ML20196K168

Rev 8 to ITS Submittal Dtd 980403,providing Update to ITS Submittal for ITS Section 3.7

ML20196K168
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Issue date:	07/01/1999
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ML20196K157	List: ML20196K168 NRC-99-0076, Forwards Rev 8 to ITS Submittal to Provide Update to ITS Submittal for ITS Section 3.7.Brief Abstract of Changes Included
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{{#Wiki_filter:* 9 INSERT THIS PAGE IN FRONT OF VOLUME 8 . Volume 8 SECTION 3.7 Remove Replace { B 3.7.1 ITS pg B 3.7.1-2 Rev 0 B 3.7.1 ITS pg B 3.7.1-2 Rev 8 B 3.7.1 ITS pg B 3.7.13 Rev 0 B 3.7.1 ITS pg B 3.7.1-3 Rev 8 B 3.7.1 ITS pg B 3.7.16 Rev 0 B 3.7.1 ITS pg B 3.7.1-6 Rev 8 B 3.7.1 NUREG M/U pg B 3.7-2 B 3.7.1 NUREG M/U pg B 3.7-2 Rev 8 B 3'.7.1 NUREG M/U pg B 3.7-6 B 3.7.1 NUREG M/U pg B 3.7-6 Rev 8 B 3.7.2 ITS pg B 3.7.21 Rev 0 B 3.7.2 ITS pg B 3.7.2-1 Rev 8 B 3.7.2 ITS pg B 3.7.2-5 Rev 0 B 3.7.2 ITS pg B 3.7.2-5 Rev 8 3.7.2 CTS M/U (3/4 7-3) pg 1 of 9 3.7.2 CTS M/U (3/4 7-3) pg i of 9 Rev 8 3.7.2 DOCS pg 3 Rev 0 3.7.2 DOCS pg 3 Rev 8 3.7.2 DOCS pg 4 Rev 0 3.7.2 DOCS pg 4 Rev 8 B 3.7.2 NUREG M/U pg B 5.7-7 (Insert) Rev 0 B 3.7.2 ITS pg B 3.7-7 (Insert) Rev 8 B 3.7.2 NUREG M/U pg B 3.7-11 Rev 0 B 3.7.2 NUREG M/U pg B 3.7-11 Rev 8 l B 3.7.2 NUREG M/U pg B 3.7-11 (Insert) Rev 0 B 3.7.2 NUREG M/U pg B 3.7-11 (Insert) Rev 8 3.7.2 NUREG M/U pg 3.7-7 3.7.2 NUREG M/U pg 3.7-8 B 3.7.2 NUREG M/U pg B 3.7-14 B 3.7.2 NUREG M/U pg B 3.7-15 B 3.7.2 NUREG M/U pg B 3.7-16 B 3.7.2 NUREG M/U pg B 3.7-17 3.7.2 JFD's pg l' Rev 0 '3.7.2 JFD's pg i Rev 8 B 3.7.3 ITS pg B 3.7.3-7 Rev 0 B 3.7.3 ITS pg.B 3.7.3-7 Rev 8 3.7.3 DOC's pg 2 Rev 0 3.7.3 DOC's pg 2 Rev 8 3.7.3 DOC's pg 3 Rev 0 3.7.3 DOC's pg 3 Rev 8 3.7.3 DOC's pg 5 Rev 0 3.7.3 DOC's pg 5 Rev 8 B 3.7.3 NUREG M/U pg B 3.7-23 'B 3.7.3 NUREG M/U pg B 3.7-23 Rev 8 3.7.4 DOC's pg 3 Rev 0 3.7.4 DOC's pg 3 Rev 8 3.7.5 CTS M/U (3/4 4-18) pg i of 2 Rev 8 3.7.5 CTS M/U (3/411-17) pg 1 of 1 3.7.5 CTS M/U (3/4 Il-17) pg 2 of 2 Rev 8 3.7.5 DOC's pg 2 Rev 0 3.7.5 DOC's pg 2 Rev 8 3.7.6 DOC's pg 1 Rev 0 3.7.6 DOC's pg 1 Rev 8 i 3.7.6 DOC's pg 2 Rev 0 3.7.6 DOC's pg 2 Rev 8 l 1 990700o190 99 % PM ADOCK 05000341 Rev 8 07/01/99 P pg

Volume 8 SECTION 3.7 (cont'd)-l ~?~ Remove Replace 3.7.7 DOC's pg 2 Rev 0 3.7.7 DOC's pg 2 Rev 8 i, 3.7.8 ITS pg 3.719 Rev 8 B 3.7.8 ITS pg B 3.7.81 Rev 8 B 3.7.8 ITS pg B 3.7.8-2 Rev 8 B 3.7.8 ITS pg B 3.7.8-3 Rev 8 3.7.8 CTS M/U (3/4 7-5) pg 1 of 1 Rev 8 3.7.8 DOC's pg i Rev 8 3.7.8 DOC's pg 2 Rev 8 3.7.8 NUREG M/U pg 3.7 7 Rev 8 3.7.8 NUREG M/U pg 3.7 8 Rev 8 B 3.7.8 NUREG M/U pg B 3.714 Rev 8 B 3.7.8 NUREG M/U pg B 3.714 (Insert) Rev 8 B 3.7.8 NUREG M/U pg B 3.715 Rev 8 B 3.7.8 NUREG M/U pg B 3.716 Rev 8 B 3.7.8 NUREG M/U pg B 3.717 Rev 8 3.7.8 JFDs pg i Rev 8 3.7.8 NSHC pg 1 Rev 8 ) Rev 8 07/01/99 l

f* l RHRSW System B 3.7.1 BASES APPLICABLE The RHRSW System removes heat from the suppression pool to SAFETY ANALYSES limit the suppression pool temperature and primary -containment pressure following a LOCA. This ensures that the primary containment can perform its function of limiting the release of radioactive materials to the environment following a LOCA. The ability of the RESW System to support long term cooling of the reactor or primary containment is discussed in the UFSAR, Chapters 6. 9. and 15 (Refs. 2. 3. and 4. respectively). These analyses explicitly assume that the RESW System will provide adequate cooling support to the equipment required for safe shutdown. These analyses include the evaluation of the long term primary containment response after a design basis LOCA. The safety analyses for long term cooling were performed for various combinations of Rm System failures. The worst case single failure that would affect the performance of the RHRSW System is any failure that would disable one subsystem of the RHRSW System. As discussed in the UFSAR. Al Section 6.3.2.14 (Ref. 5) for these analyses, manual initiation of the OPERABLE RESW subsystem and the associated R m System is assumed to occur 20 minutes after a DBA. The RHRSW flow assumed in the analyses is initially 9000 gpm with.two pumps operating in one loop. The 9000 gpm initial RHRSW flow will decrease with time due to the RHR Reservoir evaporative and drift losses. This analysis showed a peak suppression >ool temperature of 1%.5'F. This temperature is less than t1e suppression pool temperature of 198"F used in core spray and RHR net positive suction head margin calculations. The maximum suppression chamber )ressure was found to be 18.3 psig. These values are well j >elow the design temperature of 281*F and maximum allowable pressure of 62 psig. The RHRSW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). -l FERMI - UNIT 2 B 3.7.1 - 2 Revision 8. 07/01/99

RHRSW System B 3.7.1 BASES LC0 Two RESW subsystems are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RESW subsystem is considered OPERABLE when: 4 a. Two pumps are OPERABLE: and El b. An OPERABLE flow path is capable of taking suction from the RHR Reservoir and transferring the water to the RHR heat exchangers at the assumed flow rate and returning - the water to the RR Reservoir via the cooling tower or cold weather bypass valves. An adequate suction source is not addressed in this LC0 since the minimum net positive suction head (corresponding to a submergence at an elevation of 554.6 ft) is bounded by the 580 ft elevation requirements of LC0 3.7.2, " Emergency Equipment Cooling Water (EECW)/ Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (VHS)." APPLICABILITY In MODES 1, 2, and 3, the RHRSW System is required to be OPERABLE to support the OPERABILITY of the RHR System for primary containment cooling (LCO 3.6.2.3, " Residual Heat Removal (RR) Suppression Pool Cooling" and decay heat removal (LCO 3.4.8, " Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown"). The Applicability is therefore consistent with the requirements of these systems. l In MODES 4 and 5. the OPERABILITY requirements of the RHRSW System are determined by the systems it supports. l 1 -l FERMI UNIT 2 B 3.7.1 - 3 Revision 8. 07/01/99

l RHRSW System B 3.7.1 BASES ACTIONS (continued) SURVEILLANCE SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for R E SW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system. This SR does not require any testing or valve manipulation: rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. REFERENCES 1. UFSAR. Section 9.2.5. 2. UFSAR, Chapter 6. 3. UFSAR, Chapter 9. 4. UFSAR, Chapter 15. I S. UFSAR, Section 6.3.2.14. l FERMI - UNIT 2 B 3.7.1-6 Revision 8. 07/01/99

RHRSW System B 3.7.1 BASES (continued) APPLICABLE The RHR$W System removes heat from the suppression pool to SAFETY ANALYSES limit the suppression pool temperature and primary containment pressure following a (OCA. This ensures that the primary containment can perfo?m its function of limiting the release of radioactive materials to the environment following a LOCA. The ability of the RHR$W System to support long tem cooling of the reactor or prima >9 containment is discussed in the WSAR, Chapters i nM J5L (Refs. 2,and 3,trespectively). These analyses 6 icit'y Qy assume that the RHR$W System will provide adequate cooling r support to the equipment required for safe shutdown. These analyses include the evaluation of the long term primary containment response after a design basis LOCA. The safety analyses for long term cooling were performed for - various combinations of RHR System failures. The worst case si le failure that would affect the performance of the W System is any failure that would disable one subsystem of the plRSW System. AsdiscussedintheyFSAR, (,J.2.,1 m ctions p.:.:.i. P (Ref for these analyses, manual 3 initiationofthebPERABLE RSW subsystem and the //,d//y associated RHR System is assumed to occur nutes after gaoo a DBA. The RHRSW flow assumed in the ana yse is r Tx with two numos operating in one loooln[4004) gpa $1, t.. h

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== = n..:.'.. ;..e gg =. m -m =f; ;:=f '?!.50' ;i, rn;rt!=1yg well rrn = T?^'.i i Inlowthedesgntemperatureof Iandmaximum The goop jgg f pgg allowablepressureof(62fpsig.'l i lov vill o/ecreah .The RHRSW Sntes satisfies Criterion 3 o th = Fvi kyo - wiff.1.'ent du e,10 lA e -Statementr /0 cFR 50.%ON[i) y n e n c,.i., n,a..,e wwn42 u LC0 Two RHRSW subsystems are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remova post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RHRSW subsystem is, considered OPERABLE when: 4 a. Two pumps are OPERABLE; and I (continued) I = 'O !!O B 3.7-2 Pr 1, 0 /07j;'; -W m lv5 G r1a IYSO Gbowt/ f eG N Mfft Hion poo { Ye nspec h t t ce o 19t,S *P. Tit h tenyera fa t & Ic.ss flu tf<c. nffres' hn Poo l. l 1e, pen %re o f l9 s

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\\ RHRSW Systen 8 3.7.1 BASES SURVEILLANCE SR 3.7.1.1 (continued) REQUIREMDrIS. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently-misaligned, such as check valves. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. REFERENCES

1. MFSAR, Section (9.2

[g. 14f54A; %

2. MFSAR, Chapter J6T.

-4 9 I. 4(FSAR, Chapter (lq< y, X WFSAR, Section [5.2.1.'. ). g 1^/' "S B 3.7-6 a.= 1, c'/0?l05 f

r EECW/EESW System and UHS f B 3.7.2 ] B 3.7 PLANT SYSTEMS B 3,7,2 Emergency Equipment C90 ling Water (EECW)/ Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS) BASES BACKGROUND The EECW/EESW System (Ref.1) is designed to provide cooling water for the removal of heat from equipment, such as residual heat removal (RHR) and Core Spray (CS), pump coolers, and room coolers for Emergency Core Cooling System and other safety related equipment, required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient. Components cooled by each EECW subsystem are normally cooled by the Reactor Building Closed Cooling Water (RBCCW) system, which cools various plant equipment primarily in the Reactor Building. An EECW subsystem contains a. single 1450 gpm Y nominal capacity pump, a heat exchanger, a make up tank, e valves, piping, and associated instruruentation. Upon %l receipt of a loss of off-site power, a high.irywell pressure signal, or low RBCCW System pressure, both EECW subsystems are activated. Upon activation, the EECW aump starts, the EECW loop isolates from the remainder of t1e RBCCW system, and other system valves reposition as needed to isolate non-essential loads and configure the system for emergency operation. Each EECW subsystem's heat exchanger is cooled by the same division's EESW subsystem. The EESW subsystem contains a single 1600 gpm nominal ca)acity pump that pumps from the division's RHR Reservoir t1 rough the EECW subsystem's heat exchanger and returns to the RHR Reservoir. Each EESW l subsystem functions to cool the associated EECW subsystem. The EESW pum) automatically starts on the same actuation signals as t1e EECW System. The two EECW/EESW subsystems are separated from sach other so that failure of one subsystem will not affect the OPERABILITY of the other subsystem. The UHS (Ref,1) is provided by a single highly reliable l water supply in the form of the RHR reservoirs and a means of heat rejection in the form of mechanical draft cooling towers The UHS consists of two one-half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 10' gallons of water, corresponding to an elevation of 583 feet. The two reservoirs are connected by two l FERMI UNIT 2 B 3.7.2-1 Revision 8 07/01/99 9

EECW/EESW System and UHS B 3.7.2 BASES ACTIONS (continued) D.1 and D.2 If the EECW/EESW subsystem cannot be restored to OPERABLE status within the associated Com)1etion Time, or both EECW/EESW subsystems are inopera)le for reasons other than Condition A, or the URS is determined inoperable for reasons other than Conditions A and B, such.as not meeting the combined water volume or average water tem)erature requirement, the unit must be placed in a 10DE in which the LCO does not apply. To achieve this status, the unit must be ) laced in at least MODE 3 within 12 hours and in MODE 4 1 wit 11n 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the Fecuired unit conditions from full power conditions in an orcerly manner and without challenging unit systems. SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies the water level in each RHR reservoir to be sufficient for the proper reservoir heat removal capability and long term cooling capability (net positive suction head and pump vortexing are considered in determining this l limit). If each reservoir meets tne 25 foot level limit (which equates to a water volume of 2.990,000 gal or 580 ft elevation) then the average reservoir level is known to be Q met without also doing a specific calculation. If either reservoir does not meet the water level requirement, that reservoir is inoperable. Verification of the UHS combined water volume is required to assess the OPERABILITY of the entire UHS. This ensures that the heat removal capability { of the UHS is within the assumptions of the long term cooling analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the, applicable MODES. SR 3.7.2.2 Verification of the average water temperature in each reservoir, both individually and combined, ensures that the neat removal capability of the reservoirs and UHS are within the assumptions of the long term cooling analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. l FERMI UNIT 2 B 3.7.2 -5 Revision 8 07/01/99 L..

$%ciF/ cunorJ 5.?,2. PLANT SYSTEMS ///.5p Sad. SfdC/ Cob /h 3 6./) EMERGENCY E00f PMENT C00l1NG WATER SYSTEM Al.co s u $ g ci A c4 N m 0 5') tiMITING CONDITION FOR OPERATION l LCO 3.7.1.2 Two emergency equipment cooling water (EECV) system 3 7 2., subsystems shg Bpit each subsystem sm vr ueu 01. fa. OPERABLE EEC ump, and b. An OPERABLE f w path capable of moving heat from e associate safety rela d equipment., APPtfCABILITY: OPERATIONAL CONDITIONS 1. 2, 3, ACTION: a. In OPERATIONAL CONDITION 1, 2 or 3, with one EECW system subsystem inoperable: 1. Mthin2 hours: S ct. < a) Verify that all required systems, subsystems, trains, 3@gg" components and devices that depend upon the remaining 55-OPERABLE EECW system subsystem are also OPERABLE, and t M M N d '" 3 b [b) Verify that the ADS

• is 00ERABLE.

3.5.1 f 5.7 / 1 5<c Ot erwise", be in at least HOT SHUTDOWN within the next 12 hours < Sped GcahS5 and in_ COLD SHUT 00WN within the following 24 hours. /j(/rw [2. Declare the associateo savety-relatro equipment inoperable and) g ggg L ( take the ACTIONS required by the applicable Specificatto yn Restore the inoperable EECW system subsystem to OPERABLE ACTierJ 6. ,3'. status within 72 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 A c-n m D

hours, b.

In OPERATIONAL CONDITION 4 or 5 determine the OPERABILITY of the safety-related equipment associated with an inoperable EECW system subsystem and take any ACTIONS required by the applicable Specifications. f N h ( ADS is not required to be OPERABLE when reactor steam dome press ~ \\" S' than or equal to 150 PSIG. f "Except for an inoperable Drywell Cooling Unit required by Specification 8 s ei 3.7.11 or an inoperable primary containment oxygen monitoring instrumentation I Spec;(:ndig channel, required by Specification 3.3.7.5, that depends on the remaining OPERABLE EECW system subsystem. In these cases, take the ACTION required by g,g 5pecification 3.7.11 for the inoperability of both required Drywell Cooling Units or Specification 3.3.7.5 for the inoperability of both required primary containment oxygen monitoring instrumentation channels. u FERN! - UNIT 2 3/4 7 3 Amendment No. #, 55,132 PAGE I 0F 09 [(ed 8

i DISCUSSION OF CHANGES ITS: SECTION 3.7.2 EECW / EESW SYSTEM AND UHS A.6 - CTS 4.7.1.2.b requires the performance of a system functional test for the EECW System on an " actuation test signal." ITS SR 3.7.2.5 permits the system functional to be initiated by an " actual or i simulated" signal. This change allows satisfactory automatic system initiations to be used to fulfill the system functional Surveillance requirement. Operability is adequately demonstrated because the EECW Systems can not discriminate betweer, " actual" or " test" initiation signals. This is an administrative change with no impact on safety because it is a reasonable interpretation of i the existing requirement. A.7 CTS 4.7.1.2.a requires a monthly EECW System valve lineup " verifying each valve, is in its correct position." ITS clarifies this requirement by adding a Note to SR 3.7.2.4, stating that " Isolation of EECW flow to individual components does not render EECW System inoperable." Since individually cooled supported systems may be isolated for various reasons, and that supported system declared inoperable. " correct position" of valves supplying cooling flow to that system can be misleading. The intent of " correct" is to allow for certain valve realignments (e.g., isolated) that may be reouired to individual systems, to be acceptable configurations for EECW Operability. This intent is supported by the NUREG 1433 clarifying wording. Therefore this clarification is considered administrative only. TECHNICAL CHANGES MORE RESTRICTIVE None TECHNICAL CHANGES LESS RESTRICTIVE " Generic" LA.1 CTS LCOs 3.7.1.2, 3.7.1.3, 3.7.1.5, and 3.7.1.5 Action c include details relating to system design, function, and Operability for the EECW, EESW, UHS, and cross connect line respectively. ITS 3.7.2 includes only a requirement for Operability and does not include the details of system design and specific flow path and Operability requirements. This is acceptable because these details do rot impact the requirement to maintain the equipment Operable and the f ITS definition for Operability ensures that all equipment required 6 to maintain Operability is functioning. These details will be relocated to the Bases where they can be adequately defined and FERMI UNIT 2 3 REVISION 8. 07/01/99l

1 e ) DISCUSSION OF CHANGES ITS: SECTION 3.7.2 EECW / EESW SYSTEM AND UHS To controlled. The Bases require change control in accordance with ITS l [ 5.5.10. Bases Control Program. These details are not required to be g in the ITS to provide adequate protection of the pui.lic health and safety. This is acceptable because these details do not impact the requirement to maintain the equipment Operable. LA.2 CTS 4.7.1.5 details proper positioning of UHS cross connect valves. ITS SR 3.7.2.4 provides the requirement for verifying all safety t related valves to be "in the correct position." The ITS presentation (consistent with NUREG 1433 presentation) does not detail these correct positions. The details found in CTS are located.in the Bases for ITS SR 3.7.2.4. This is acceptable because these details do not impact the requirement to maintain the reservoir Operable and the associated valves in their correct position. These details can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10, Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety because these details do not ispect the requirement to maintain the valves properly positioned and the system operable. LA.3 CTS 4.7.1.5.b.1 details the method for operating the UHS cooling tower fans (i.e. from the control room). These details are not included in the ITS. The detailed methods for performing this Surveillance are moved to the Bases for ITS SR 3.7.2.3. These details can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the ITS continues to require the appropriate operability testing. LA.4 CTS 4.7.1.5.c specifies performing the cross connect valve cycle verification once per 92 days' ITS Specification 3.7.2 does not require a specific valve cycling test; rather ITS 5.5.6. Inservice Testing Program, generically encompasses all required valve cycling. ~ This is acceptable because the CTS frequency is based on inservice d test (IST) program requirements and will change based on any 4 lk ..j approved changes to that program. Therefore, this information will ~ be defined and controlled in the IST Program which requires change control in accordance with ITS Section 5.5 Programs and 10 CFR i 50.55. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the details in ITS 5.5.6 are adequate to require that the surveillance be performed in accordance with the Inservice Testing Program. FERMI., UNIT 2 4 REVISION 8. 07/01/99l

1 EECW/EESW System and UHS B 3.7.2 Insert B 3.7.2-1 1 ( Components cooled by each EECW subsystem are normally cooled by the Reactor Building Closed Cooling Water (RBCCW) system, which cools various plant equipment primarily in the Reactor Building. An EECW subsystem.contains a single 1450 gpm nominal capacity pump, a heat exchanger, a make up tank, valves, piping, and associated instrumentation. Upon receipt of a loss of ly off site power, a high drywell pressure signal, or low RBCCW System g pressure, both EECW subsystems are activated. Upon activation, the EECW W pump starts, the EECW loop isolates from the remainder of the RBCCW system, and other system valves reposition as needed to isolate non essential loads - and configure the system for emergency operation. Each EECW subsystem's heat exchanger is cooled by the same division's EESW subsystem. The EESW subsystem contains a single 1600 gpm nominai capacity pump that pumps from the division's RHR reservoir through the EECW subsystem *s heat exchanger and returns to the RHR reservoir. Each EESW subsystem functions to cool the associated EECW subsystem. The EESW pump lh dutomatically starts on the same actuation signals as the EECW System. The two EECW/EESW subsystems are separated from each other so that failure of one subsystem will not affect the OPERABILITY of the other subsystem. The UHS (Reference 1) is provided by a single highly reliable water supply in the form of the RHR reservoirs and a means of heat rejection in the form of mechanical draft cooling towers. The UHS consists of two one half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 106 gallons of water, corresponding to an elevation of 583 feet. The two reservoirs are connected by two redundant lines, each with two motor operated isolation valves, to permit access to the combined inventory to either division of cooled equipment in the event of a failure in one of the divisions. Each RHR reservoir is the cooling source for that division's RHRSW subsystem, and EESW subsystem,.as well as the diesel generator service water pumps for that division's emergency diesel generators (EDGs). A two cell mechanical draft cooling tower is located over each division reservoir. Each cooling tower is designed to cool one division of supported equipment, thus providing full redundancy. FERMI - UNIT 2 Page B 3.7 7 (Insert) REVISION 8. 07/01/$9

Ecc wlEEw) M System and JUHSE B 3.7.2 BASES ACTIONS .1 and 2 (continued) power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE ,LL1 REQUIREMENTS This-SR-ens es-adequate--long-te -(30-days}-cooNgwa e maintain d 9 th the [LHS] ea -source-be w the mi levolv-thf-affected-[PSW]-sub stes-must-be-declare inoper le The.24 hour Fr uency is based on op ating expe ence related to tr ing of the parameter riations dur, ng the applicable MODES - SR 3.7.2.r f W This SR verifies the water level fin each 2Hg k'ese rve,'e ump ec ef-t intake-structure} to be sufficient for the proper operat4cn-reserWie /en7 Af-the-[PSW}-pumps (net positive suction head and pump i Mg M8'j;jg vottexing are considered in determining this limit) The 24 hour Frequency is based on operating experience related and /h:3obilifY km to trending of the parameter variations during the Co ch'n tag ' applicable MODES. WWT B3/7 2-Vag [L ._a t un ..i.r.n '} Y:rific.tkr. :f th: !L'PI] ti;: 2t m eMer:: th:t th: h:& M If.M.....".}.2..'l..*.* U N.... "O".5..?2,.5.. U pased-on-operat4ng =Prience-rd. N?,[d_,itp{,, y,, a 4 tet-to-trending-of-.t[., y jg _varamette-variations-during-the-ap Weli MODE 3. ,J l lk)$EILT y Sco

• ~ ko \\ coo m d fad V W M 7

( B 30.2. *l bj sp dn 3'7'p & ' og sfads QC k l% yo P3 ), Operating each cooling tower fanffor it 15 minuteg,bsures that all fans are OPERABLE and that all associateFcontrols are qctioning phoperly. It also ensures that fan or mot @ lure, or excessive vibration, can be detected for cor ive action. The 31 day Frequency is based on operating experience, the known reliability of the fan units, the redundancy available, and the low probability of (continued) BWR/4 515 B 3.7-11 Rev-lM4/07/95-

EECW/EESW System and UHS B 3.7.2 Insert B 3.7.2 4a If each reservoir meets the 25 ft limit (which equates to a water volume of 2.990,000 gal or 580 ft elevation), then the average reservoir level is known to be met without also doing a specific calculation. If either reservoir does not meet the water level requirement, that reservoir is inoperable. Verification of the UHS O combined water level is required to assess the OPERABILITY of the entire UHS. This ensures that the heat removal capability of the UHS is within the - assumptions of the long term cooling analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. O Insert B 3.7.2-4b l SR 3.7.2.2 Verification of the. average water temperature in each i reservoir, both individually and combined, ensures that the heat removal capability of the reservoirs and UHS are within the assumptions of the long term cooling analysis. The 24 hour Frequency is based on operating. experience related to trending of the parameter variations during the applicable MODES. 6 FERMI UNIT 2 Page B 3.7 11 (Insert) REVISION 8 07/01/99l

JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.7.2 EECW/EESW System and UHS NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting. ) and revised numbering is made to incorporate these changes consistent d with Writer's Guide conventions. Refer to CTS Discussion Of Changes to the related requirements for a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. Specifically, the NLREG presentation for [PSW] and [ UHS] is based on the lead plant (E.I. Hatch). The revised presentation constituting the ITS is based on CTS requirements for j EECW, EESW, and the ultimate heat sink. Several administrative changes ar'e adopted in order to adopt the intent and scope of the NUREG standard. P.2 Bases changes are made to reflect plant specific design details. equipmont terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification change (and associated JFD) for additional detail. P.4 Not used. lw'4 4 FERMI - UNIT 2 1 REVISION 8, 07/01/99l

o .' D ~ CREF System B 3.7.3 BASES: SURVEILLANCE REQUIREMENTS'(continued) Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available. The STAGGERED TEST BASIS requires the 10 hour testing of the redundant portions of the subsystem be alternated each 31 day test. such that each redundant portion is operated for 10 hours each 62 day test cycle. ' SR 3.7.3.2' ' This SR verifies that the required CREF testing is performed k in accordance with the Ventilation Filter Testing Program M (VFTP). The VFTP includes testing HEPA filter performance. E charcoal adsorber efficiency minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). ' Specific test frequencies and additional information are discussed in detail.in the VFTP, The Note for this SR provides an allowance to delay entry .into the associated Conditions and Required Actions for up to 6 hours in MODES 1, 2. and 3. This allowance prevents intentional entry into LCO 3.0.3 that would otherwise be caused by tests required by the VFTP. The tests that may be required while operating in MODE 1,' 2, or 3 are: 1) the periodic charcoal sample: and 2) tests and samples required after exposing the filtration system to ventilation from painting, fire, or chemical release. Other VFTP required surveillances can be scheduled when the plant is not operating in MODE 1, 2. or 3. i SR 3.7.3.3-This SR verifies that the silicone sealant applied to CREF ] system duct work outside of the Control Room envelope has j not degraded. The duct work of concern received a general j coating of sealant on the duct seams. This includes a visual inspection for cracking, debonding, and other abnormal degradation of the applied silicone sealant. Such degradation could be indicative of lack of duct integrity. ) Since a portion of the duct work inspected is at negative pressure ur. der postulated system operation during accident conditions, the loss of duct integrity could result in excessive in leakage of radioactive air during an accident. Only duct work-for which in leakage does not receive full 1' FERMI UNIT.2 B 3.7.3 - 7 Revision 8. 07/01/99

DISCUSSION OF CHANGES ITS:.SECTION 3.7.3 CONTROL ROOM EERGENCY FILTRATION (CREF) SYSTEM A.4 The Surveillance Requirement CTS 4.7.2.1.b.2 for the heaters is revised from Operable to operating. It is necessary for the heaters to actually operate (cycle properly between operating and standby when required) to reduce moisture from the adsorbers and HEPA filters. No change in actual operating practice is intended. Therefore, this change is considered administrative. A.5 CTS 4.7.2.1.e.2 requires the performance of a system functional test by a actuation test signal." ITS SR 3.7.3.4 permits the lA system functional test to be initiated by an " actual or simulated" automatic initiation signal. This change allows satisfactory automatic CREF system actuations for other than Surveillance purposes to be used to fulfill the Surveillance Requirement. Operability is adequately demonstrated because the CREF system cannot discriminate between " actual" or " test" signals. This is an administrative change with no impact on safety because it is a reasonable interpretation of the' existing requirements. A.6 CTS 3.7.2 Action c.2 provides specific actions for when the CREF system becomes inoperable (due to loss of charcoal efficiency, to replace the charcoal, or to perform Control Room duct leakage testing during handling fuel in secondary containment) during Core Alterations and during operations with a potential of draining the reactor vessel. The CTS Action c.2 requirements are the same actions as would be required by. CTS Action a.3 except that suspension of Core Alterations and handling of fuel inside secondary containment is not required under Action c.2. The ITS implements these requirements together in Action C by adding a note to the Required Actions for suspending Core Alterations and handling fuel in secondary containment to not require these Required Actions in the situations covered by CTS Action c.2. The resulting requirements are thus unchanged from CTS to ITS. This presentational preference has no affect on safety. Therefore, this is an administrative change with no impact on safety. A.7 CTS 4.7.2.1.h contains two footnotes to provide guidance on test protocol acceptability and a one-time interval extension to allow for implementation of the test requirement. The need for these allowances has passed and they are therefore not included in the ITS. Since this change eliminates provisions that have expired it is an administrative change with no impact on safety. FERMI - UNIT 2 .2 REVIS'^N 8. 07/01/99l i

} DISCUSSION OF CHANGES ITS: SECTION 3.7.3 CONTROL ROOM EMERGENCY FILTRATION (CREF) SYSTEM TECHNICAL CHANGES MORE RESTRICTIVE None TECHNICAL CHANGES LESS RESTRICTIVE " Generic" LA.1 CTS 3.7.2 requires the CREF system to be Operable and identifies what components are required for the CREF system. ITS 3.7.3 requires the CREF system to be Opsrable, but does not define what equipment is required. This is acceptable because these details do { not impact the ITS requirement to maintain the CREF system 6 Operable. ~Therefore, this information will be adequately defined l4 and centrolled in the ITS Bases which require change control in t accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. LA.2 The following CTS details for performing Surveillances are not included in the ITS. These detailed methods for performing i Surveillances will be' moved to the Bases and Technical Requirement Manual (TRM): a'. CTS 4.7.2.1.b.1 details the method of starting a subsystem ("from the control room"). This is relocated to the Bases i for SR 3.7.3.1: b. CTS 4.7.2.1.e.2 details that the system functional test includes a check that the system isolation valves close within 5 seconds. This is relocated to the Bases: l c. CTS 4.7.2.1.h and Table 4.7.2.11 contain details concerning the section of duct work subject to inleakage verification, the test pressures, the test protocol, and the allowable inleakage. These details will be relocated to the Bases and TRM: d. CTS 4.7.2.2 details the parameters of the visual inspection (i.e.. cracking, debonding, and abnormal degradation). These details will be relocated to the Bases and TRM; and FERMI - UNIT 2 3 REVISION 8. 07/01/99l

DISCUSSION OF CHANGES 'ITS: SECTION 3.7.3 CONTROL ROOM EMERGENCY FILTRATION (CREF) SYSTEM L.2 CTS 4.7.2.2 requires an inspection of applied silicone sealant and a Special Report in the event abnormal degradation of the silicone . sealant on the inspected duct work is discovered. In the event of abnormal degradation.. the cause and corrective action is pursued in a timely manner. This also entails a determination of system l@ Operability which will dictate whether continued operation would be allowed. Additionally, depending on the impact on the system's function, the degradation may be reportable under 10 CFR 50.72 or 10 CFR 50.73. Since the activities required to be reported in the Special Report will be taken regardless of the' existence of the reporting requirement. and existing reporting requirements will dictate necessary reporting to the NRC. the ITS does not include this repotting requirement. This has no impact on safety since there is no change in the response to silicone degradation and the change will only eliminate an unnecessary resource burden on both Detroit Edison and the NRC. L.3 CTS 4.7.2.1.e.2 surveillance requires that each subsystem be j tested every eighteen months to show: (1) that the subsystem automatically switches to the required mode of operation, and (2) 4 that the control room pressure is maintained. The ITS also ) requires both subsystems be tested every 18 months to show automatic actuation (refer to ITS SR 3.7.3.4). However, the control room pressure requirement is a test of the integrity of the control room enclosure and can be verified by using either subsystem. Given the other subsystem filtration tests that must be performed every 18 months to demonstrate proper subsystem operation (refer to ITS SR 3.7.3.2). the control room enclosure test need only be verified once every 18 months using one subsystem. To add assurance of no undetected subsystem failures, this testing of the control room enclosure is required to be demonstrated by alternating the CREF subsystems each outage (i.e., on a Staggered Test Basis). RELOCATED SPECIFICATIONS .None FERMI UNIT 2-5 REVISION 8. 07/01/99l

CA E F [ " E ] System 8 3.7.13 BASES SURVE!LLANCE SR 3., 1 (continued) h REQUJREMENTS S. b,- moisture that has accumulated in the charejl as a result of ) humidity in the ambient air. _ {$y:t-- d., i::t:r; must be O of*O. cycl hg bdwu$ norms lly 6',t. operated fgy 2 10 continuous hours with the heater f p I upunkgod "energizedf *y t r dth::t 5::t:rs need only be operated - for215miTutestodemonstratethefunctionofthesystem SWh h md:Wa" Furthermore, the 31 day Frequency is based on the known blMa44d fil4ec inigt reliability of the equipment and the two subsystem y,. h%g g gndancy available. The SMcGatfD "fEST SAsa,5 lejvids thc 10-bour 4csWq ef ne rehnduf forHmie(+ka sh5ysh be. alknm4e# 004 AHe4em chx t.atA U Aq4en, 5 ackht each (AA-+ perh ir Opa,, 3.7.T.2 W 4 to koes oub 61 de-y SR Md c ycle. This SR verifies that the requi W L ] testing is - - - - performed in accordance with thej#entilation Filter Testing Program (VFTP) -** - M ser:-t ce 'b .C;. bi.w.$. jh; """E' ""tr #, via -.E '.'. 4. "The 4VFTPj includes L testing HEPA filter performance, charcoal adsorber IQ efficiency, minimum system flow rate, and the physical pro arties of the activated charcoal (gene'ral use and M foi owing specific operations). Specific test frequencies nd a i ional information are discussed in detail in the TmeN u' (f olehm*lvCS clost, seas, w Wg 7,5 i at on an actual orjsimulated initiation This SR verif signal,each(4..".EC'subsystemstartrandoperates. The g LOGICSYSTEMl'UNCT!6NALTESTinSR3.3.7.15everlapsthis SR to provide complete testing of the safety function. The J18] month Frequency is specified in Reference / SR 3.7. This SR verifies the integrity of the control room enclosure /,\\ and the assumed inlaakage rates of potentially contaminated \\ air. The control room positive pressure, with respect to / \\ potentially contaminated adjacent areas @ t.th.;- i;t M h,;,-is periodically tested to vertfy proper function a th "C".!C' System. During the emergency mode of Cgp_ operat on, thi HERE i;.e.iUffle the contro'I System is designed to slightlyincheswat room 2 positive pressure with respect t he turbin 5"i."" to

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DISCUSSION OF CHANGES ITS: SECTION 3.7.4 CONTROL CENTER AIR CONDITIONING (AC) SYSTEM LA.2 CTS 3.7.2 (LC0 and Action b.1) requires the Control Center AC system to be Operable and identifies what components are required for the Control Center AC' system. ITS 3.7.4 requires the Control Center AC system to be Operable, but does not define what equipment is required. This is acceptable because these details do not Y impact the ITS requirement to maintain the Control Center AC system lQ Operable. Therefore, this information will be adequately defined and controlled in the ITS Bases which require change control in accordance with ITS 5.5.10 Bases Control Program. These d? tails are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. TECHNICAL CHANGES LESS RESTRICTIVE " Specific" L.1 With the addition of the new Control Center AC System Specification, the time allowed with an inoperable AC subsystem has been increased from 7 days (CTS Actions b.2 and c.1) to 30 days (ITS Action A). The 7 day allowance was based upon the inoperability of a Control Room Emergency Filtration (CREF) subsystem, of which the AC subsystem was considered a component. The 30 day allowance in ITS is based upon only the AC subsystem being inoperable. The longer time period reflects that at least one AC subsystem is always operating thus giving additional assurance that a sole remaining subsystem will be Operable should it be needed during the 30 day period. Additionally alternative cooling means may be able to mitigate a complete loss of cooling. On this basis the longer out of service time is justified. In addition. the change is consistent with NUREG 1433, Rev.1. 6 FERMI UNIT 2 3 REVISION 8. 07/01/99l

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SpuiMon 375 RADIDACTIVE EFFLUENTS MAIN CONDENSER t1MITING CONDITION FOR OPERATION f ( O 3,'/.5 3.11.2.7 The gross radtoactivity rate of noble gases measured at the discharge of the 2.2 minute delay piping shall be limited to less than or equal to 340 millicuries /sec after 30 minute decay. OPERATIONALCONDITIONS1,f,and3*. /,2, APPLICABILITY: sum: /g t,,g/ With the gross radioactivity rate of noble gases at the the discharge of the 2.2 minute delay piping exceeding 340 millicuries /see after 30 minute 'A,2 decay, restore the gross ctivity rate to within its limit within 72 hours or be in at least TARTUP with all main steam lines isolated, within 0/##Ng gA.S /A00 Rct#cd A'd'. the next 12 hours. n' N s.7)F.S./ W 3.3.2 SURVEILLANCE REDUIREMENTS mi del uou in 0.11.2.7.2 The gross radioactivity rate of noble gases from the main condenser steam jet air ejector shall be determined to be within the limits o^f Specification 3.11.2.7 at the following frecuenciesrDy errorming isotop gnalysis f a representa e samole or ymses taken the disc e of t .2 1sinute 4elay pioinct Li41 f R 3,#7.g,/ a. At least once per 31 days, b Within 4 hours followino an incre' ate. 45 .a. um OT T2 m 6R 30*b 1 c:di:* '- "--i:craar greater than40%, after factortna out

1. T0 b increases cue 'to changes in THERMAL POWER ievel, in the nominal steady-state fission gas release from the primary coolant.

6 c. The provisions of Specification 4.0.4 are not applicable. 4l $/{ 3,7,(I N oTE 4 ?. 7. 5 wnen tne main canoenser air eaector is in coeration. AppieWig;q FERMI - UNIT 2 3/4 11 17 Amenoment No. /7. 82 PAGE 2-0F 02 i (fev ti

i DISCUSSION OF CHANGES ITS: SECTION 3.7.5 MAIN CONDENSER OFFGAS TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 4.11.2.7.2.b requires determination of gross radioactivity following an increase in offgas activity. In ITS SR 3.7.5.2. the amount of increase of offgas radiation before sampling is ' required, is changed from the CTS requirement of " greater than 50%" to include an. increase equivalent to 50%. This change is more restrictive since technically it increases the range of releases to be considered. However, no additional performances of the Surveillance would be expected since the increase is insignificant. TECHNICAL CHANGES L'ESS RESTRICTIVE " Generic" C k LA.1 CTS 4.11.2.7.2.b and CTS Table 4.4.5 1 Item 5 requires that gross l .y radioactivity rate is maintained within limits in addition to C detailing methods for performing this Surveillance, and methods for determining when an increase has occurred. ITS 3.7.5 requires that the gross radioactivity rate is maintained within limits, but does not define the details relating to the specific radioisotopes monitored, methods for performing the surveillance, and methods for determining when an increase has occurred. This is acceptable because these requirements do not impact the ITS requirement to T maintain the gross radioactivity rate within limits. Therefore. lk this information/ requirement will be adequately defined and controlled in the ITS Bases which require change control in accordance with ITS 5.5.10, Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. LA.2 CTS 4.11.2.7.1 Surveillance Requirement has been moved to the Offsite Dose Calculation Manual consistent with the direction provided in Generic Letter 89 01. This requirement can be adequately defined and controlled in documents which require change mntrol in accordance with ITS 5.5.1. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. FERMI, UNIT 2 2 REVISION 8. 07/01/99l =

O DISCUSSION OF CHANGES ITS: SECTION 3.7.6 MAIN TURBINE BYPASS SYSTEM ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting. and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWI) Standard Technical Specifications NUREG 1433, Rev. 1. A.2 CTS 3.7.9 Applicability requirement " 0PERATIONAL CONDITION 1 l when. " is_ removed and not included in the Applicability of ITS 3.7.6 since, with Thermal Power 2 25% RTP. the unit will always be in Mode 1. Therefore, it is unnecessary to state this requirement in the Applicability. Since the change is consistent with the intent of the CTS, this change is administrative with no impact on safety. A.3 CTS 3.7.9 requires that MCPR Actions be applied within one hour h when the Main Turbine Bypass System is inoperable, with the MCPR actions of CTS 3.2.3 requiring that the operating MCPR is determined to be within the MCPR limit within an additional hour. TogetP a this provides a total of two hours to restore compliance with bypass valve related MCPR limits. This is consistent with ITS 3.7.6, which also allows 2 hours to apply the MCPR limit with an inoperable Main Turbine Bypass System. A.4 CTS 3.2.3, Action b, allows an unrestricted " operation may continue" when MCPR limits for inoperable bypass valves are applied when the bypass valve (s) are inoperable. ITS LCO 3.7.6 implements this CTS action by stating this option as part of the LC0 statement. The effect is identical to the CTS action: therefore, the change is an administrative presentation preference only. TECHNICAL CHANGES MORE RESTRICTIVE None FERMI UNIT 2 1 REVISION 8. 07/01/99l

4 = DISCUSSION OF CHANGES ITS: SECTION 3.7.6 - MAIN TURBINE BYPASS SYSTEM TECHNICAL CHANGES LESS RESTRICTIVE " Generic" LA.1 CTS 4.7.9.b.1 requires the performance of a system functional test and defines how the surveillance test is to be performed. ITS SR 3.7.6.2 requires the performance of a system functional test, but does not identify how the surveillance is to be performed. This T-is acceptable because the methods 'of performing the surveillance o j C does not impact the requirement to perform the surveillance. Therefore, this information will be adequately defined and l,;ig controlled in ITS Bases which require change control in accordance T with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. LA.2 CTS 4.7.9.b.2 requires the performance of response' time testing and defines the acceptance criteria for response times. ITS SR 3.7.6.3 requires the performance of response time testing but does not define the acceptance requirements. This acceptance criteria is relocated to the Technical Requirements Manual (TRM). These details are not. required to te in the ITS to provide adequate protection of the public health and safety because the acceptance criteria does not impact the requirement to perform the surveillance test or the requirement for operability of the i turbine bypass system. Therefore, this information can be adequately defined and controlled in docunants which require I change control in accordance with 10 CFR 50.59. LA.3 CTS 3.2.3 Action a requires operators to " initiate corrective action within 15 minutes." ITS 3.7.6. Action A maintains the 2 hour completion time currently allowed to restore MCPR to within limits. but does not include the requirement to initiate action within 15 minutes. This is acceptable because the requirement to restore MCPR is maintained and the time requirement to initiate action does not impact the requirement to restore MCPR. Therefore, the requirement to initiate prompt action will be l ",j adequately controlled in the ITS Bases which require change i control in accordance with ITS 5.5.10. Bases Control Program. i These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to restore MCPR to within limits. FERMI UNIT 2 2 REVISION 8 07/01/99l

DISCUSSION OF CHANGES ITS: SECTION 3.7.7. SPENT FUEL STORAGE P0OL WATER LEVEL operations with loads. This is acceptable because suspension of crane operation does not impact the ITS Applicability for fuel movement and requirement to suspend fuel movement. Furthermore, crane operations will be addressed in the UFSAR. Therefore, this requirement can be adequately defined and controlled in the UFSAR. which requires change control in accordance with 10 CFR 50.59. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the mitigative features assumed for the DBA fuel handling accident. LA.2 CTS 3.9.9 Action requires movement of irradiated fuel to be suspended _and require fuel assemblies to be placed in a safe condition. ITS 3.7.7 Actions requires movement of irradiated fuel to be suspended, but does not specify where fuel assemblies being moved should be placed. This is acceptable because the movement of the fuel to a safe position is considered an acceptable and prudent step in the requirement to suspend fuel movement. o Therefore, this requirement will be adequately defined and l0 controlled in ITS Bases which require change control in accordance g with ITS 5.5.10. Bases Control Program. These details are not required to be in the,ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable. TECHNICAL CHANGES LESS RESTRICTIVE " Specific" None RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The Bases of the CTS for this Specification have been replaced by Bases that reflect the. format and applicable content of ITS 3.7.7 consistent with the BWR STS, NUREG 1433. Revision 1. FERMI UNIT 2 2 REVISION 8 07/01/99l

!L o f 7$ 1' / *> 3.7 PLANT SYSTEMS l 3.7.8 Emergency Diesel Generator Service Water (EDGSW) System l LC0 3.7.8 Four EDGSW subsystems shall be OPERABLE. l APPLICABILITY: When associated EDG is required to be OPERABLE. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more $0GSW A.1 Declare associated Immediately subsystems inoperable. EDG(s) inoperable. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.7.8.1 Verify each EDGSW subsystem manual, power 31 days operated, and automatic valve in the flow path, that is not locked. sealed, or otherwise secured in position, is in the correct position. SR 3.7.8.2 Verify each EDGSW subsystem pump starts 18 months automatically when the associated EDG starts. j FERMI'- UNIT 2 3.7 19 Rev 8 07/01/99

n t k Q EDGSW System I k B 3.7.8 8 3.7 PLANT SYSTEMS l B 3.7.8 Emergency Diesel Generator Service Water (EDGSW) System BASES BACKGROUND The EDGSW System is designed to provide cooling water for the removal of heat from the emergency diesel generators (EDGs). Each of the four EDGSW subsystems consists of one EDGSW pump supporting the cooling function for one EDG. l The EDGSW pump autostarts upon recei when power is available to the pump'pt of an EDG run signal s electrical bus. Cooling water is pumped from the RHR reservoirs (ultimate heat sink (UHS)) to the essential EDG components through an ~1ndividual EDGSW supply line. After removing heat from the components, the water is discharged into the associated RHR reservoir via the mechanical draft cooling towers (or via the cooling tower bypass line during col.d weather or testing). A complete description of the EDGSW System is presented in the UFSAR. Section 9.2.5 (Ref.1). APPLICABLE-The ability of the EDGSW System to provide adeq. uate SAFETY ANALYSES cooling to.the EDGs is an implicit assumption for the safety analyses presented in the UFSAR. Chapters 6 and 15 (Refs. 2 and 3. respectively). The ability to provide onsite emergency AC power is dependent on the ability of the EDGSW l System to cool the EDGs. The EDGSW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 The OPERABILITY of the EDGSW System is required to provide a coolant source to ensure effective operation of the EDGs in the event of an accident or transient. The OPERABILITY of each EDGSW subsystem is based on having an OPERABLE pump and an OPERABLE flow path through the associated EDG heat exchanger. An adequate suction source is not addressed in this LC0 since the minimum net positive suction head of the EDGSW pump is bounded by the requirements of LCO 3.7.2. "EECW/EESW System and UHS." l-l FERMI UNIT 2 B 3.7.8-1 Rev 8 07/01/99 1

o l EDGSW System B 3.7.8 BASES i APPLICABILITY The requirements for OPERABILITY of the EDGSW subsystems ar governed by the required OPERABILITY of the EDGs (LC0 3.8.1 "AC Sources-Operatin Sources-Shutdown"). g, " and LCO 3.8.2. "AC ACTIONS M 4 If one or more EDGSW subsystems are inoperable. the OPERABILITY of the ass of its cooling source.ociated EDG(sr is affected due to loss intended function and must be immediately declaredThe E inoperable. In accordance with LC0 3.0.6. this also Required Actions for LC0 3.8.1 or LCO 3.8.2. requ l -l SURVEILLANCE SR. 3JE REQUIREMENTS Verifying the correct alignment for manual. power operated, and automatic valves in the EDGSW System flow path provides assurance that the proper flow paths will exist for EDGSW System operation. locked, sealed or otherwise secured in position since t valves were ver,ified to be in the correct position prior to locking, sealing or securing. A valve is also allowed to be in the nonaccident position, and yet be considered in the to its accident position, within the required time. cor does not require any testing or valve manipulation: This SR mispositioned are in the correct position.it involves v

rather, such as check valves. apply to valves that cannot be inadverten The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governin operation, and ensures correct valve positions. g valve l FERMI - UNIT 2 B 3.7.8-2 Rev 8 07/01/99 1

EDGSW System B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued) l SR 3.7.8.2 This SR ensures that each EDGSW subsystem pump will automatically start to provide required cooling to the EDG when the EDG starts and the respective bus is energized. Operating experience has shown that these components usually 1-pass the SR when performed at the 18 month Frequency, which is based at the refueling cycle. Therefore, this Frecuency is concluded to be acceptable from a reliability stancpoint. l REFERENCES l'. UFSAR. Section 9.2.5. l 2. UFSAR. Chapter 6. ~ l 3. UFSAR. Chapter 15. I l l l l FERMI UNIT 2 B 3.7.8-3 Rev 8 07/01/99

$ PEC /fiU T 5-t PLANT SYSTEMS DIESEL CENERATOR COOLING WATER SYSTEN ,f LIMITING CONDITION FOR OPERATION h*?,g 3.7.1.4 - The dieseldiesel generator sha$enerator cooline water subsystem associated with each 7 1 be OPERABLE /9Tth each sub stem compriseo er; ~ lb.l a. OPERABLE diese generator coolin water pump, and b. n OPERABLE f1 path capable of ing suction from associated,- 1 associated di sel generator heay)(-.: hanger., ultimate heat nk and transferr :c ;ooling water th ugh the j APPLICABILITY: When the diesel generator is required to be OPERABLE. ACTION: With one or more diesel generator cooling water subsystems inoperable, declare the associated djesel generator inoperab,lej.,,u e we m.7 requ i.. 7, y {pe7iwouno.oy.,or .......,..yy..wabl g SURVEILLANCE REQUIREMENTS ' 7.:.0 Each of the above required diesel generator cooling water subsystems shall be demonstrated OPERABLE: 5g5.1.T.g-er At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position. 4r-At least once per 18 months by verifying that each pump starts g g y ),gl1 automatically upon receipt of a start signal for the associated diesel generator. l s l V g' w FERMI - UNIT 2 3/4 7-5 A PAGE / OF 01 gen $ ]

t DISCUSSION OF CHANGES ITS: SECTION 3.7.8 - EDGSW SYSTEM ADMINISTRATIVE l A.1 In the conversion of the Fermi 2 current Technical Specifications -(CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences.or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes. reformatting and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWt) Standard Technical Specifications NUREG 1433. Rev. 1. A.2 CTS 3.7.1.4 Action, in addition to requiring that the associated EDG be declared inoperable, explicitly requires "take the Action required by [the EDG Specifications)." ITS 3.7.8 Action ooes not retain the explicit direction to cascade to the EDG Specification Actions since LCO 3.0.6 adequately addresses this requirement in the event an ITS Actions requires declaring a system inoperable. This is consistent with CTS requirements. These changes are presentation preferences only, and therefore administrative with no impact on safety. TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES LESS RESTRICTIVE " Generic" LA.1 CTS 3.7.1.4 includes details relating to system design, function, and Operability for de EDG Cooling Water System. ITS 3.7.8 includes only a requirement for EDGSW Operability and does not include the details of subsystem design and specific Operability requirements. This is acceptable because these detaiis do not impact the requirement to maintain the EDG or EDGSW System Operable and the ITS definition for Operability ensures that all equipment required to maintain Operability is functioning. These details will be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety and are acceptable because these details do not impact the requirement to maintain the EDG or EDGSW System Operable. FERMI UNIT 2 1-REVISION 8 07/01/99l

DISCUSSIGN OF CHANGES ITS: SECTION 3.7.8 - EDGSW SYSTEM TECHNICAL CHANGES LESS RESTRICTIVE

• • Speci fi c

None RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.8.1 consistent with the BWR STS, NUREG 1433. Rev. 1. 4 h ..a FERMI - UNIT 2 2 REVISION 8. 07/01/99l

D h6DI? DER - f=Y 3.7 PLANT SYSTEMS-E04 75 ) 3.7 r '=1 :*r: ts.Ai Service Water ( SW) System LC0 3.7. The = :: System shall be OPERABLE. f.I (650cickd EDh APPLICABILITY: When t M is required to be OPERABLE. 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME i A. " S T G W Systent -- - ----NOTE---- inoperable. L .0.4 is not appl able. A.1 Align cooling wat 8 hours DG [lB) from a U t [1] plant i se ce water (PSW) subs om. A.2 Verify cool g water Once 31 days is aligned to [1B] roe a Unit [1 P3W s system. s gg Restore [1B) SSW 60 days ,l Systen t OPERABLE

status, w

Requ ed Ac on a 1 Declare,le. Imediately 1 o_4 Assoc ted co l e.. i.e.e,. Time no set. i BWR/4 STS 3.7-7 Rev 1, 04/07/95 3'

• • h

l iist-g>W Syste 3.7 SURVEILLANCE REQUIRENENTS /C% SURVEILLANCE FREQUENCY SR 3.7 .1 Verify eac -f4H-9SW System manual, 31 days f power operated, and automatic valve in the 4 7./OAh flow path, that is not locked, sealed, or othentise secured in position, is in the correct position. SR 3.7. 2 Vert

HR)::$SW tem pump starts 8 months g

automreally when = i;-) starts and= /\\f,7,INb) l anoug. _ + M r..p.;t ' = 0-gevey 1 O M 9 AM} BWR/4 STS 3.7-8 Rev 1, 04/07/95 (3hyst f*f + t

6 DG-fib 2-35W System B 3.7 g B 3.7 PLANT tytTrm Y I f, \\ B 3.7.~ WMDent**W)dDE' I'"' *t=% Service Water Diesel senerator W) System 8 f'b BASES BACKGROUND Th -tit $:5SW System is designed to provide. cooling water k fortheremovalofheatfromthgvu i '"' n th; .J q

w. ; c: ;::..; s m py n S* f :

W sy m s. [ lNSEllT 03fl.8-lq) Thk (IE.} Ft! pum(Autostart)t upon receipt ]a E0O Pe gemstart signal when power is available to the pump's electrical bus. Cooling water is pumped from the Ja'^-- '- "'-- : '; tb ae p=; ra' ;g +r th: ;;,,,,;;. a c- ;;;;;t; thr:;7, ti; !!" ::;;1; h;;de,. After removing m :.:- h,}he compongn,t,s, p gtb!*! N"" .=, w. =u z== water is dischargedf% L,

n. - =

"-=~ m \\ I FKGlLT f> 3 7 2-Ibj. .gz; 3:: =;9;;.m,;;; ;;_c.~ :..-m- ,,~r m y ...w._,- h.opecable[.A complete de iption of the DG AB)=SSW E yp 8 3/7g.-/g System is presented in th AR,Section.19. },(Ref. 1). APPLICABLE The ability o 44BHItW System to provide adequate SAFETY ANALYSES cooling to th

[dBk is an i it assumption for the safety analyses presented in t AR,Chaptersd61and(15[

(Refs. 2 and 3, respectively). e ability to proFide onsite emergency AC power is dependent on the ability of the (DG SW System to cool th g p i Th -itB3-S$W System satisfies Criterion 3 of the 2^- OO Pell;y 't:^----'_QR. 60 3r,(c)(zXii)) 1 LCO The OPERABILITY of th G-{dit):dW System is required to pr e a coolant source to ensure effective operation of 3PERA @ILITY of tlikh in th vent of an accident or transient. The th E G;(19)=g$W stem is 311n0 an _ OPEPABLEJu and an OPERABLE vh asssio+ Q.2. Anadeq(uat~esuctionsourceisnSAs.,, mi aisubcsqw Eae ressed in since the minimum th CD .35W pump is bounde, net positive suction hea d by the-JtSE requirement CO 3. 2, "{4lntt-Saruira hter 'P )]4ystemandKUlt ate Heat Sink (UHS){}. QEEct{/- EELh)) (continued) Rev1,04/07/95gt) BWR/4 STS B 3.7-14 (3%g d p Rc4 % Y

4 EDGSW System B 3.7.8 Insert B 3.7.8 la ... emergency diesel generators (EDGs).. Each of the four EDGSW subsystems consists of one EDGSW pump supporting the cooling function for one EDG. Insert B 3.7.8 1b ... RER reservoirs (ultimate heat sink (UHS)) to the - essential EDG components through an individual EDGSW supply line. Insert B 3.7.8-1c ... into the associated RHR reservoir via the mechanical draft cooling towers (or via the cooling tower bypass line during cold weather or testing). j FERMI - UNIT 2 Page B 3.7-14 (Insert) REVISION 8. 07/01/99l

[18) SSW System B 3.7 BASES (continued) APPLICABILITY The requirements for DPERABILITY of th m are governed by the required OPERABILITY of;UM; & r = ystem f. (LC0 3.B.1, 'AC Sources-0perating," and LCO 3.T.2, "AC Sources-Shutdown"). IONS A.1 P,3 rThe r.d Actions a swifi.d by a note indstating that the L 3.0.4 does not ly. As a result, a 10DE change is all when the DG )SSWSystemisinoperple,provided ) the [18)hasana quate cooling water supply from th [1] PS h on ew' (p5bsJ Au If W prystem noperable, the OPERABILITY of l Osociakk t .:, tY 60 6 ) Ifromthe System of Unit

1 Continued operation is allowed r 60 days if the W ILITY of a Unit 1 PSW

~ System with respect to its apability to provide coo ng to the [1B), can be verif This is accomplished y ali ing cooling water DG [18) from the Unit I W System w in 5 hours and ver ing this lineup once av y 31 days. e 8 hour Completto rise is based on the ti required to reasonably complet he Required Action, and low probability of an vent occurring requiring LIB;lduring this period. Th 31 day verification of e Unlt [1] PSW lineup to the [lB) is consistent with he PSW valve lineup SRs. e 60 day Completion Ti o restore ',he DG [18) SSW stem to OPERABLE status llows sufficient ti to repair e system,.yet prevents definite operation h cooling w er provided from the Un [1]PSWSystem. i Id I If ooling water cannot be e available to th DG[18] hin the B hour Comple on Time, or if cool i, water nnot be verified to aligned to DG [18) ona' Unit [1 PSW subsystem as reau ed hv the 31 dav ve cation '< Reauired Actio @ ( cannot perform its intended function and must'be diately declared inoperable. In accordance with LCO 3.0.6, this also requires entering into the Applicable Conditions and Required Actions for LCO 3.B.1 . wit 4~"y, th M l!") !!" !y += it -{ or LCO 3.B.2. (continued) BWR/4 STS B 3.7-15 Rev 1, 04/07/ gi) (3ube T f, Y t

g DG [18] SSW System B 3.7. 8 BASES ACTIONS L1 continued / restor o OPERABLE atus withi 60 days, DG B] a f0 immedi ely declare noperable. SURVEILLANCE SR 3.7 1 i REQUIREMEhTS Verifying the correct ali t for manual, power operated. and automatic valves in t 2232-SSW System flow path j g ides assurance that t roper flow paths will exist for -fES$W System operation. This SR does not apply to lves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A - valve is also allowed to be in the nonaccident position, and yet be considered in the correct position provided it can be automatically realigned to its accident position, within the required time. This SR does not require any. testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply in valves that cannot be inadvertently aisaligned, such as check valves. The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions. Q SR 3.7.T.2 sub.s i This SR ensures that -Li em pump will A utomatically start to provide required cooling to the OP/1. (EipG when th fili-starts... th; n;;;;O;; ir is. Operating experience has shown that these components usually passtheSRwhenp?:formedatthefl8 nth Frequency, which is based at the refueling cyc1. Therefore,'this Frequency is concluded to be acceptable from a reliability standpoint. (continued) Rev 1, 04/07/95 [ L BWR/4 STS B 3.7-16 9bWW b (W % l

DG [1B] SSW System G 3.7. 4 8ASES (continued) 1.kFSAR,Section REFERENCES 2. FSAR, Chapter [6). 3.gFSAR, Chapter {15g l 0 1 Rev 1, 04/07 95 gi) BWR/4 STS B 3.7-17 ks Y"p f Rsv3Il]

[ JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.7.8 - EDGSW SYSTEM NON-BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NtREG 1433 to reflect Fermi 2 current licensing basis: including design features existing license ~ requirements and comitments. Additional rewording. reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. Refer to CTS Discussion Of Changes to the related requirement for a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for additional detail. P.4 The reference to the EC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification " split" criteria found in 10 CFR 50.36(c)(2)(ii). GENERIC CHANGES None b FERMI UNIT 2 1 REVISION 8. 07/01/99l

1 NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.7.8 - EDGSW SYSTEM There are no TECHNICAL CHANGES LESS RESTRICTIVE for this Section: as such, specific evaluations for No Significant Hazards Considerations are not needed. O 1 9 FERMI UNIT 2 1 REVISION 8, 07/01/99 l

1 INSERT THIS PAGE IN FRONT OF VOLUME 11 Volume 11: CTS MARKUP COMPILATIONc Remove Replace 3.7.5 CTS M/U (3/4 4-18) pg 1 of 2 Rev 8 3.7.2 CTS M/U (3/4 7-3) pg 1 of 9 3.7.2 CTS M/U (3/4 7-3) pg 1 of 9 Rev 8 3.7.8 CTS M/U (3/4 7-5) pg 1 of 1 Rev 8 3.7.5 CTS M/U (3/411-17) pg 1 of 1 3.7.5 CTS M/U (3/411-17) pg 2 of 2 Rev 8 I Rev 8 07/01/99

%%Q ~ %. N Q ~ g ^< k @ R h Q g w$ v sa S w N D O E r I R o TEI t ILU c DPQ 4 a NME e OAR r CS S e LHI 3 c ACS n NIY i OHL s s IWA 3 t T N 2 d i ANA RI 2 2 e m s i E s p l P 1 1 a l O A I 1 I I l s I e t W i e lG v n 0 a i t h h iP t n N i S ee 0 w I ehrd l wt oe l o S s Y r t. t r A t L u ib e gR i R A s o m bnEu E d s s P e N r s h hciN ,iWq A u y t il 0 woe y O r o a n 4f l eoPr a o h d o i ai ll d R t DN m rc t pl Ls I s eesA moA a 1 W e A 2 1 S 7 3 6 ppd afM 3 O r E sey s R, P I P S r r r e eb sEl r s L e 'f i Y e e e cec erHe L p p p nhxd nut vc p o 1 M AY ot ee oo e m A 5 S MC e e e r hnlN e s e AN c c c t r yi t i O c y t E n n n setu ss sI n a s Y 4 t a eat o d y T DU o o o avi< NO eeve e d g gC s 4 I AE t t t l nir l nn A t 0 V R s s s et aaf s 2 t E I EF a a a thcs t hfy a n L T L e e e Awaa A2 cob e d a B C l n l A A P l l l a o T M ) t o C A t t t ) F -a b A D c I S A A A / P y F I I L r C m / .a E 2rm P ei S f gr T e, onp n v3 o N L io ml e A y3 u h an mrt n t O y o a t e io O t i n e f iX n f C i t i n .f t iso v Ea m i O nt mr Y i Sr r d as uy R t Ot e o n ua aot A c Dn t I a qe hi M A e e l r v I rc D r f e8i R a on o o tJ t4t P m f o [ f f c m C / a s r i s a ara s i u o G i1 o s io nf c s3 f s y ct - e i T d y1 y l n r klf N nn l - l l a isK aai E ao aI a a m nrt t cc M i n c n Ae nd ie ES at AT i A i en et p RI t a N m b cp ma bis US en cE e c imi r SY Bi i L h i A pa r5 ote AL m pA c p r7 o S ~ y3 tbh EA sr oV i t o o t s ut osaA l MN se tI efU-I X pti i es A ot oU d o saee l l F re sQ a s OD GD IE R i Jr3 mst N b aan EA Sl U p P S Y 5 T l 2 3 r! l e A!*EU~ wD ? "' 5 ig l g d t 7 k 3 3 de / 'g 5 m hgf w OT oy T T

SWctFi es,sorJ 3 9,2. PLANT SYSTEMS gjg g gjg(Qg 3,g,j } Cu $ Ci Aca/W 0 5') EMEpGENCY E001PMENT C00t1NG WATER SYSTEM Al.':0 F 1IMITING CONDITION FOR OPERATION v LCO 3.7.1.2 Two E h ac aP imergency equipment cooling water (EECW) system 3,7 2,,, subsystems shall be UPLMhit each subsystem w priaru of. fa. e OPERABLE EEC ump, and 'b. An OPERABLE f w path capable of moving heat from e associat safety-rela,d equipment 7 APPLICABILITY: OPERATIONAL CON 0!TIONS 1, 2, 3, ACTION: In OPERATIONAL CONDITION 1, 2 or 3, with one EECW system subsystem a. inoperable: j 1. kithin2 hours: see < a) Verify that all required systems, subsystems, trains, Me components and devices that depend.upon the remaining OPERABLE EECW system subsystem are also OPERABLE, and 55 t Verify that the ADS

• is OPERABLE.

5<c Ot erwise", be in at least H0T SHUTDOWN within the next 12 hours < Sped ficah55 and in COLD SHUTOOWN within the following 24 hours. /jc.rw [2. Declare the associateo safety-rri u ru equipment inoperable and ) Nes e d L L

• • th' ^C "5 " a"id 6' th'
• "'*b SDiM V" Restore the inoperable EECW system subsystem to OPERABLE A C TierJ C

,7. status within 72 hours or be in at least HOT SHUTOOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 /t C S M D hours. b. InOPERATIONALCONDITION4or5,determinetheOPERABILITYofthel safety-relatedequipmentassociatedwithaninoperableEECWsystem) subsyste. and take any ACTION 5 required by the applicable y Specifications. f i M (*ADSisnotrequiredtobeOPERABLEwhenreactorsteamdomepressureisless S #C[ (thanorequalto150PSIG. f

• • Except for an inoperable Drywell tooling Unit required by Specification S tL 3.7.11 or an inoperable primary containment oxygen monitoring instrumentation speckenlig channel, required by Specification 3.3.7.5, that cepends on the remaining OPERABLE EECW system subsystem, in these cases, take the ACTION required by i

65 Specification 3.7.11 for the inoperability of both required Drywell Cooling Units or Specification 3.3.7.5 for the inoperability of both required primary containment oxygen monitoring instrumentation channels. L FERMI UNIT 2 3/4 7 3 Amendment No. JJ, 30,132 h PAGE l 0F 09 [(ed 8

6 P M tFi ort br0 5 l $ PLANT SYSTEMS DIESEL CENERATOR COOLING WATER SYSTEM / LIMITING CONDITION FOR OPERATION

1. • 7'g 2.7.1.4-The diesel enerator cooline water subsystem associated with each diesel generator sha 1 be OPERABLF,fWth each subs / stem comprisea en I a.

OPERABLE diese generator coo 11 water pump, and b. n OPERABLE f1 path capable of king suction from associated i ultimate heat nk and transferr g cooling water th ugh the j 1 associated di sel generator hea exchanger. f APPLICABILIJ,1: When the diesel generator is required to be OPERABLE. EllQ!i: With one or more diesel generator cooling water subsystems inoperable, declare the associated diesel generator inoperablef nu av me m. p nryvi...).,g e7 6.u un o.oy.4 ..... y..ry. wabl v1 SURVEILLANCE REOUIREMENTS 4.7.:.0 Each of the above required diesel generator cooling water subsystems shall be demonstrated OPERABLE: N 3 l'I' ! -+r At least once per 31 days by verifying that each valve (manual. power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position. ~ -br-At least once per 18 months by verifying that each pump starts g $t),g,L automatically upon receipt of a start signal for the associated diesel generator. O-w' V g) FERMI - UNIT 2 3/4 7-5 PAGE / OF 01 gev $

SpedMon 375 RADIDACTIVE EFFLUENTS MAIN CONDENSER LIMITING CONDITION FOR OPERATION /,,Co 3.7. 5 3.11.2.7 The gross radioactivity rate of noble gases measured at the discharge of the 2.2 minute delay piping shall be limited to less than or equal to 340 millicuries /sec af ter 30 minute decay. OPERATIONAL CON 0!TIONS 1.f and 3*. /,2., APPLICABILITY: ACTION: /gy,og/ With the gross radioactivity rate of noble gases at the the discharge of Q the 2.2 minute delay piping exceeding 340 millicuries /sec after 30 minute ,M,2 decay, restore the gros tivity rate to within its limit within 72 hours or be in at least TARTU with all main steam lines isolated, within p0 RefheaAcf. 0 # the next 12 hours.~ g),} ons le.7)F.5./ W 3.3.2 SURVEILLANCE REOUTREMENTS si dIt1 a ou in ?.;;.2.7.; The gross radioactivity rate of noble gases from the main condenser staan jet air ejector shall be determined to be within the limits of ^ Specification 3.11.2.7 at the following frecuenciesroy errormin isow Analysis f a representa e sample of ymses tamen ' the dise e of t .2 Winute Aelay pipino f R 3,7.g,/ a. At least once per 31 days, ty Within 4 hours following an increate. E ..c.c.a

m. a C T T2 60 3.7'5' 1

@a664MaHea+4 crena greater inangC*. af ter f actorino out & 98 L increases out to enanges in THERMAL POWER ievel, in tne nominal steady-state fission gas release from the primary coolant. 6 c. The provisions of Specification 4.0.4 are not applicable. g SR 3,7.fi N o72 ?.75 wnen tne main concenser air eaecter is in ooeration. Applem;g;q s FERMI UNIT 2 3/4 11 17 Amenoment No. 47, E2 PAGE 2-0F 02. RevE 1

INSERT THIS PAGE IN FRONT OF VOLUME 12 Volume 12: IMPROVED TECHNICAL SPECIFICATIONS Remove Replace 3.7.8 ITS pg 3.7-19 Rev i l ) Rev 8 07/01/99

W h f D L3.7 PLANT SYSTEMS 'l 3.7.8 Emergency Diesel Generator Service Water (EDGSW) System q

j. LCO 3.7.8 Four EDGSW.silbsystems shall be OPERABLE.

'l. APPLICABILITY: When associated EDG is required to be OPERABLE. ' ACTIONS 4 CONDITION REQUIRED ACTION COMPLETION TIME ' A.- One or more-EDGSW A.1 Declare associated Immediately subsystems inoperable. .EDG(s) inoperable. 4 SURVEILLANCE REQUIREENTS SURVEILLANCE FREQUENCY l SR 3.7.8.1 Verify each EDGSW subsystem manual, power 31 days operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position. is.in the j correct position. SR 3.7.8.2 Verify each EDGSW subsystem pump starts 18 months automatically when the associated EDG starts. i l ' FERMI ~ UNIT.2 3.7 Rev 8. 07/01/99

INSERT THIS PAGE IN FRONT OF VOLUME 13 Volume 13: IMPROVED TECHNICAL SPECIFICATIONS BASES 4 Remove Replace B 3.7.1 ITS pg B 3.7.12 Rev 0 B 3.7.1 ITS pg B 3.7.1-2 Rev 8 B 3.7.1 ITS pg B 3.7.1-3 Rev 0 B 3.7.1 ITS pg B 3.7.1-3 Rev 8 B 3.7.1 ITS pg B 3.7.1-6 Rev 0 B 3.7.1 ITS pg B 3.7.1-6 Rev 8 B 3.7.2 ITS pg B 3.7.2-1 Rev 0 B 3.7.2 ITS pg B 3.7.2-1 Rev 8 B 3.7.2 ITS pg B 3.7.2-5 Rev 0 B 3.7.2 ITS pg B 3.7.2-5 Rev 8 B 3.7.3 ITS pg B 3.7.3-7 Rev 0 B 3.7.3 ITS pg B 3.7 3-7 Rev 8 B 3.7.8 ITS pg B 3.7.8-1 Rev 8 B 3.7.8 ITS pg B 3.7.8-2 Rev 8 B 3.7.8 ITS pg B 3.7.8-3 Rev 8 s I i Rev 8 07/01/99

w RHRSW System l B 3.7.1 BASES APPLICABLE The RHRSW System removes heat from the suppression pool to SAFETY ANALYSES-limit the suppression pool temperature and primary containment pressure following a LOCA. This ensures that the primary containment can perform its function of limiting the release of radioactive materials to the environment following a LOCA. The_ ability of the RRSW System to support long term cooling of the reactor or primary containment is discussed in the UFSAR Chapters 6. 9. and 15 (Refs

2. 3. and 4. respectively). These analyses explicitly assume that the RESW System will provide adequate cooling support to the equipment required for safe shutdown. These analyses include the evaluation of the long term primary containment response after a design basis LOCA.

~ The safety analyses for long term cooling were performed for various combinations of RHR System failures. The worst case single failure that would affect the performance of the i I RHRSW System is any failure that would disable one subsystem of the RHRSW System. As discussed in the UTSAR. 'OAl Section 6.3.2.14 (Ref. 5) for these analyses, manual initiation of the OPERABLE RRSW subsystem and the associated R m System is assumed to occur 20 minutes after a DBA. The RESW flow assumed in the analyses is initially 9000 gpm with two pumps operating in one loop. The 9000 gpa initial RESW flow will decrease with time due to the RHR Reservoir evaporative and drift losses. This analysis showed a peak suppression )ool temperature of 1%.5'F. This temperature is less than t1e suppression pool temperature of 198'F used in core spray and RHR net positive suction head margin calculations. The maximum suppression chamber )ressure was found to be 18.3 psig. These values are well >elow the design temperature of 281*F and maximum allowable pressure of 62 psig. The RHRSW System satisfies Criterion 3 of 10 CFR 50.36(c)(2'(ii). i ) ) J l FERMI - UNIT 2 B 3.7.1 - 2 Revision 8. 07/01/99

I RHRSW System B 3.7.1 BASES j 1 LCO Two RHRSW subsystems are required to be OPERABLE to provide the required redundancy to ensure that the system functions { to remove post accident heat loads, assuming the worst case single active failure occurs coincident with the loss of offsite power. An RESW subsystem is considered OPERABLE when: s .L a. Two pumps are OPERABLE: and El b. An OPERABLE flow path is capable of taking suction from the RHR Reservoir and transferring the water to the RHR heat exchangers at the assumed flow rate and returning the water to the Rm Reservoir via the cooling tower or cold weather bypass valves. An adequate suction source is not addressed in this LC0 since the minimum net positive suction head (corresponding to a submergence at an elevation of 554.6 ft) is bounded by the 580 ft elevation requirements of LCO 3.7.2, " Emergency Equipment Cooling Water (EECW)/ Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (VHS)." APPLICABILITY In MODES 1, 2, and 3, the RHRSW System is required to be OPERABLE to support the OPERABILITY of the RHR System for primary containment cooling (LCO 3.6.2.3, " Residual Heat Removal (RHR) Suppression Pool Cooling" and decay heat removal (LCO 3.4.8. " Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown"). The Applicability is therefore consistent with the requirements of these systems. In MODES 4 and 5, the OPERABILITY requirements of the RHRSW System are determined by the systems it supports. ~ l FERMI UNIT 2 B 3.7.1 - 3 Revision 8. 07/01/99

RHRSW System B 3.7.1 BASES ACTIONS (continued) SURVEILLANCE SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for RESW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing or securing. A valve is also allowed to be in the nonaccident position. and yet considered in the correct position provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system. This SR does not require any testing or valve manipulation: rather it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently 4 misaligned, such as check valves. The 31 day Frequency is based on engineering judgment is consistent with the procedural controls governing valve operation, and ensures correct valve positions. REFERENCES 1. UFSAR. Section 9.2.5. 2. UFSAR. Chapter 6. 3. UFSAR, Chapter 9. 4. UFSAR, Chapter 15. 5. UFSAR. Section 6.3.2.14. ! FERMI UNIT 2 B 3.7.1 - 6 Revision 8. 07/01/99

EECW/EESW System and UHS B 3.7.2 i B 3.7 PLANT SYSTEMS. B 3.7.2 Emergency Equipment Cooling Water (EECW)/ Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (VHS) BASES BACKGROUND The EECW/EESW System (Ref.1) is designed to provide cooling water for the removal of heat from equipment, such as residual heat removal (RHR) and Core Spray (CS), pump coolers, and room coolers for Emergency Core Cooling System and other safety related equipment, required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient. - Components cooled by each EECW subsystem are normally cooled by the Reactor Building Closed Cooling Water (RBCCW) system. which cools various plant equipment primarily in the Reactor Building. An EECW subsystem contains a single 1450 gpm Y nominal capacity pump, a heat exchanger, a make up tank. valves piping, and associated instrumentation. Upon I receipt of a loss of off site power, a high drywell pressure signal, or low RBCCW System pressure, both EECW subsystems are activated. Upon activation, the EECW ) ump starts, the EECW loop isolates from the remainder of t1e RBCCW system, and other system valves reposition as needed to isolate non-essential loads and configure the system for emergency operation. Each EECW subsystem's heat exchanger is cooled by the same division's EESW subsystem. The EESW subsystem contains a i single 1600 gpm nominal capacity pump that pumps from the division's RHR Reservoir through the EECW subsystem's heat exchanger and returns to the RHR Reservoir. Each EESW l subsystem functions to cool the associated EECW subsystem. The EESW pump automatically starts on the same actuation signals as the EECW System. The two EECW/EESW subsystems are separated from each other so that failure of one subsystem will not' affect the OPERABILITY of the other subsystem. The UHS (Ref.1) is provided by a single highly reliable 1 water supply in the form of the RHR reservoirs and a means { of heat rejection in the form of mechanical draft cooling towers. The UHS consists of two one-half capacity reinforced concrete reservoirs each with a capacity of 3.41 X 10' gallons of water. corresponding to an elevation of 583 feet. The two reservoirs are connected by two s j FERMI UNIT 2 B 3.7.2 - 1 Revision 8. 07/01/99

o EECW/EESW System and UHS B 3.7.2 BASES ACTIONS (continued) D.1 and D.2 If the EECW/EESW subsystem cannot be restored to OPERABLE status within the associated Com)letion Time, or both EECW/EESW subsystems are inoperaale for reasons other than Condition A, or the UHS is determined inoperable for reasons other than Conditions A and B. such.as not meeting the combined water volume or average water temperature requirement, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the -required unit conditions from full power conditions in an orderly manner and without challenging unit systems. SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies the water level in each RHR reservoir to be sufficient for the proper reservoir heat removal capability and long-term cooling capability (net positive suction head and pump vortexing are considered in determining this l limit). If each reservoir meets the 25 foot level limit j (which equates to a water volume of 2.990.000 gal or 580 ft j Ml elevation) then the average reservoir level is known to be ) met without also doing a specific calculation. If either 1 reservoir does not mset the water level requirement, that $k reservoir is inoperable. Verification of the UHS combined water volume is required to assess the OPERABILITY of the ) entire UHS. This ensures that the heat removal capability i of the UHS is within the assumptions of the long-term cooling analysis. The 24 hour Frequency is based on 3 operating experience related to trending of the parameter variations during the applicable MODES. SR 3.7.2.2 Verification of the average water temperature in each reservoir, both individually and combined, ensures that the heat removal capability of the reservoirs and UHS are within the assumptions of the long term cooling analysis. The 24 hour Frequency is based on operating experience related to trending of the parameter variations during the applicable MODES. j j FERMI UNIT 2 B 3.7.2 - 5 Revision 8. 07/01/99 j

CREF System B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued) Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available. The STAGGERED TEST BASIS requires the 10 hour testing of the redundant portions ~ of the subsystem be alternated each 31 day test such that each redundant portion is operated for 10 hours each 62 day test cycle. 1 SR 3.7.3.2 i This SR verifies that the required CREF testing is performed h in accordance with the_ Ventilation Filter Testing Program 'l (VFTP). The VFTP includes testing HEPA filter performance. E charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP. The Note for this SR provides an allowance to delay entry into the associated Conditions and Required Actions for up to 6 hours in MODES 1, 2. and 3. This allowance prevents intentional entry into LCO 3.0.3 that would otherwise be caused by tests required by the VFTP. The tests that may be required while operating in MODE 1. 2. or 3 are: 1) the periodic. charcoal sample: and 2) tests and samples required after exposing the filtration system to ventilation from painting, fire, or chemical release. Other VFTP required surveillances can be scheduled when the plant is not operating in MODE 1, 2. or 3. SR 3.7.3.3 I This SR verifies that the silicone sealant applied to CREF i system duct work outside of the Control Room envelope has not degraded. The duct work of concern received a general coating of sealant on the duct seams. This includes a visual inspection for cracking, debonding, and other. abnormal degradation of the applied silicone sealant. Such degradation could be indicative of lack of duct integrity. Since a portion of the duct work inspected is at negative i pressure under postulated system operation during accident conditions, the loss of duct integrity could result in excessive in leakage of radioactive air during an accident. Only duct work for which in-leakage does not receive full l ) j' FERMI UNIT 2 B 3.7.3 - 7 Revision 8. 07/01/99

e e 4, ipM @Q LOGSW System ,% / B 3.7.8 B 3.7 PLANT SYSTEMS l B 3.7.8 Emergency Diesel Generator Service Water (EDGSW) System BASES BACKGROUND The EDGSW System is designed to provide cooling water for the removal of heat from the emergency diesel generators (EDGs). Each of the four EDGSW subsystems consists of one EDGSW pump supporting the cooling function for one EDG. l The EDGSW pump autostarts upon receipt of an EDG run signal when power is available to the pump's electrical bus. Cooling water is pumped from the RHR reservoirs (ultimate heat sink (VHS)) to the essential EDG components through an - individual EDGSW supply line. After removing heat from the components the water is discharged into the associated ~ 'iR reservoir via the mechanical draft cooling towers (or via the cooling tower bypass line during cold weather or testing). A complete description of the EDGSW System is presented in the UFSAR. Section 9.2.5 (Ref. 1). APPLICABLE The ability of the EDGSW System to provide adequate SAFETY ANALYSES cooling to the EDGs is an implicit assumption for the safety analyses presented in the UFSAR, Chapters 6 and 15 (Refs. 2 and 3, respectively). The ability to provide onsite emergency AC power is dependent on the ability of the EDGSW System to cool the EDGs. l The EDGSW System satisfies Criterion 3 of 10 CFR l 50.36(c)(2)(ii). LC0 The OPERABILITY of the EDGSW System is required to provide a coolant source to ensure effective operation of the EDGs in the event of an acdident or transient. The OPERABILITY of each EDGSW subsystem is based on having an OPERABLE pump and an OPERABLE flow path through the associated EDG heat exchanger. An adequate suction source is not addressed in this LC0 since the minimum net positive suction head of the EDGSW pump is bounded by the requirements of LCO 3.7.2. "EECW/EESW System and UHS."

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O l EDGSW System B 3.7.8 BASES-APPLICABILITY . The requirements for OPERABILITY of the EDGSW subsystems are governed by the required OPERABILITY of the EDGs (LCO 3.8.1 "AC Sour Sources ces-Operating." and LC0 3.8.2. "AC Shutdown"). ACTIONS M If one or more EDGSW subsysten are inoperable. the OPERABILITY of the ass of its cooling source.ociated EDG(s)'is affected due to loss intended function and must be immediately declaredThe EDG( inoperable. In accordance with LC0 3.0.6. this also Required Actions for LC0 3.8.1 or LC0 3.8.2. requires 1 l SURVEILLANCE SR 3.7.8.1 REQUIREMENTS Verifying the correct alignment for manual power operated and automatic valves in the EDGSW System flow path provides assurance that the proper flow paths will exist for EDGSW System operation. valves sealed or otherwise secured in position since thes locked locking, sealing, or securing.were verified to be in the correct position A valve is also allowed to be in the nonacr.ident position, and yet be considered in the correct position prov1ded it can be automatically realigned to its accident position. within the required time. does not require any testing or valve manipulation: This SR mispositioned are in the correct position.it involves ver rather. such as check valves. apply to valves that cannot be inadvertently m consistent with the procedural controls governinThe operation, and ensures correct valve positions. g valve j FERMI - UNIT 2 B 3.7.8-2 Rev B. 07/01/99

o EDGSW System B 3.7.8 BASES SURVEILLANCE REQUIREMENTS (continued) l SR 3.7.8.2 This SR ensures that each EDGSW subsystem pump will automatically start to provide required cooling to the EDG when the EDG starts and the respective bus is energized. Operating experience has shown that these components usually l pass the SR when performed at the 18 month Frequency, which is based at the refueling cycle. Therefore. this Frequency is concluded to be acceptable from a reliability standpoint. l REFERENCES -1. UFSAR. Section 9.2.5. l 2. UFSAR. Chapter 6. l 3. UFSAR, Chapter 15. I I l j FERMI UNIT 2 B 3.7.8-3 Rev 8. 07/01/99 u ...,}}