associated Completion restore DRAIN TIME to Time of Condition C or ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

D not met.

OR DRAIN TIME< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant In accordance injection (LPCI) subsystem. the suppression with the pool water level is~ -66 inches. Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) In accordance subsystem. the: with the Surveillance

a. Suppression pool water level is Frequency

~ -66 inches: or Control Program

b. Condensate storage tank water level is

~ 19 ft.

(continued)

FERMI

UNIT 2 3.5-9b Amendment No. 211

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify correct voltage and breaker In accordance alignment to the LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.2.5 Verify, for the required ECCS In accordance injection/spray subsystem, locations with the susceptible to gas accumulation are Surveillance sufficiently filled with water. Frequency Control Program SR 3.5.2.6 -------- -----------NOTE - -------------------

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

Verify, for the required ECCS In accordance injection/spray subsystem, each manual, with the power operated, and automatic valve in the Surveillance flow path. that is not locked. sealed, or Frequency otherwise secured in position, is in the Control Program correct position.

SR 3.5.2.7 Operate the required ECCS injection/spray In accordance subsystem through the recirculation line with the for~ 10 minutes. Surveillance Frequency Control Program SR 3.5.2.8 Verify each valve credited for In accordance automatically isolating a penetration flow with the path actuates to the isolation position on Surveillance an actual or simulated isolation signal. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-10 Amendment No.~. 2-01, ~ . 211

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.9 -------------------NOTE --------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance subsystem can be manually operated. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.5-11 Amendment No. lJ4 +/-84, ~ . ~ .

~. 211 .

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.l Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

B. Required Action and B.l --------NOTE --------

associated Completion LCO 3.0.4.a is not Time not met. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FERMI - UNIT 2 3.5-12 Amendment No. -!J4, ~ 194, 211

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A. -AND B, C, or D not met in MODE 1. 2. or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Required Action and F.l Initiate action to Immediately associated Completion restore valve(s) to Time of Condition A, OPERABLE status.

B, C. or D not met for RHR-SDC PCIV(s) required to be OPERABLE during MODE 4 or 5.

FERMI - UNIT 2 3.6-13 Amendment No. !J4., 211

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACT! ON COMPLETION TIME A. Secondary Containment A.l Restore railroad bay 7 days inoperable due to one door to OPERABLE railroad bay access status.

door inoperable.

B. Secondary containment B.l Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, containment to 2, or 3 for reasons OPERABLE status.

other than Condition A.

C. Required Action and C.l --------NOTE --------

associated Completion LCO 3.0.4.a is not Time of Condition A or applicable when B not met. entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

FERMI - UNIT 2 3.6-40 Amendment No. !34, 144 +/-94, 211

Secondary Containment 3.6.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Secondary containment D.l --------NOTE ---------

inoperable during LCO 3.0.3 is not movement of recently applicable.

irradiated fuel assemblies in the secondary containment. Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 . 6 . 4 . 1. 1 Verify secondary containment vacuum is In accordance

~ 0.125 inch of vacuum water gauge. with the Surveillance Frequency Control Program (continued)

FERMI - UNIT 2 3.6-41 Amendment No.~. -144, ~ . 211

SCIVs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.l Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths penetration flow path with one SCIV by use of at least inoperable. one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND (continued)

FERMI - UNIT 2 3.6-43 Amendment No.~. +/-44, 211

SCIVs 3.6.4.2 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME D. Required Action and D.l --------NOTE -- -------

associated Completion LCO 3.0.3 is not Time of Condition A applicable.

or B not met during movement of recently irradiated fue 1 Suspend movement of Immediately assemblies in the recently irradiated secondary containment. fuel assemblies in the secondary containment.

FERMI - UNIT 2 3.6-45 Amendment No. 134, 144, 211

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1. 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACT! ON COMPLETION TIME A. One SGT subsystem A.I Restore SGT subsystem 7 days inoperable. to OPERABLE status.

B. Required Action and B.l --------NOTE --------

associated Completion LCO 3.0.4.a is not Time of Condition A applicable when not met in MODE 1. 2. entering MODE 3.

or 3. --------------------

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

FERMI - UNIT 2 3.6-47 Amendment No. 1J4, -144 +/-94, 211

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and ------------NOTE ------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A ..........................................................

not met during movement of recently C.1 Place OPERABLE SGT Immediately irradiated fue 1 subsystem in assemblies in the operation.

secondary containment.

-OR C.2 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

D. Two SGT subsystems 0.1 --------NOTE --------

inoperable in MODE 1, LCO 3.0.4.a is not 2, or 3. applicable when entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

FERMI - UNIT 2 3.6-48 Amendment No.~.l44194, 211

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME E. Two SGT subsystems E. l --------NOTE ----- ----

inoperable during LCO 3.0.3 is not movement of recently applicable.

i rradi ated fue 1 assemblies in the secondary Suspend movement of Immediately containment. recently irradiated fuel assemblies in secondary containment.

FERMI - UNIT 2 3.6-49 Amendment No. -1J4. 144, 211

CREF System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Filtration (CREF) System LCO 3.7.3 The CREF System shall be OPERABLE.

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREF subsystem A.l Restore CREF 7 days inoperable for reasons subsystem to OPERABLE other than Condition status.

B.

B. One or more CREF B.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable CRE actions.

boundary in MODE 1, 2, or 3. -AND B.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

FERMI - UNIT 2 3. 7-6 Amendment No . ', -144, -l49, -182,

+/-94, 98, 211

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 ------- -NOTE --------

associated Completion LCO 3.0.4.a is not Time of Condition A or applicable when B not met in MODE 1, entering MODE 3.

2, or 3. .. ......................................

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. Required Action and ------------NOTE -------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A .. ------------ ---------- - - - - .. -

not met during movement of recently D.l Place OPERABLE CREF Immediately irradiated fue 1 subsystem in assemblies in the recirculation mode.

secondary containment.

-OR D.2 --------NOTE - -------

Not required for a CREF System or subsystem inoperable due to failure to provide the required filtration efficiency, or due to replacement of charcoal filtration media.

Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

(continued)

FERMI - UNIT 2 3. 7-7 Amendment No. '. !44. +/-49. !@,

198, 211

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME E. Two CREF subsystems or E.1 --------NOTE --------

a non-redundant LCO 3.0.4.a is not component or portion applicable when of the CREF System entering MODE 3.

inoperable in MODE 1. --------------------

2, or 3 for reasons other than Condition Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.

F. Two CREF subsystems or F.l --------NOTES ---- --- -

a non-redundant 1. LCO 3.0.3 is not component or portion applicable.

of the CREF System inoperable during 2. Not required for a movement of recently CREF System or irradiated fuel subsystem assemblies in the inoperable due to secondary containment. failure to provide the required

-OR filtration efficiency, or due One or more CREF to replacement of subsystems inoperable charcoal due to an inoperable filtration media.

CRE boundary during -------- - - - - - - - .. - - - -

movement of recently i rradi ated fuel Suspend movement of Immediately assemblies in the recently irradiated secondary containment. fuel assemblies in the secondary containment.

FERMI - UNIT 2 3. 7-8 Amendment No. H4. !44, !49, W, l-94. 98, 211

Control Center AC System 3.7.4 3.7 PL.ANT SYSTEMS 3.7.4 Control Center Air Conditioning (AC) System LCO 3.7.4 Two control center AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control center AC A.l Restore control 30 days subsystem inoperable. center AC subsystem to OPERABLE status.

B. Two control center AC 8.1 Verify control Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystems room area inoperable. temperature <90°F.

-AND 8.2 Restore one control 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months center AC subsystem to OPERABLE status.

C. Required Action and C.l --------NOTE -- -- ---

associated Completion LCO 3.0.4.a is not Time of Condition A applicable when or B not met in MODE entering MODE 3.

1, 2, or 3. -----------------* ..

Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FERMI - UNIT 2 3.7-11 Amendment No. 134, 144, 177 194, 211

Control Center AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and ----- ----- -NOTE --------- -----

associated Completion LCO 3.0.3 is not applicable Time of Condition A not met during movement of recently irradiated fue 1 D.l Place OPERABLE Immediately assemblies in the control center AC secondary containment. subsystem in operation.

OR D.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

(continued)

FERMI - UNIT 2 3.7-12 Amendment No. 134, 144, +/-/+, 211

Control Center AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.l -------NOTE ----- -----

associated Completion LCO 3.0.3 is not Time of Condition B applicable not met during movement of recently irradiated fue 1 Suspend movement of Immediately assemblies in the recently irradiated secondary containment. fuel assemblies in the secondary containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify the control room air temperature is In accordance

~ 95°F. with the Surveillance Frequency Control Program FERMI - UNIT 2 3.7-13 Amendment No. !J4, -144. l+l-. 201-,

211

AC Sources -Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND A.2.3 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

(continued)

FERMI - UNIT 2 3.8-11 Amendment No. -!J4, -144, 211

AC Sources -Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACT! ON COMPLETION TIME B. One or both required B.1 Suspend CORE Immediately EDGs inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

AND B.3 Initiate action to Immediately restore required EDGs to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------- --------- ---NOTE -------- --- ---------

The following SRs are not required to be performed: SR 3.8.1.2, SR 3.8.1.3, and SR 3.8.1.7 through SR 3.8.1.17.

For AC sources required to be OPERABLE In accordance SR 3.8.1.1 through SR 3.8.1.17, are with applicable applicable. SRs FERMI - UNIT 2 3.8-12 Amendment No. +/-J4, 144, 211

DC Sources -Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND A.2.3 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

FERMI - UNIT 2 3.8-20 Amendment No. +/-J4. -144, 211

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACT! ON COMPLETION TIME A. (continued) A.2.3 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystems to OPERABLE status.

AND A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and In accordance voltage to required AC and DC electrical with the power distribution subsystems. Surveillance Frequency Control Program FERMI - UNIT 2 3.8-29 Amendment No. +/-d4, 2-Gl-, 211

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 211 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION

By application dated August 31, 2017 (Reference 1), and supplemented by letters dated April 4 (Reference 2), May 17 (Reference 3), June 27 (Reference 4), and August 7, 2018 (Reference 5), DTE Electric Company (DTE, the licensee) requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF- 542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 6), for Fermi 2. The final safety evaluation (SE) for TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC, the Commission) on December 20, 2016 (Reference 7).

The proposed changes would replace existing technical specification (TS} requirements associated with "operations with a potential for draining the reactor vessel" (OPDRVs) with new and revised TSs providing alternative requirements for reactor pressure vessel (RPV) water inventory control (WIC). These alternative requirements would protect Safety Limit TS 2.1.1.3, which states "Reactor vessel water level shall be greater than the top of active irradiated fuel."

Additionally, a new definition, "DRAIN TIME," would be added to the Fermi 2 TSs, Section 1.1, "Definitions." Drain Time would establish requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for Modes 4 and 5 outage-related activities. Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system (ECCS) safety injection/spray systems during Modes 4 and 5 requires a properly calculated Drain Time.

The licensee has proposed several variations from the TS changes described in the applicable parts of TSTF-542, Revision 2, or the NRG-approved TSTF-542 SE. These are explained below in Section 2.2.5 and evaluated in Section 3.5 of this SE.

The supplements dated April 4, May 17, June 27, and August 7, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on November 7, 2017 (82 FR 51649).

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 System Description The boiling water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During operation in Mode 1 (Power Operation - Reactor Mode Switch in Run), Mode 2 (Startup - Reactor Mode Switch in Refuel 1 or Startup/Hot Standby), and Mode 3 (Hot Shutdown - Reactor Mode Switch in Shutdown and average reactor coolant temperature

> 200 degrees Fahrenheit (°F)), the TS for instrumentation and ECCS require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should level decrease below the preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss.

During operation in Modes 4 (Cold Shutdown 1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature s 200 °F), and 5 (Refueling 2 - Reactor Mode Switch in Shutdown or Refuel), the pressures and temperatures that could cause a LOCA are not present. During certain phases of refueling (Mode 5) a large volume of water is available above the RPV (i.e., the RPV head is removed, the water level is 2! 20 feet (ft) - 6 inches over the top of the RPV flange, and the spent fuel storage pool gates are removed).

The large volume of water available in and above the RPV (during much of the time when in Mode 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, typically at other times during a refueling outage, during Cold Shutdown (Mode 4) or Refueling (Mode 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities. There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV.

In comparison to Modes 1, 2, and 3, with typical high temperatures and pressures (especially in Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the potential sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decrease from potentially significant or unexpected drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less water replacement capability to maintain water above TAF.

To address the drain down potential during Modes 4 and 5, the current Fermi 2 TSs contain specifications that are applicable during an OPDRV, or require suspension of OPDRVs if certain equipment is inoperable. The term OPDRV is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed 1

With all reactor vessel head closure bolts fully tensioned.

2 One or more reactor vessel head closure bolts less than fully tensioned.

in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions and surveillance requirements (SRs) and deleting references to OPDRVs throughout the TSs.

2.2 Proposed TS Changes Section 2.2.1 below describes the proposed addition of a new definition, "DRAIN TIME" (evaluated below in Section 3.1 ).

Section 2.2.2 below describes: (1) the proposed revision to TS 3.3, "Instrumentation," (2) the proposed revision to TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation,"

(3) the proposed addition of new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including Table 3.3.5.3), and (4) the proposed revision to TS 3.3.6.1, "Primary Containment Isolation Instrumentation" (evaluation in Sections 3.2 and 3.4 of this SE).

Section 2.2.3 below describes the proposed revision to TS 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System," which includes the proposed revision to TS 3.5.2 "ECCS-Shutdown" (evaluation in Section 3.3 of this SE).

Section 2.2.4 below describes the proposed deletion of existing TS references to OPDRVs (evaluated below in Section 3.6).

Section 2.2.5 below describes Fermi 2 plant-specific variations to TSTF-542, Revision 2 (evaluated below in Section 3.5).

2.2.1 Addition of "DRAIN TIME" Definition The following definition of "DRAIN TIME" would be added to Section 1.1, "Definitions":

The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level

being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

2.2.2 TS 3.3, "Instrumentation" The following subsections describe the existing and proposed changes to the Fermi 2 TS, Section 3.3, "INSTRUMENTATION."

2.2.2.1 TS 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation" Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1 and C.1, which states:

Only applicable in MODES 1, 2, and 3.

As a result, the numbering for Note 2 would be removed with no change in the note.

For TS Table 3.3.5.1-1, the applicability in Modes 4 and 5 was proposed for deletion because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation."

Modes 4 and 5 applicability and associated requirements would be deleted for the following functions:

1. Core Spray System (a) Reactor Vessel Water Level - Low Low Low, Level 1 (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

( d) Manual Initiation

2. Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level - Low Low Low, Level 1 (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

(d) Reactor Vessel Water Level - Low Low, Level 2 (Loop Select Logic)

(e) Reactor Steam Dome Pressure - Low (Break Detection Logic)

{h} Manual Initiation Table 3.3.5.1-1 footnote (a), which states, "When the associated subsystem(s) of LCO

[limiting condition for operation] 3.5.2 are required to be OPERABLE," would be deleted and footnote (a) would not be used for this table and would be replaced with "Not Used."

2.2.2.2 New TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed new TS 3.3.5.3 would contain existing ECCS and Primary Containment Isolation instrumentation functions that would be relocated from TSs 3.3.5.1 and 3.3.6.1, as well as new TS requirements. The proposed new TS 3.3.5.3 is shown below:

3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Enter the Condition Immediately channels inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by 8.1 Declare associated Immediately Required Action A.1 penetration flow path( s) and referenced in incapable of automatic Table 3.3.5.3-1. isolation.

AND 8.2 Calculate DRAIN TIME. Immediately C. As required by C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 and referenced in Table 3.3.5.3-1.

D. As required by D.1 Declare associated low Immediately Required Action A.1 pressure ECCS and referenced in injection/spray subsystem Table 3.3.5.3-1. inoperable.

OR Required Action and associated Completion Time of Condition C not met.

SURVEILLANCE REQUIREMENTS

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

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

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control ProQram.

SR 3.3.5.3.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program.

SR 3.3.5.3.3 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control ProQram.

Table 3.3.5.3-1 (Page 1 of 1)

RPV W ater Inven tory Contro I Instrumen tat1on APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SURVEILLANCE SPECIFIED PER REQUIRED REQUIREMENTS CONDITIONS ACTION A.1 ALLOWABLE FUNCTION FUNCTION VALUE

1. Core Spray System 4,5 4 (a) C SR 3.3.5.3.1 ~ 441 psig

a. Reactor SR 3.3.5.3.2 Steam Dome Pressure -

Low 4,5 1 per subsystem D SR 3.3.5.3.3 NA (Injection (a), (c)

Permissive)

b. Manual Initiation

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor 4,5 4 (a) C SR 3.3.5.3.1 ~ 441 psig Steam SR 3.3.5.3.2 Dome Pressure - L ow (Injection Permissive) 4,5 1 per subsystem D SR 3.3.5.3.3 NA (a), (c)

b. Manual Initiation

3. RHR System Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.3.1 ~

Vessel Water system SR 3.3.5.3.2 171.9 inches Level - Low, Level3

4. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor (b) 2 in one trip B SR 3.3.5.3.1 Vessel Water system SR 3.3.5.3.2 ~

Level - Low 103.8 inch Low, Level 2 es (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Individual component controls.

2.2.2.3 TS 3.3.6.1, "Primary Containment Isolation Instrumentation" In TS Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System Isolation, Reactor Vessel Water Level - Low, Level 3, the applicability in Modes 4 and 5 was proposed for deletion.

Also, footnote (c) to Table 3.3.6.1-1 was proposed to be deleted (replaced with "Not Used"),

as it is applicable only to Function 6.b during Modes 4 and 5. This function would be moved to the new TS Table 3.3.5.3-1, Function 3.a, as shown in Section 2.2.2.2 of this SE.

In TS LCO 3.3.6.1, Required Action J.2 was proposed for deletion since it was associated with the isolation of residual heat removal (RHR)/shutdown cooling (SOC) during Modes 4 and 5.

2.2.3 TS Section 3.5, "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System" The title of Fermi 2 TS Section 3.5 would be revised from "Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System" to "Emergency Core Cooling Systems (ECCS), RPV Water Inventory Control, and Reactor Core Isolation Cooling (RCIC)

System."

The title of Fermi 2 TS Section 3.5.2 would be revised from "ECCS - Shutdown" to "Reactor Pressure Vessel (RPV) Water Inventory Control." Also, TS 3.5.2 would be revised as follows:

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be;:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection capable Time of Condition A not of operating without offsite met. electrical power.

C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystem is capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D. 1--------------N()TE------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for o!: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to verify one Immediately standby gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore DRAIN Immediately associated Completion TIME too!: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

()R DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The proposed SRs for TS 3.5.2 are shown below:

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with the (LPCI) subsystem, the suppression pool water level Surveillance Frequency is ~ - 66 inches. Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the the: Surveillance Frequency

a. Suppression pool water level is ~ - 66 inches; or Control Program

b. Condensate storage tank water level is ~ 19 ft.

SR 3.5.2.4 Verify correct voltage and breaker alignment to the In accordance with the LPCI swing bus. Surveillance Frequency Control Program SR 3.5.2.5 Verify, for the required ECCS injection/spray In accordance with the subsystem, locations susceptible to gas Surveillance Frequency accumulation are sufficiently filler with water. Control Program SR 3.5.2.6 ------------------------N()TE------------------------------

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

Verify, for the required ECCS injection/spray In accordance with the subsystem, each manual, power operated, and Surveillance Frequency automatic valve in the flow path, that is not locked, Control Program sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.7 Operate the required ECCS injection/spray In accordance with the subsystem through the recirculation line for Surveillance Frequency

~ 10 minutes. Control Program SR 3.5.2.8 Verify each valve credited for automatically isolating In accordance with the a penetration flow path actuates to the isolation Surveillance Frequency position on an actual or simulated isolation signal. Control Program

SR 3.5.2.9 ---------------------l'J()l"E--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance with the actuated can be manually operated. Surveillance Frequency Control Program 2.2.4 Deletion of Reference to ()PDRVs In References 1, 2, 3, 4, and 5, the licensee proposed to revise current l"S requirements related to ()PDRVs (or terms related to ()PDRVs) with new requirements on RPV WIC that will protect l"S Safety Limit 2.1.1.3. l"o remain consistent with l"Sl"F 542, all references to the term ()PDRVs in the l"Ss would be deleted. l"he following table lists the l"S location of these references:

Fermi 2 LC() Location of OPDRVs Reference 3.3.6.1, Primary Containment Isolation l"able 3.3.6.1-1 footnote (c)

Instrumentation 3.3.6.2, Secondary Containment Isolation l"able 3.3.6.2-1 footnote (a)

Instrumentation 3.3.7.1, Control Room Emergency Filtration l"able 3.3.7.1-1 footnote (a)

(CREF) System Instrumentation 3.6.1.3, Primary Containment Isolation Required Action F Valves (PCIVs) 3.6.4.1, Secondary Containment Applicability, Condition D 3.6.4.2, Secondary Containment Isolation Applicability, Condition D Valves (SCIVs) 3.6.4.3, Standby Gas l"reatment (SGl") Applicability, Conditions C and E System 3.7.3, Control Room Emergency Filtration Applicability, Conditions D and F (CREF) System 3.7.4, Control Center Air Conditioning Applicability, Conditions D and E (AC) System 3.8.2, AC Sources - Shutdown Conditions A and 8 Required Actions A.2.4 and 8.4 are renumbered as A.2.3 and 8.3, respectively 3.8.5, DC Sources - Shutdown Condition A Required Action A.2.4 is renumbered as A.2.3 3.8.8, Distribution Systems - Shutdown Condition A Required Actions A.2.4 and A.2.5 are renumbered as A.2.3 and A.2.4, respectively

2.2.5 Fermi 2 Plant-Specific TSTF-542 Variations In References 1, 2, 3, 4, and 5, the licensee identified several Fermi 2 plant-specific TS variations from TSTF-542, Revision 2 (Reference 6), or the NRC-approved TSTF-542 SE (Reference 7). The licensee stated that these variations do not affect the applicability of TSTF-542 or the NRC staff's SE to the proposed license amendment. Section 3.5 of this SE includes the staff's evaluation of each of these technical variations.

2.2.5.1 Variation 1, SR 3.5.2.5 Note Fermi 2 SR 3.5.2.5 contains Note 1 regarding realignment to the LPCI mode from the decay heat removal mode, which is similar to the Note in the Standard Technical Specifications (STS) LCO 3.5.2. DTE proposed to delete Note 1, which applies only to SR 3.5.2.5, and insert a similar note that will apply the exception to the overall LCO for 3.5.2, to be consistent with the STSs.

2.2.5.2 Variation 2, CS and LPCI Pump Discharge Flow Low The proposed Fermi 2 TS 3.3.5.3, Table 3.3.5.3-1, does not include functions corresponding to STS Table 3.3.5.1-1, Function 1.d, "Core Spray Pump Discharge Flow - Low (Bypass),"

and Function 2.g, "Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass),"

since the Fermi 2 TS does not currently contain these functions in TS Table 3.3.5.1-1.

2.2.5.3 Variation 3, LPCI Loop Select Logic and Break Detection Logic Fermi 2 TS Table 3.3.5.1-1, Function 2.d, "Reactor Vessel Water Level - Low Low, Level 2 (Loop Select Logic)," and Function 2.e, "Reactor Steam Dome Pressure - Low (Break Detection Logic)," are not included in the STS Table 3.3.5.1-1. Functions 2.d and 2.e automatically enable and initiate LPCI loop select logic. Loop select logic is initiated on the decreasing RPV water level at Level 2. The logic then has time to detect a broken recirculation loop and select the unbroken recirculation loop for LPCI injection.

2.2.5.4 Variation 4, CS and LPCI Individual Component Controls (Manual Initiation) and Proposed Revision to SR 3.5.2.9 (Manual Operated)

The NRC staff found that the licensee's use of the term "manual initiation channel" is inconsistent with the design assumptions in TSTF-542 and the STS in general. As a result, this section contains a discussion of the clarifications and revisions to the original license amendment request (LAR) (Reference 1) with regard to the requirements for ECCS manual initiation.

The required channels for Fermi 2 TS Table 3.3.5.1-1, Function 1.d, "Manual Initiation," of the CS system, and Function 2.h, "Manual Initiation" of the LPCI system, are modified by a footnote stating, "Individual component controls." The footnote is retained for the manual initiation functions of the CS system and the LPCI system in the proposed TS Table 3.3.5.3-1, as footnote (c) consistent with the current Fermi 2 TS requirements.

In Reference 3, DTE revised SR 3.5.2.9 from that which was proposed in Reference 1, to reflect the existing Fermi 2 ECCS design, in which manual initiation occurs by means of individual component controls. The proposed SR 3.5.2.9 would require verification that the required ECCS subsystem can be manually operated. The proposed SR aligns with the

proposed TS Table 3.3.5.3-1 footnote (c), which states that the Manual Initiation function of the CS and LPCI systems is by means of individual component controls and is an acceptable, plant-specific variation from TSTF-542, Revision 2.

In Reference 4, DTE proposed to revise SR 3.3.5.3.3, as indicated in Enclosure 2, from "Perform LOGIC SYSTEM FUNCTIONAL TEST" to "Perform CHANNEL FUNCTIONAL TEST."

In Reference 5, DTE proposed to revise TS LCO 3.3.5.3 Condition D by changing the 24-hour Completion Time to "Immediately" for restoration of an inoperable CS or LPCI system Manual Initiation Function. Proposed Condition D would also be combined with the Condition E that was proposed in Reference 1. The originally proposed TS LCO 3.3.5.3 Conditions D and E from Reference 1 are shown below.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.3-1.

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

met.

Newly proposed Condition D in Reference 5:

D. As required by D.1 Declare associated low Immediately Required Action A.1 pressure ECCS and referenced in injection/spray subsystem Table 3.3.5.3-1. inoperable.

OR Required Action and associated Completion Time of Condition C not met.

2.2.5.5 Variation 5, TS 3.6.1.3, Action F.1 (RHR/SDC Isolation)

Fermi 2 TS 3.6.1.3 Required Action F.1 requires the licensee to initiate action to isolate RHR-Shutdown Cooling System. This action differs slightly from STS 3.6.1.3 Required Action H.1 to initiate action to suspend OPDRVs; however, both actions direct immediate action to isolate PCIVs to prevent inadvertent draindown.

2.2.5.6 Variation 6, Administrative Change to TS 3.6.4.2 Title The licensee proposes to add a closed parenthesis to the title of TS 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)." This is an administrative change.

2.3 Applicable Regulatory Requirements The regulation in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must also include in the application, a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 10 CFR 50.36(a)(1 ), these TS bases "shall not become part of the technical specifications."

As required by 10 CFR 50.36(c), TSs will include items in the category of safety limits, limiting safety system settings, and limiting control settings. Section 50.36(c)(1) states, in part, that safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation at 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria. Specifically, Criterion 4, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety," supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs

provide reasonable assurance that the health and safety of the public will not be endangered.

Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

NUREG-1433, Revision 4 (Reference 9 and 10), contains the STS for BWR/4 plants; and is part of the regulatory standardization effort. The NRC staff has prepared STSs for each of the light-water reactor nuclear designs. The approved changes to the STS in TSTF-542 will be incorporated into future revisions of NUREG 1433, Volumes 1 and 2. Fermi 2 is a BWR/4 plant and is aligned with the BWR/4 STS, without a setpoint control program.

The NRC staff's guidance for review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," dated March 2010 (Reference 8).

2.3.1 Fermi 2 Applicable Regulatory Design Requirements Fermi 2 Updated Final Safety Analysis Report (UFSAR), Section 3.1, "Conformance with General Design Criteria, contains an evaluation of the design basis of Fermi 2 as measured against the General Design Criteria (GDC) for Nuclear Power Plants, Appendix A, 10 CFR Part 50, effective May 21, 1971, and subsequently amended July 7, 1971. The following criteria from the Fermi 2 UFSAR are related to this LAR.

Criterion 13 - Instrumentation and Control. Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Criterion 14 - Reactor Coolant Pressure Boundary. The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.

Criterion 30 - Quality of Reactor Coolant Pressure Boundary. Components which are part of the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

Criterion 33 - Reactor Coolant Makeup. A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided.

The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 35 - Emergency Core Cooling. A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that ( 1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

3.0 TECHNICAL EVALUATION

Section 2.2 of this SE lists the proposed TS changes, as described in References 1, 2, 3, 4, and 5, for the licensee to adopt TSTF-542, Revision 2. The following sections summarize the NRC staff's evaluation of each of these proposed changes.

3.1 Staff Evaluation of Proposed "DRAIN TIME" Definition As discussed in Section 2.2.1 of this SE, the "DRAIN TIME" is the time it would take the RPV water inventory to drain from the current level to the TAF, assuming the most limiting of the RPV penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action.

The NRC staff reviewed the proposed "DRAIN TIME" definition from TSTF-542. For the purpose of NRC staff considerations, the term "break" describes a pathway for water to drain from the RPV that has not been prescribed in the "DRAIN TIME" definition in TSTF-542.

Based on information furnished by the licensee, the NRC staff has determined that the licensee is appropriately adopting the definition of drain time as specified in TSTF-542.

The NRC staff has reasonable assurance that the licensee will include all RPV penetrations below the TAF in the determination of DRAIN TIME as potential pathways. As part of this evaluation, the staff reviewed requests for additional information used during the development of TSTF-542, Revision 2, which provided examples of bounding drain time calculations for three examples: ( 1) water level at or below the RPV flange; (2) water level above the RPV flange with fuel pool gates installed; and (3) water level above the RPV flange with fuel pool gates removed. The drain time is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the drain down event. The discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the drain time of the RPV.

The NRC staff concluded that the licensee will use methods resulting in conservative calculations to determine RPV drain time, thereby, protecting TS Safety Limit 2.1.1.3, which meets the requirements of 10 CFR 50.36(c)(3). Based on these considerations, the NRC staff has determined that the licensee's proposed addition of the drain time definition to the Fermi 2 TSs is acceptable.

3.2 Staff Evaluation of Proposed TS 3.3.5.3, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The purpose of the proposed new TS 3.3.5.3 regarding RPV WIC instrumentation is to support the requirements of revised TS LCO 3.5.2, and the proposed new definition of drain time. There are instrumentation and controls required for manual pump starts or required as a permissive or operational controls on the systems that provide water injection capability, certain start commands, pump protection, and isolation functions. These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable, as described in Section 3.3 of this SE, the evaluation for revised TS 3.5.2.

For Fermi 2, reactor operators have alternate means, often requiring several more steps, to start and inject water than the preferred simple push button start, but these actions can still be accomplished within the time frames assumed in the development of TSTF-542.

Specifically, the proposed new TS 3.3.5.3 supports operation of the CS and LPCI systems when needed, as well as, the system isolation of the RHR system and the RWCU system.

The equipment involved with each of these systems is described in the evaluation of TS 3.5.2 and the Bases for LCO 3.5.2. The following sections evaluate the various parts of the new TS 3.3.5.3.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.3 LCO and Applicability In References 1, 2, 3, 4, and 5, the licensee proposed a new TS 3.3.5.3 to provide alternative instrumentation requirements to support manual initiation of the ECCS injection/spray subsystem and for automatic isolation of penetration flow paths that may be credited in the determination of drain time. The current TSs contain instrumentation requirements related to OPDRVs in TS Table 3.3.5.1-1, TS Table 3.3.6.1-1, TS Table 3.3.6,2-1, and TS 3.3.7.1. The requirements from Tables 3.3.5.1-1 and Table 3.3.6.1-1, would be consolidated into new TS 3.3.5.3. The OPDRVs requirements in Tables 3.3.6.2-1 and 3.3.7.1-1, would be deleted, as discussed in Section 3.6 of this SE.

The proposed LCO 3.3.5.3 would state:

The RPV Water Inventory Control instrumentation for each function in Table 3.3.5.3-1 shall be OPERABLE.

The proposed Applicability would state:

According to Table 3.3.5.3-1.

A table in TSTF-542 contains those instrumentation Functions needed to support manual initiation of the ECCS injection/spray subsystem required by LCO 3.5.2, and for automatic isolation of penetration flow paths that may be credited in a calculation of drain time. The functions that are required in Modes 4 or 5, or during OPDRVs, are relocated to Table 3.3.5.3-1 and are moved from existing TS 3.3.5.1 and TS 3.3.6.1. Creation of TS 3.3.5.3 places these functions in a single location with requirements appropriate to support the safety function for TS 3.5.2.

The NRC staff concluded that the licensee's proposed alternative is acceptable for Fermi 2 since, at a minimum, either a CS or LPCI subsystem would be available to perform the intended function to inject water into the RPV; therefore, this meets the intent of the NRC-approved TSTF-542.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.3 Actions Section 2.2.2.2 of this SE describes the proposed Actions for the licensee's proposed new TS 3.3.5.3. The NRC staff has determined that these Actions provide effective remedial measures for when one or more instrument channels are inoperable or the equipment and function controlled by these instruments cannot complete the required function in the normal manner. The Actions are evaluated as follows.

Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.3-1 and directs the licensee to immediately enter the Condition referenced in Table 3.3.5.3-1 for that channel.

Action B (concerning the RHR system isolation and RWCU system isolation Functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating drain time. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 requires an immediate re-calculation of drain time, but automatic isolation of the affected penetration flow paths cannot be credited.

Action C (concerning low reactor steam dome pressure permissive Functions necessary for ECCS subsystem manual injection valve opening) would address an event in which the permissive is inoperable. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the trip condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The completion time of one hour is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

Action D would apply if the Manual Initiation Function (via individual component controls) is inoperable, or if the Required Action and associated Completion Time of Condition C were not met.

If the Manual Initiation Function is inoperable, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

With the Required Action and associated Completion Time of Condition C not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

These Actions direct the licensee to take appropriate actions and enter into the Conditions referenced in Table 3.3.5.3-1. The NRC staff has determined that these Actions satisfy the requirements of 10 CFR 50.36( c)(2)(i) by providing remedial actions permitted by the TSs until

the LCO can be met. Therefore, the NRC staff concludes that there is reasonable assurance that the licensee will take appropriate actions during an unexpected drain event to either prevent or to mitigate RPV water level being lowered to the T AF and therefore, that the propose Actions are acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.3 Surveillance Requirements The proposed new TS 3.3.5.3 SRs include Channel Checks and Channel Functional Tests numbered SR 3.3.5.3.1, SR 3.3.5.3.2, and SR 3.3.5.3.3.

The NRC staff finds that these tests are sufficient and adequate, because they will ensure that the Functions of TS 3.3.5.3 are operable (i.e., capable of performing the specified safety function in support of TS 3.5.2, and protection from a potential drain down of the RPV in Modes 4 and 5). The NRC staff also finds that the proposed SRs of LCO 3.3.5.3 are acceptable and concludes that these SRs satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

The proposed SRs are as follows.

SR 3.3.5.3.1 SR 3.3.5.3.1 would require a Channel Check and applies to all functions, except the Manual Initiation. Performance of the Channel Check would ensure that a 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 related channels. A Channel Check is significant in assuring that there is a low probability of an undetected complete channel failure and is a key safety practice to verifying the instrumentation continues to operate properly between each Channel Functional Test. The frequency, in accordance with the surveillance frequency control program (SFCP), is consistent with the current Fermi 2 requirements and supports operating shift situational awareness.

SR 3.3.5.3.2 and SR 3.3.5.3.3 SR 3.3.5.3.2 would require a Channel Functional Test and applies to Reactor Steam Dome Pressure - Low (Injection Permissive) for the CS and LPCI systems, RHR System Isolation, and RWCU system Isolation Functions.

SR 3.3.5.3.3 would require a Channel Functional Test and applies to the CS and LPCI systems Manual Initiation Functions.

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 is acceptable because all of the other required contacts of the relay are verified by other TSs and non-TSs tests. The frequency would be in accordance with the Surveillance Frequency Control Program. The licensee stated in Reference 4 that the reasoning for these two SRs with the same test is that the frequencies are different. The baseline frequencies are 92 days for SR 3.3.5.3.2 and 18 months for SR 3.3.5.3.3; this information is not obvious due to the reference to the Surveillance Frequency Control Program in both SRs. The licensee proposed to structure the Channel Functional Test SRs similar to

the current requirements found in TS 3.3.5.1, from which the Modes 4 and 5 requirements of the functions were relocated.

TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a Channel Calibration or a surveillance to calibrate the trip unit. This is because a draining event in Modes 4 or 5 is not an analyzed accident and, therefore, there is no accident analysis on which to base the calculation of a setpoint. The Functions required to be operable permit ECCS manual initiation or automatic isolation of a penetration flow path, but no specific RPV water level is assumed for those actions. Therefore, the allowable value for Mode 3 was chosen for use in Modes 4 and 5 as it will perform the desired function.

Calibrating the Functions in Modes 4 and 5 is not necessary, as TSs 3.3.5.1 and 3.3.6.1 continue to require the Functions to be calibrated on an established interval.

The NRC staff has determined that the Mode 3 allowable value and established calibration intervals are adequate to ensure that the channel will respond with the required accuracy to allow manual initiation of the pumping systems to inject water and automatic isolation of penetration flow paths.

Based on the above, the NRC staff concludes that the proposed SRs of LCO 3.3.5.3 satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary operability of systems and components is maintained and are, therefore, acceptable.

3.2.4 Staff Evaluation of Proposed Table 3.3.5.3-1, "RPV Water Inventory Control Instrumentation" In order to support the requirements of proposed TS 3.5.2, "Reactor Pressure Vessel (RPV)

Water Inventory Control," the associated instrumentation requirements would be designated in Table 3.3.5.3-1. These instruments would be required to be operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2.

The NRC staff finds the table to be acceptable because it sufficiently discusses the purpose of the functions, the applicability, the number of required channels, the references to the Condition to be entered by letter (e.g., A, B, C) if the function is inoperable, the applicable

$Rs, and the selection of the allowable value, and justification of differences between the existing and proposed TS functions.

In addition, NRC staff finds that the RPV WIC Instrumentation table is acceptable, because it is adequate to ensure that the instrument channels respond permitting pump systems to inject water when needed, and isolation equipment to activate when commanded to support prevention or mitigation of a potential RPV draining event.

Each of the low pressure ECCS subsystems in Modes 4 and 5 can be started by manual alignment of ECCS pumps and valves by individual component controls. Automatic initiation of an ECCS injection/spray subsystem may be undesirable because it could lead to overflowing the RPV cavity, due to injection rates of thousands of gallons per minute (gpm).

Considering the action statements as the drain time decreases (e.g., the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in drain times less than one hour), there is sufficient time for the reactor operators to take manual action to stop the draining event, and to manually start an ECCS injection/spray subsystem or additional method of water injection

as needed. Consequently, there is no need for automatic initiation of ECCS to respond to an unexpected draining event. The NRC staff finds this acceptable because a draining event is a slow evolution when compared to a design basis LOCA assumed to occur at a significant power level.

3.2.4.1 Staff Evaluation of Proposed Table 3.3.5.3-1 Functions The signals from Table 3.3.5.3-1 Functions 1.a (CS) and 2.a (LPCI), Reactor Steam Dome Pressure - Low (Injection Permissive), would be used as permissives for the low pressure ECCS injection/spray subsystem manual initiation functions. This function would ensure that the reactor pressure has fallen to a value below these subsystems' maximum design pressure before permitting the operator to open the injection valves of the low pressure ECCS subsystems. Even though the reactor steam dome pressure is expected to be below the ECCS maximum design pumping pressure during Modes 4 and 5, the Reactor Pressure - Low signals would be required to be operable and capable of permitting initiation of the ECCS. The proposed allowable value would be~ 441 psig, with four required channels per function, as it is currently in Fermi 2 TS Table 3.3.5.1-1.

The instruments for Table 3.3.5.3-1 include Functions 1.b (CS) and 2.b (LPCI), the Manual Initiation channels, which provide manual initiation capability by means of individual component controls. There is one manual initiation channel for each of the CS and LPCI subsystems (i.e., four for CS and four for LPCI). There are no Allowable Values for these functions since the channels are mechanically actuated based solely on the position of the individual components. Each channel of the Manual Initiation Function is only required to be operable in Modes 4 and 5, when the associated ECCS subsystems are required to be OPERABLE per LCO 3.5.2. In addition, these two Functions have footnote (c), which would state, "Individual component controls." The use of this footnote is further described in Section 3.5.4 of this SE (Variation 4).

Table 3.3.5.3-1, Function 3.a, RHR System Isolation, Reactor Vessel Water Level - Low, Level 3, would only be required to be operable when automatic isolation of the associated penetration flow path is credited in the drain time calculation. The proposed number of required instrument channels is 2 in one trip system. Reactor Vessel Water Level - Low, Level 3 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels (two channels per trip system) of the Reactor Vessel Water Level - Low, Level 3 Function are available and are required to be operable to ensure that no single instrument failure can preclude the isolation function. The allowable value was chosen to be the same as the current Primary Containment Isolation Instrumentation, Reactor Vessel Water Level - Low, Level 3 Allowable Value (Function 6.b) from LCO 3.3.6.1, which is~ 171.9 inches.

For Table 3.3.5.3-1 Function 4.a, RWCU System Isolation, Reactor Vessel Water Level - Low Low, Level 2, the function is only required to be operable when automatic isolation of the associated penetration flow path is credited in the drain time calculation. The proposed number of required instrument channels is 2 in one trip system. Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low, Level 2 Function are available, only two channels (both in the same trip system) are required to be Operable. This

proposed change is a new requirement in Modes 4 and 5 for the RWCU system. However, the instrumentation function is the same as TS Table 3.3.6.1, Function 5.e, which contains the requirements for Modes 1, 2, and 3, with the same allowable value of~ 103.8 inches.

The NRC staff finds that the proposed new LCO 3.3.5.3 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met are adequate to protect the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined that the licensee's proposed changes to LCO 3.3.5.3 are acceptable.

3.3 Staff Evaluation of TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control" The NRC staff reviewed the water sources that would be applicable to the proposed TS 3.5.2.

The proposed LCO 3.5.2 would state, in part, One low pressure ECCS injection/spray subsystem shall be OPERABLE.

"One low pressure ECCS injection/spray subsystem" would consist of either one CS subsystem or one LPCI subsystem. A CS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tanks to the RPV. An LPCI subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool to the RPV. Fermi 2 has a total of four CS pumps and four LPCI pumps as described in UFSAR Section 6.3.2, "System Design."

The ECCS pumps are high-capacity pumps, with flow rates of thousands of gpm. Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates. The LPCI subsystem is considered to be operable to perform its safety function while it is aligned and operating for decay heat removal if it is capable of being manually realigned. Decay heat removal in Modes 4 and 5 is not affected by the proposed Fermi 2 TS change as the requirements on the number of shutdown cooling subsystems that must be operable to ensure adequate decay heat removal from the core are unchanged.

These requirements can be found in the Fermi 2 TS 3.4.9, "Residual Heat Removal (RHR)

Shutdown Cooling System - Cold Shutdown," TS 3.9.7, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.8, "Residual Heat Removal (RHR) - Low Water Level." These Fermi 2 decay heat removal requirements are similar to the STS and can be found in NUREG-1433 TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.9, "Residual Heat Removal (RHR) - Low Water Level." Based on these considerations, the NRC staff finds that the water sources provide reasonable assurance that the lowest functional capability required for safe operation is maintained and the safety limit is protected.

The proposed TS LCO 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control,"

contains two parts. The first part states that drain time of RPV water inventory to the TAF shall be ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and the second part states that one low pressure ECCS injection/spray subsystem shall be operable. The proposed Applicability for TS 3.5.2 is Modes 4 and 5. The proposed LCO 3.5.2 note states:

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

The NRC staff reviewed the proposed TS 3.5.2, focusing on how the proposed changes maintain or establish requirements to ensure that the fuel remains covered with water during potential drain events. The proposed TS 3.5.2 contains Conditions A through E, which are based on either required ECCS injection/spray subsystem operability or drain time.

The current TS LCO states that two low pressure ECCS injection/spray subsystems shall be operable, whereas the proposed LCO 3.5.2 states that only one low pressure ECCS injection/spray subsystem shall be operable. This change is reflected in Condition A. The change from two low pressure ECCS injection/spray subsystems to one low pressure ECCS injection/spray subsystem is because this redundancy is not required for the applicable modes. With one ECCS injection/spray subsystem and non-safety related injection sources, defense-in-depth will be maintained. This defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The drain time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TS Safety Limit 2.1.1.3.

The proposed Modes 4 and 5 Applicability of TS 3.5.2 is appropriate given that the TS requirements on ECCS in Modes 1, 2, and 3 will be unaffected.

The proposed Condition A states that if the required ECCS injection/spray subsystem is inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The proposed Condition B states that if Condition A is not met, a method of water injection capable of operating without offsite electrical power shall be established immediately. The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour completion time.

The proposed Condition C states that for a drain time < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and 2: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (C.1) verify the secondary containment boundary is capable of being established in less than the drain time with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.2) verify each secondary containment penetration flow path is capable of being isolated in less than the drain time with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.3) verify one standby gas treatment subsystem is capable of being placed in operation in less than the drain time with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection should the Drain Time be < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and 2: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operation.

The proposed Condition D states that when drain time is < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (D.1) immediately initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 2: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and (D.2) immediately initiate action to establish secondary containment boundary, and (D.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (D.4) immediately initiate action to verify one standby gas treatment subsystem is capable of being placed in operation. Additionally, there is a note stating that required ECCS injection/spray subsystem or additional method of water injection shall be

capable of operating without offsite electrical power, which is similar to proposed Condition B.

The current Fermi 2 TS Condition D (Required Action C.2 and associated Completion Time not met) is similar to proposed Condition D. The proposed Condition D provides adequate protection should the drain time be< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the requirement for the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the standby gas treatment subsystem capable of being placed in operation.

The proposed Condition E states that when the required action and associated completion time of Condition C or D is not met, or the drain time is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then immediately initiate action to restore drain time to ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed Condition E is new, as it is not present in the current Fermi 2 TS. The proposed Condition E is acceptable, as it provides the necessary step to restore the drain time to ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should the other conditions not be met, or if the drain time is < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The NRC staff evaluated the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the TS Safety Limit 2.1.1.3 with the water sources available and maintaining Drain Time ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The LCO correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public and, therefore, they are acceptable.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 Surveillances Requirements The proposed TS 3.5.2 SRs include verification of Drain Time, verification of water levels/volumes that support ECCS injection/spray subsystems, verification of water filled pipes to preclude water hammer events, voltage and bus alignment verification to the LPCI swing bus, verification of correct valve positions for the required ECCS injection/spray subsystem, operation of the ECCS injection/spray systems through the recirculation line, verification of valves credited for automatic isolation actuated to the isolation position, and verification that the required ECCS injection/spray subsystem actuated on a manual initiation signal. Each of the nine SRs are described below.

SR 3.5.2.1: The Drain Time would be determined or calculated, and required to be verified to be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the SFCP. This SR would verify that the LCO for Drain Time is met. Numerous indications of changes in RPV level are available to the operator.

The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant (normally three operator shifts). Changes in RPV level would necessitate recalculation of the Drain Time.

SR 3.5.2.2 (previously SR 3.5.2.1 ): The suppression pool water level(~ -66 inches) for a required LPCI subsystem is required to be verified to ensure pump net positive suction head and vortex prevention is available for the injection subsystem required to be operable by the LCO. Indications are available either locally or in the control room regarding suppression pool water level. This SR would be required to be performed in accordance with the SFCP.

SR 3.5.2.3 (previously SR 3.5.2.2): The suppression pool water level(~ -66 inches) or condensate storage tank water level (~ 19 ft.) for a required CS subsystem is required to be verified to ensure pump net positive suction head and vortex prevention. Indications are

available either locally or in the control room regarding suppression pool water level. This SR would be required to be performed in accordance with the SFCP.

SR 3.5.2.4 (existing TS SR 3.5.2.3 is unchanged and is added here for SR completeness and not part of the TSTF-542 scope of changes): The SR to verify correct voltage and breaker alignment to the LPCI swing bus. 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 made per the SFCP. The correct breaker alignment ensures that 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 Frequency takes into account the redundant capability of the AC, DC, and AC swing bus electrical power sources, and other indications available in the control room that alert the operator to subsystem malfunctions.

SR 3.5.2.5 (previously SR 3.5.2.4): The SR to verify that the ECCS injection/spray subsystem piping locations susceptible to gas accumulation (voiding and entrained air) are sufficiently filled with water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one low pressure ECCS injection/spray subsystem to be operable instead of two. Existing SR 3.5.2.4 wording would change from "Verify, for each required ECCS ... " to "Verify, for the required ECCS ... " This change would clarify the requirement to maintain consistency with the proposed LCO. Maintaining the pump discharge lines of the required ECCS injection/spray subsystem sufficiently full of water ensures that the ECCS subsystem will perform properly.

This will also prevent water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. This SR would be required to be performed in accordance with the SFCP.

SR 3.5.2.6 (previously SR 3.5.2.5): The SR to verify the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2. Similar to the change discussed above for proposed SR 3.5.2.5, changes to SR 3.5.2.6 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "Verify, for the required ECCS injection/spray subsystem, each manual. .. " would replace "Verify each required ECCS injection/spray subsystem manual. .. " SR 3.5.2.6 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This SR would be required to be performed in accordance with the SFCP. This SR would not apply to valves that are locked, sealed, or otherwise secured in position, since these valves would be verified to be in the correct position prior to locking, sealing, or securing.

This SR is modified by a note stating that it is not required to be met for system vent flow paths opened under administrative control. This note would require, under administrative control, a dedicated individual to rapidly close the system vent flow path, if directed.

The existing Note for SR 3.5.2.5 related to LPCI alignment from decay heat removal would be deleted and a similar note would be added to the beginning of LCO 3.5.2. This was previously described in Section 2.2.5.1 of this SE and is further evaluated in Section 3.5.1 (Variation 1).

SR 3.5.2. 7: The required ECCS injection/spray subsystem would be required to be operated through its recirculation line for~ 10 minutes in accordance with the SFCP. This would demonstrate that the subsystem is capable of operation to support TS 3.5.2. Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 10 minutes is based on engineering judgement.

SR 3.5.2.8: Verification that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal would be required to prevent RPV water inventory from dropping below the TS Safety Limit 2.1.1.3 should an unexpected draining event occur. This SR would be required to be performed in accordance with the SFCP.

SR 3.5.2.9 (previously SR 3.5.2.7): In Reference 3, DTE revised the SR as initially proposed in Reference 1. This SR would state, "Verify the required ECCS injection/spray subsystem can be manually operated." This SR verifies that manual initiation by means of individual component controls will cause the required CS subsystem or LPCI subsystem to start and operate as designed, including pump startup and actuation of all valves to their required positions. Vessel injection/spray may be excluded from the SR, per the existing Note. This SR would be required to be performed in accordance with the SFCP.

The NRC staff evaluated each of these proposed SRs associated with the proposed changes to LCO 3.5.2 and concluded that they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. The staff concluded that each of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating experience and 10 CFR 50.36(c)(3) for SRs by ensuring that the necessary quality of systems and components is maintained.

3.4 Staff Evaluation of TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation" Fermi 2 TS LCO 3.3.5.1 currently states that, "The ECCS instrumentation for each Function in Table 3.3.5.1-1 shall be OPERABLE," with the applicability as stated in TS Table 3.3.5.1-1.

TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," contains requirements for function operability during Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable. Conforming changes were proposed for the Actions table of LCO 3.3.5.1 as well.

For the following Functions in Table 3.3.5.1-1, Mode 4 and 5 requirements would be deleted:

1. Core Spray System (a) Reactor Vessel Water Level - Low Low Low, Level 1 (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

(d) Manual Initiation

2. Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level - Low Low Low, Level 1 (c) Reactor Steam Dome Pressure - Low (Injection Permissive)

(d) Reactor Vessel Water Level - Low Low, Level 2 (Loop Select Logic)

(e) Reactor Steam Dome Pressure - Low (Break Detection Logic)

(h) Manual Initiation

These Functions would be deleted to support the consolidation of RPV WIC instrumentation requirements into proposed new TS 3.3.5.3. The requirements for Functions 1.c, 1.d, 2.c, and 2.h would be moved to proposed TS Table 3.3.5.3-1 as discussed in Section 3.2.4.1 of this SE.

For TS Table 3.3.5.1-1 Functions 1.a, 2.a, 2.d, and 2.e, the Modes 4 and 5 requirements would not be retained. The Fermi 2 TSs currently require automatic initiation of ECCS pumps on low reactor vessel water level. However, in Modes 4 and 5, automatic initiation of ECCS pumps could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment.

The NRC staff finds acceptable the deletion of TS Table 3.3.5.1-1, Functions 1.a and 2.a because manual ECCS initiation is preferred over automatic initiation during Modes 4 and 5, and the operator would be able to use other, more appropriately sized pumps if needed to mitigate a draining event.

The deletion of Functions 2.d and 2.e, regarding the LPCI loop select logic and break detection logic, are evaluated as Variation 3 in Section 3.5.3 of this SE.

3.5 Staff Evaluation of Proposed Technical Variations DTE proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staffs SE for TSTF-542. The licensee stated in the LAR that these variations do not affect the applicability of TSTF-542 or the NRC staffs SE for TSTF-542 to the proposed license amendment. The NRC staff evaluated each variation below.

3.5.1 Variation 1, SR 3.5.2.5 note Fermi 2 SR 3.5.2.5 contains Note 1 regarding realignment to the LPCI mode from the decay heat removal mode, which is similar to the proposed Note in STS LCO 3.5.2. DTE proposed to delete Note 1, which applies only to SR 3.5.2.5, and insert a similar note that will apply to the overall LCO for 3.5.2, to be consistent with the STS.

The NRC staff finds that adding the Note to LCO 3.5.2 associated with the LPCI subsystem is appropriate. Without the note, the associated RHR pump would be declared inoperable, which would be contrary to the intent of the current note for SR 3.5.2.5, which allows the LPCI subsystem to be OPERABLE when aligned for decay heat removal; therefore, the NRC staff finds Variation 1 acceptable.

3.5.2 Variation 2, CS and LPCI Pump Discharge Flow Low The proposed Fermi 2 TS Table 3.3.5.3-1 does not include functions corresponding to STS Table 3.3.5.1-1, Function 1.d, "Core Spray Pump Discharge Flow - Low (Bypass)," and Function 2.g, "Low Pressure Coolant Injection Pump Discharge Flow - Low Bypass," since the Fermi TSs do not currently contain these functions in TS Table 3.3.5.1-1.

The licensee clarified the omission of these functions from proposed TS Table 3.3.5.3-1 by stating (Reference 2):

The necessary alignments and component surveillances are accomplished through use of approved plant procedures and Operators that are trained on the use of these procedures. In Modes 4 or 5, alignment of either CS or LPCI from the normal standby system alignment consists of starting the associated CS or LPCI pump and opening of the injection valve. Both manipulations are performed from the main control room and guidance including the expected minimum flow valve response is provided in system operating procedures. Therefore, the corresponding automatic support functions are not proposed to be added to the Fermi 2 TS with the adoption of TSTF-542, consistent with these functions not being included in the current Fermi 2 TS.

The NRC staff finds that the manual operating procedures required to perform the manual initiation of CS and LPCI functions of TS 3.3.5.3 provide reasonable assurance that the pumps will operate as expected and that adequate pump protection will be provided; therefore, the NRC staff finds Variation 2 acceptable.

3.5.3 Variation 3, LPCI Loop Select Logic and Break Detection Logic Fermi 2 TS Table 3.3.5.1-1, Function 2.d, "Reactor Vessel Water Level - Low Low, Level 2 (Loop Select Logic)," and Function 2.e, "Reactor Steam Dome Pressure - Low (Break Detection Logic)," are not included in the STS Table 3.3.5.1-1. Function 2.d and 2.e enable and initiate LPCI loop select logic. Loop select logic is initiated on decreasing RPV water level at Level 2. The logic then has time to detect a broken recirculation loop and select the unbroken recirculation loop for LPCI injection. TSTF- 542 states that if there are plant-specific design and TSs that provide different automatic functions that can be credited for isolating penetrations flow paths below the top of active fuel on low RPV water level, that those functions should be included in the RPV WIC instrumentation TS (DTE proposed TS 3.3.5.3 for Fermi 2). Function 2.d and 2.e are automatic functions for enabling LPCI loop select logic and are removed, consistent with the TSTF-542 justification.

The NRC staff reviewed this variation and determined that the current licensing basis from TS Table 3.3.5.1-1, Functions 2.d and 2.e, is related to the reactor coolant system breaks in Modes 1, 2, 3, 4, and 5. Modes 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure.

Thus, while the potential for the sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decreases resulting from potentially significant or even unexpected drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less water replacement capability to maintain water above the TAF. Therefore, the NRC staff finds Variation 3 acceptable.

3.5.4 Variation 4, CS and LPCI Individual Component Controls (Manual Initiation) and Proposed Revision to SR 3.5.2.9 (Manual Operation)

The NRC staff found that the licensee's use of the term "manual initiation channel" is inconsistent with the design assumptions in TSTF-542 and the STS in general. As a result, this section contains a discussion of the clarifications and revisions to the original LAR (refence 1) with regard to requirements for ECCS manual initiation.

The required channels for Fermi 2 TS Table 3.3.5.1-1, Function 1.d, "Manual Initiation" of the CS system, and 2.h, "Manual Initiation" of the LPCI system, are modified by a footnote stating, "Individual component controls." The footnote is retained for the manual initiation functions of the CS system and the LPCI system in the proposed TS Table 3.3.5.3-1 as footnote (c) consistent with the current Fermi 2 TS requirements.

In Reference 2, the licensee clarified the Fermi 2 "manual initiation" functions for its low pressure ECCS systems as follows:

Fermi 2 does not have the capability to actuate an entire subsystem of CS or LPCI by a single manual pushbutton [as described in another part of reference 2.] Instead, a CS or LPCI subsystem is actuated by manually controlling each individual component of that subsystem in accordance with approved plant procedures. In this context, the phrase "manual initiation channel" in the proposed TS Bases page B 3.3.5.3-3 is used to collectively describe all of the individual components required to manually initiate a subsystem and is not intended to imply that pushing one or two buttons actuates an entire subsystem. Collectively referring to the individual component controls of a subsystem as a "manual initiation channel" in the proposed TS Bases page B 3.3.5.3-3 was done to maintain consistency with the previous usage of the phrase in the Fermi 2 TS Bases, such as shown on page B 3.3.5.1-10 included in the original LAR.

In Reference 3, DTE proposed to revise SR 3.5.2.9 to reflect the existing Fermi 2 ECCS "manual initiation" design. The proposed SR would require verification that the ECCS subsystem designated to support WIC can be manually operated. The proposed SR was revised to align with TS Table 3.3.5.3-1 footnote (c) which states that the manual initiation function of CS and LPCI is accomplished through individual component controls.

In Reference 4, DTE proposed to revise SR 3.3.5.3.3 from "Perform LOGIC SYSTEM FUNCTIONAL TEST" to "Perform CHANNEL FUNCTIONAL TEST," since the logic system functional test does not apply to the Fermi 2 ECCS manual initiation design. The purpose of the logic system functional test in TSTF-542 is to test manual actuation of an ECCS subsystem via a single push button. Therefore, the licensee proposed in Reference 4 to require a channel functional test for the ECCS component controls for manual operation, consistent with the current licensing basis found in TS 3.3.5.1 for the same functions.

In Reference 5, DTE proposed to revise TS LCO 3.3.5.3 Condition D, changing the 24-hour Completion Time to "Immediately" for restoration of an inoperable CS or LPCI Manual Initiation Function. Proposed Condition D would also be combined with the Condition E that was proposed in Reference 1.

The NRC staff reviewed Variation 4 and determined that the licensee's use of the term "manual initiation channel" is inconsistent with the design assumptions in TSTF-542 and the STS in general. Therefore, the NRC staff deems it appropriate for the licensee to clarify Fermi 2's existing ECCS design and alter the TSTF-542 template accordingly to maintain consistency throughout the TSs.

The licensee stated in Reference 2 that the Fermi 2 CS or LPCI subsystem is actuated by manually controlling each individual component of that subsystem in accordance with

approved plant procedures and Fermi 2 does not have the capability to actuate an entire subsystem of CS or LPCI by a single manual pushbutton. The licensee proposed SR 3.5.2.9 (in Reference 3) which states, "Verify the required ECCS injection/spray subsystem can be manually operated." The NRC staff finds that this proposed manual initiation description and supporting SR 3.5.2.9 is consistent with a plant design in which the ECCS subsystem is started with individual component controls and not with the start of an l::CCS injection push button.

The licensee proposed (in Reference 4) to change SR 3.3.5.3.3 from "Perform LOGIC SYSTEM FUNCTIONAL TEST" to "Perform CHANNEL FUNCTIONAL TEST." This is acceptable since manual initiation occurs by means of individual component controls and there is no logic system functional test that can be performed. Additionally, SR 3.3.5.3.3 is consistent with the current requirements for CS and LPCI manual initiation found in TS 3.3.5.1.

The licensee proposed (in Reference 5) to combine the requirements in TSTF-542 LCO 3.3.5.2 Conditions D and E since, for Fermi 2, the loss of the instrumentation that supports the CS and LCPI manual initiation function would be an immediate loss of the ability to inject water into the RPV, thus the licensee's originally proposed 24-hour Completion Time for the Required Action of "Restore channel to OPERABLE status" would be non-conservative.

According to TSTF-542, LCO 3.3.5.2, Condition D, it is assumed that if there was a loss of ECCS instrumentation function, ECCS injection in the RPV would still be achievable since individual ECCS subsystem pump and valve switches (RPV injection function) would still be available. Newly proposed Fermi 2 LCO 3.3.5.3 Condition D is an immediate action to declare the ECCS subsystem inoperable, since the Fermi 2 design for CS/LPCI manual initiation via individual component controls has no backup means for achieving this function.

Based on the above discussion, the NRC staff finds Variation 4 acceptable.

3.5.5 Variation 5, TS 3.6.1.3, Action F.1 (RHR/SDC Isolation)

Fermi 2 TS 3.6.1.3, Action F.1 differs slightly from STS 3.6.1.3, Action H.1.

Specifically, Fermi 2 TS 3.6.1.3, Condition F states:

Required Action and associated Completion Time of Condition A, B, C, or D not met for RHR-SDC PCIV(s) required to be OPERABLE during MODE 4 or 5.

Fermi 2 TS 3.6.1.3, Required Action F.1 states:

Initiate action to isolate RHR-Shutdown Cooling System.

STS 3.6.1.3 (pre-TSTF-542 changes) Condition H states:

[Required Action and associated Completion Time of Condition A, B, C, D, or E not met for PCIV(s) required to be OPERABLE during MODE 4 or 5 or during operations with a potential for draining the reactor vessel (OPDRVs)]

STS 3.6.1.3 (pre-TSTF-542) Required Action H.1 states:

Initiate action to suspend OPDRVs.

The NRC staff reviewed Variation 5 and determined that Fermi 2's TS 3.6.1.3 Required Action F.1 is one of the OPDRV-related phrases used in TS. Its deletion is consistent with TSTF-542, as evaluated in Section 3.6 of this SE, where the deleted OPDRVs terms are evaluated collectively. Therefore, the NRC staff finds Variation 5 acceptable.

3.5.6 Variation 6, Administrative Change to TS 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs."

DTE proposes to add a closed parenthesis to the title of Fermi 2 TS 3.6.4.2, "Secondary Containment Isolation Valves (SCIVs)."

This is an administrative change and has no effect on the adoption of TSTF-542; therefore, the NRC staff finds Variation 6 acceptable.

3.6 Staff Evaluation of Proposed Deletion of Reference to OPDRVs Section 2.2.4 of this SE lists the numerous OPDRV references proposed for deletion. The proposed changes would replace the existing specifications related to OPDRVs with revised specifications for RPV WIC. Specifically, the proposed changes would remove the following from the current Fermi 2 TS: the term "operations with a potential for draining the reactor vessel," the acronym "OPDRVs," and related concepts such as "RHR Shutdown Cooling System integrity maintained," and Required Actions to "suspend OPDRVs."

The term OPDRVs is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions, and SRs, and deleting references to OPDRVs throughout the TS.

The current Fermi 2 TSs contain instrumentation requirements related to OPDRVs in four TS; three of them, which have the OPDRVs phrases described above, and TS 3.3.5.1. The proposed TS 3.3.5.3 consolidates the instrumentation requirements into a single location to simplify the presentation and provides requirements consistent with TS 3.5.2. The remaining TSs with OPDRVs requirements are for primary/secondary containment, primary/secondary containment isolation valves, standby gas treatment system, control room habitability, and electrical sources. Each of these systems' requirements during OPDRVs were proposed for consolidation into the proposed new TS 3.5.2 for RPV WIC, based on the appropriate plant conditions and calculated Drain Time.

The NRC staff determined that the deletion of OPDRV references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation (TSs 3.5.2 and 3.3.5.3, respectively) are a simplified alternative set of controls for ensuring that water level is maintained above the TS Safety Limit 2.1.1.3 and, therefore, these changes are acceptable.

3. 7 Staff Evaluation of TS 3.10, "Special Operations," and TSTF-484 The current Fermi 2 TS LCO 3.10.1, "lnservice Leak and Hydrostatic Testing Operation,"

allows temperature excursions greater than 200 °F, while in Mode 4, to allow performance of inservice leak and hydrostatic testing, as a consequence of maintaining adequate pressure for

an inservice leak and hydrostatic test, or as a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities," revised LCO 3.10.1 in the STS to expand its scope to include operations where temperature exceeds 200 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

By amendment No. 210, dated September 13, 2018 (Reference 11 ), the NRC approved changes to Fermi 2 TS LCO 3.10.1 to adopt the provisions of TSTF-484. The NRC staff's SE for this amendment stated, in part, that, "two ECCS injection/spray subsystem[s must] be operable in Mode 4" at Fermi 2 per TS 3.5.2. However, per the proposed revised LCO 3.5.2, only one low pressure ECCS injection/spray subsystem would be required to be operable in Mode4 The NRC staff has determined that changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is acceptable because, as stated previously in Section 3.3 of this SE, this level of redundancy is not required, even during application of LCO 3.10.1.

The NRC staff's SE for Fermi 2 amendment No. 210 stated, in part:

During inservice leak or hydrostatic testing in Mode 4, both pressure and temperature are elevated and leaks can develop. If a leak occurs during testing, it may be necessary to replenish inventory. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurs. In the event of a large RCS leak, the reactor pressure vessel would rapidly depressurize and allow operation of the low pressure emergency core cooling system (ECCS). The TS requires that two ECCS injection/spray trains be operable.

Since the licensee applies LCO 3.10.1 at the end of a refueling outage, at low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low. There is much more water in the reactor vessel than what is present during power operation and the reactor pressure vessel nearly water solid. Therefore, the operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room. The capability of the low pressure ECCS would be adequate to maintain the fuel covered under the low decay heat conditions during these tests.

As stated previously in Section 3.3 of this SE, with one ECCS injection/spray subsystem and non-safety related injection sources, defense-in-depth will be maintained. The defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The drain time controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TS Safety Limit 2.1.1.3.

After considering of the reasoning presented in this SE in Section 3.3 and reviewing Reference 11, the NRC staff determined that the Fermi 2 LCOs 3.3.5.3 and 3.5.2 adopted as part of TSTF-542 are satisfactory and will, therefore, be acceptable even during application of LCO 3.10.1.

3.8 Technical Conclusion Fermi 2 TS Safety Limit 2.1.1.3 requires that reactor vessel water level shall be greater than the top of active irradiated fuel. Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions. The proposed TS changes evaluated within this SE establish new LCO requirements that address the preventive and mitigate equipment and associated instrumentation that provide an alternative means to support TS Safety Limit 2.1.1.3 during Modes 4 and 5 operations.

The reactor coolant system is at a low operating temperature(< 200 °F) and is depressurized during Modes 4 and 5 conditions. An event involving a loss of inventory while in the shutdown condition does not exceed the capacity of one ECCS subsystem. The accidents that are postulated to occur during shutdown conditions (i.e., the Fuel Handling Accident (UFSAR Section 15.7.4) and the Hypothetical Liquid and Solid Radwaste System Accident Analysis (UFSAR 15.7.3)) do not involve a loss of inventory. Therefore, the equipment and instrumentation associated with the RPV WIC TSs do not provide detection or mitigation related to these design basis accidents.

The proposed TS LCO 3.5.2 contains requirements for operability of one ECCS subsystem along with requirements to maintain a sufficiently long Drain Time so that plant operators would have time to diagnose and mitigate an unplanned draining event. The NRC staff has determined that LCO 3.5.2 and LCO 3.3.5.3 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.3 provide remedial actions to be taken in the event the LCO is not satisfied and, therefore, meet the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed Action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The NRC staff evaluated the proposed Drain Time definition, TS 3.5.2 (which contains the requirements for RPV WIC), and TS 3.3.5.3 (which contains the requirements for instrumentation necessary to support TS 3.5.2). Based on the considerations discussed above, the NRC staff concludes that the propos~d revisions are acceptable because they consolidate and clarify the RPV WIC requirements, which meet 10 CFR 50.36(c)(2)(ii),

Criterion 4, to establish LCOs for structures, systems, or components significant to public health and safety as evidenced by operating experience.

The licensee proposed to delete OPDRV references from the TS Applicability, Conditions, Required Actions, and Notes. The NRC staff reviewed the proposed changes and determined that the deletion of OPDRV references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated

instrumentation, TSs 3.5.2 and 3.3.5.3, respectively, are a clarified and simplified alternative set of controls for ensuring that water level is maintained above the TAF.

The NRC staff reviewed the SRs associated with the revised TS LCO 3.5.2 and new LCO 3.3.5.3. The NRC staff finds that the proposed SRs is TS 3.5.2 are acceptable since they support TS 3.5.2 drain time requirements, assure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, ECCS injection/spray subsystems are adequately filled (mitigates effects of gas accumulation or voiding), the subsystems have verified valve positions to support RPV injection, verify correct voltage and breaker alignment to the LPCI swing bus, verify that pumps provide adequate flow to support drain time and RPV injection, verification of automatic isolation, and ECCS injection/spray subsystems can be manually operated (manual initiation by means of individual component controls). The NRC staff finds that the three SRs proposed for TS 3.3.5.3 are sufficient and adequate, because they ensure that the Functions are capable of performing their specified safety functions in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in Modes 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed Fermi 2 changes against each of the unit applicable design requirements listed in Section 2.3.1 of this SE. The NRC staff finds that the proposed changes for Mode 4 and 5 operations, as they relate to the proposed TS changes for the new drain time definition and the removal of OPDRV references, remain consistent with the Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," in that the Fermi 2 design requirements for instrumentation, reactor coolant leakage detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected.

The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. Consistent with 10 CFR 50 .36( a)( 1), the licensee submitted corresponding TS Bases changes that provide the reasons for the proposed TSs changes. The NRC staff concludes that the TS Bases changes provided describe the bases for the affected TSs and follow the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing Fermi 2 requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with TSTF-542, Revision 2 (Reference 6) and Chapter 16 of the SRP (Reference 8).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on September 6, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released

offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the Federal Register on November 7, 2017 (82 FR 51649), and there has been no public comment on such finding.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

( 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter from DTE Energy (DTE) to US NRC, "Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated August 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A422).

2. Letter from DTE Energy (DTE) to US NRC, "Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated April 4, 2018 (ADAMS Accession No. ML18094A165).

3. Letter from DTE Energy (DTE) to US NRC, "Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated May 17, 2018 (ADAMS Accession No. ML18138A149).

4. Letter from DTE Energy (DTE) to US NRC, "Supplemental Information in Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated June 27, 2018 (ADAMS Accession No. ML18178A134).

5. Letter from DTE Energy (DTE) to US NRC, "Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control," dated August 7, 2018 (ADAMS Accession No. ML18219A659).

6. Enclosure to Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016 (ADAMS Accession No. ML16074A448).

7. Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (TAC NO. MF3487),

dated December 20, 2016 (ADAMS Accession No. ML16343B008).

8. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (NUREG-0800, formerly issued as NUREG-75/087)," Chapter 16.0. "Technical Specifications," Revision 3, dated March 2010 (ADAMS Accession No. ML100351425).

9. NUREG-1433, "Standard Technical Specifications, General Electric BWR/4 Plants,"

Vol. 1, "Specifications," Rev. 4.0, dated April 2012 (ADAMS Accession No. ML12104A192).

10. NUREG-1433, "Standard Technical Specifications, General Electric, BWR/4, Revision. 4.0, Vol. 2, Bases," dated April 2012 (ADAMS Accession No. ML12104A193).

11. Letter from US NRC to DTE Energy, "Fermi 2 - Issuance of Amendment Regarding the Adoption of Technical Specification Task Force Traveler TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities, (EPID L-2017-LLA-0351)" dated September 13, 2018 (ADAMS Accession No. ML18165A202).

Principal Contributors: Larry Wheeler, NRR Khadijah West, NRR Diana Woodyatt, NRR Date of issuance: September 17, 2018

ML18247A452 *via email FFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC*

SGoetz SRohrer (IBetts for) VCusumano 9/13/2018 9/10/2018 9/6/2018 OFFICE NRR/DE/EICB/BC* OGC NLO

NRR/DORL/LPL3/BC 3/PM NAME MWaters JWachutka DWrona DATE 9/5/2018 9/17/18 9/17/18

v t e Letter Sequence Approval
CAC:MG0208, (Approved, Closed) EPID:L-2017-LLA-0282, (Approved, Closed)
Initiation Request Acceptance... Supplement Administration Questions Answers 4 April 2018 17 May 2018 7 August 2018 Results Approval Other:
MONTHYEAR2018-05-17 [Table View]

ML18247A452

Text

SUBJECT:

Dear Mr. Polson:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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