Text

Proposed Tech Specs Section 3.6,converting to ITS
	ML20206M112
Person / Time
Site:	Fermi
Issue date:	05/07/1999
From:	; DETROIT EDISON CO.
To:	;
Shared Package
ML20206M111	List: ML20206M112; NRC-99-0045, Forwards Rev 5a to Fermi 980403 Submittal,Converting TS to Its.Encl Rev Provides Remaining Responses to NRC RAIs Re ITS Section 3.6 Contained in NRC 990211 Rai.Brief Abstract of Changes & Responses to Rai,Encl;
References
	NUDOCS 9905140193
	Download: ML20206M112 (150)
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PCIVs 3.6.1.3 3.6 CONTAINENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs) i LC0 3.6.1.3 Each PCIV, except reactor building to suppression chamber vacuum breakers, shall be OPERABLE.

.k l APPLICABILITY: MODES 1, 2 -and 3.

When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1. " Primary Containment Isolation Instrumentation."

ACTIONS

$ ..................................... NOTES- --. - -. --- - --- - -

4, Penetration flow paths may be unisolated intermittently under Q l 1. administrative controls.

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

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

4. Enter applicable Conditions and Required Actions of LC0 3.6.1.1, " Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria in MODES 1, 2. and 3.

CONDITION REQUIRED ACTION COMPLETION TIME 5

-f A. -

NOTE- - -

A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except 7 Only applicable to )enetration flow path for main steam penetration flow paths d with two PCIVs.

)y use of at least one closed and line g ......................

de activated M automatic valve, One or more closed manual valve, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main penetration flow paths blind flange, or steam line 4 with one PCIV check valve with flow lif' inoperable, except due through the valve to leakage not within secured.

.k limit.

9905140193 990507 PDR P ADOCK 05000341 (continued)

PDR

, e l FERMI -. UNIT 2 3.6 7 Revision Sa, 05/10/99 I

PCIVs 3.6.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 - . .

-NOTES- - -

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, )

sealed, c otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days

. penetration flow path for isolation is isolated. devices outsiae primary containment ANQ Prior to entering MODE 2 or 3 from MODE 4, if primary containment was s

!J de inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment

, (continued) a "-

l FERMI UNIT 2 3.6 8 Revision Sa, 05/10/99 i

F-

4 PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 4

f B. -

NOTE - -

B.1 Isolate the affected I hour

. Only applicable to aenetration flow path

'T penetration flow paths byuseofatleast

- with two PCIVs. one closed and Q ............. ........

de activated automatic valve, One or more closed manual valve, penetration flow paths or blind flange.

with two PCIVs i

La inoperable, except due to leakage not within limit.

(continued) l FERMI UNIT 2 3.6 9 Revision Sa, '05/10/99

,r

l PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. -- - - NOTE-- - ---

C.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except Only applicable to >enetration flow path for excess flow penetration flow paths )y use of at least check valves with only one PCIV. one closed and (EFCVs) and

...................... de activated penetrations

' automatic valve. with a closed One or more closed manual valve. system penetration flow paths or blind flange.

with one PCIV E

$ inoperable except due to leakage not within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for y

-- limit. EFCVs and i penetrations with a closed Q a system w

C.2 ------- NOTES - --- -

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed. or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

(continued)

. m.

l FERMI - UNIT 2 3.6 10 Revision Sa, 05/10/99

PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more secondary D.1 Restore leakage rates 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for b containment bypass to within limit. leakage on leakage rate. M5!V hydrostatically leakage rate purge tested line valve leakage rate, hydrostatically tested N ANQ line leakage rate, or EFCV leakage rate not 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for a within limit. secondary contalnment la, bypass leakage e

E k' 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV l leakage M

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for purge valve leakage M

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for yl EFCV leakage 5

gl E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

- associated Completion S Time of Condition A. M 4 B. C, or D not met in g MODE 1, 2. or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

=>

l FERMI UNIT 2 3.6 11 Revision Sa. 05/10/99

PCIVs l 3.6.1.3 I ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 4 l

I

%l F. Required Action and F.1 Initiate action to Immediately )

M associated Completion isolate RHR-Shutdown l Y Time of Condition A. Cooling System. 1 Fl B, C. or D not met for

.L RHR SDC PCIV(s) {}R required to be Qj OPERABLE during MODE 4 '2

r. Initiate action to Immediately or 5. restore valve (s) to OPERABLE status.

l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

~

SR 3.6.1.3.1 ----- ---- - -NOTE --- ------- ---

Not required to be met when the isolation

= valves for one purge or containement J. pressure control supply line and one ,

purge or containement pressure control

{

exhaust line are open for inerting, de-inerting, pressure control. ALARA or air quality considerations for personnel entry, or Surveillances that require the i valves to be open.

~ Verify each drywell and suppression 31 days T

' chamber purge system and containment pressure control isolation valve is closed.

(continued) l

.s

-l FERMI - UNIT 2 3.6-12 Revision Sa,'05/10/99

\

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.2 ---- -- -- - - NOTES - -- --- - - --

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation 31 days manual valve and blind flange that is i

M located outside primary containment and '

I is not locked, sealed, or otherwise g secured and is required to be closed during accident conditions is closed.

SR 3.6:1.3.3 ---

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

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify-each primary containment manual Prior to F) isolation valve and blind flange that is entering MODE 2 T located inside primary containment and is or 3-from not locked, sealed, or otherwise secured MODE 4 if and is required to be closed during primary ;

accident conditions is closed. containment was de-inerted while in 1 MODE 4, if not performed within the previous 92 days

- i (continued) l FERMI UNIT 2 3.6 13' Revision Sa. 05/10/99 5

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.4 Verify continuity of the traversing 31 days incore probe (TIP) shear isolation valve i explosive charge.

SR 3.6.1.3.5 Verify the isolation time of each power In accordance l operated automatic PCIV. except for with the MSIVs. is within limits. Inservice Testing Program SR 3.6.1.3.6 Perform leakage rate testing for each 184 days primary containment purge valve with resilient seals. 6@

Once within 92 days after opening the valve

.SR 3.6.1.3.7 Verify 1he isolation time of each MSIV is In accordance

= 3 secc:1ds and s 5 seconds. with the Inservice Testing Program SR 3.6.1.3.8 Verify each automatic PCIV actuates to 18 months the isolation position on an actual or simulated isolation signal.

SR 3.6.1.3.9 ~ Verify each reactor instrumentation line 18 months EFCV actuates on a simulated instrument ,

line break to restrict flow.

(continued) r

, +..

l F RMI UNIT 2 3.6 13a. Revision Sa, 05/10/99

.t

, PCIVs l 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued) 1 SURVEILLANCE FREQUENCY SR 3.6.1.3.10 Remove and test the explosive squib from 18 months on a l l each shear isolation valve of the TIP STAGGERED TEST l

System. BASIS j I

SR 3.6.1.3.11 -- - - --

-- NOTE - - - --

Results shall be evaluated against I acceptance criteria applicable to SR 3.6.1.1.1.

l Verify the combined leakage rate for all In accordance secondary containment bypass leakage with the paths that are not provided with a seal Primary system is s 0.04 L, when pressurized to Containment a 56.5 psig. Leakage Rate '

iesting Program and Inservice i Testing Program SR 3.6.1.3.12 Verify combined MSIV leakage rate for all In accordance four main steam lines is 5 100 scfh when with the tested at = 25 psig. Primary Containment Leakage Rate Testing Program l

l SR 3.6.1.3.13 --- - -- - -

NOTE - - - --

Only required to be met in MODES 1. 2.

and 3.

l l

(ni -

Verify combined leakage rate through In accordance i hydrostaticilly tested lines that with the penetrate the primary containment is Primary' I within limits. Containment Leakage Rate Testing Program i, v> .,

Je l FERMI - UNIT 2 3.6 13 b Revision Sa, 05/10/99 o #

PCIVs B 3.6.1.3 BASES BACKGROUND (continued) the isolation capability is available without conflicting I with the vacuum relief function.

The drywell purge and vent lines are 24 inches in diameter:

and the suppression chamber purge and vent lines are-

, 20 inches in diameter. -The 24 and 20 inch primary containment purge valves are normally maintained closed in MODES 1. 2. and 3 to ensure the primary containment boundary is maintained. However, these lines are used for inerting and de inerting the primary containment in conjunction with planned shutdowns that will involve entry into the primary containment. The isolation valves on the 24 and 20 inch

, vent lines have 6 inch bypass lines. The nitrogen purge supply valves for the drywell and suppression chamber are 10 inches and 6 inches, respectively. In addition 1 inch lines are provided for containment pressure control.

l APPLICABLE The PCIVs LC0 was derived from the assumptions related to SAFETY ANALYSES minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during major l

accidents. As part of the primary containment boundary.

PCIV OPERABILITY supports leak tightness of primary containment. Therefore, the safety analysis of any event requiring isolation of primary containment is applicable to this LCO.

A spectrum of piping breaks inside of Primary Containment varying in size, type and location are postulated. The break types include steam lines and/or liquid process system lines. In the analysis for each of these accidents i (summarized in Reference 1). it is assumed that PCIVs are either closed or close within the required isolation times following event initiation. This ensures that potential paths to the environment through PCIVs (including primary containment purge valves) are minimized. <

-The Main Steam Line Break (MSLB) is of particular importance l l - due to the radiological consequences of the steam release' '

N outside of the primary containment. The closure time of the MSIVs is a significant variable from a radiological T I standpoint. The MSIV closure is assumed to occur no later

^k than 10.5 seconds following the event initiation. The

requirement that the MSIVs close within 3 to 5 seconds is consistent with this assumption. '

IM l FERMI - UNIT 2 B 3.6.1.3 - 2 Revision Sa."05/10/99 l

1 l PCIVs B 3.6.1.3 l

BASES APPLICABLE SAFETY ANALYSES (continued)

The accident analyses assume that PCIVs that automatically close have stroke times no greater than that given in b Reference 2. In addition to the stroke time. an additional I

delay of 13 seconds is assumed for isolation signal delay.

and diesel generator startup (for loss of offsite power).

k Following the completion of the automatic containment isolation the analyses assume that containment leakage is terminated. except for the maximum allowable leakage rate.

L.

, The PCIVs are also required to function to minimize the loss of reactor coolant inventory and thus minimize the i radiological consequences of postulated failures outside of containment of systems that directly connect to the reactor coolant system. These failures are also evaluated to assure that the ability to safely shutdown the plant is maintained.

The single failure criterion required to be imposed in the conduct of unit safety analyses was considered in the original design of the primary containment purge valves.

Two valves in series.on each purge line provide assurance that both the supply and exhaust lines could be isolated even if a single failure occurred.

l l PCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). l

LC0 PCIVs form a part of the primary containment boundary. The l

PCIV safety function is related to minimizing the loss of ,

reactor coolant inventory and establishing the primary l containment boundary during a DBA.

The power operated automatic isolation valves are required I to have isolation times within limits and actuate on an i' l automatic isolation signal. The reactor building to-suppression chamber vacuum breakers that isolate primary dI containment penetrations are excluded from this

d. Specification, controls on their isolation function are

- adequately addressed in LCO 3.6.1.7. " Reactor Building to-gl Suppression Chamber Vacuum Breakers." The valves covered by this LCO are listed with their associated stroke times in Reference 2.

3

. , . ~ .

l FERMI - UNIT 2 - B 3.6.1.3 - 3 Revision Sa. 05/10/99 i

(.j '

PCIVs B 3.6.1.3 BASES LCO (continued)

Purge valves with resilient seals, secondary containment bypass valves, MSIVs, EFCVs and hydrostatically tested valves must meet leakage rate requirements in addition to the other PCIV leakage rates which are addressed by LC0 3.6.1.1, " Primary Containment," as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their. designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor

. vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.1,

" Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instrumentation.)

5- ACTIONS The ACTIONS are modified by a Note allowing penetration flow

$l path (s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated a

g operator at the controls of the valve, who is in continuous communication with the control room. . In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated. Due to the size of the primary containment purge line penetration and the fact that those mnetrations exhaust directly from the containment atmosp1ere to the environment, the penetration flow path containing these valves is not allowed to be opened under

- administrative controls.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide

appropriate compensatory., actions for each inoperable PCIV.

~-

l FERMI UNIT 2 B 3.6.1.3 -4 RevisionSa['05/10/99

i PCIVs l B 3.6.1.3 BASES ACTIONS (continued)

Complying with the Required Actions may allow for continued l- . operation, and subsequent inoperable PCIVs are governed by i l subsequent Condition entry and application of associated l l

Required Actions.

The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary, if.the affected system (s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System l subsystem is inoperable due to a failed open test return I

valve). Note 4 ensures appropriate remedial actions are l

taken when the primary containment leakage limits are exceeded. Pursuant to LC0 3,0.6, these actions are not required even when the associated LC0 is not met.

Therefore, Notes 3 and 4 are added to require the proper actions be taken.

A.1 and A.] ;

l a With one or more penetration flow paths with one PCIV g inoperable except for leakage (i.e., secondary containment <

. bypass leakage rate, MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV leakage rate) not within limit, the affected penetration l flow paths must be isolated. The method of isolation must include the use of at least one isolation barrier th6t cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and I

de-activated automatic valve, a closed manual valve, a blind flange, and a check valve with flow through the valve .

i secured. For a penetration isolated in accordance with i

Required Action A.1, the device used to isolate the penetration should be the closest available valve to the primary containment. The Required Action must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam

<Yl i

lines). The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the time required to isolate the penetration and Qi the relative importance of supporting primary containment OPERABILITY during MODES 1, 2, and 3. For main steam lines.

an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed. The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the main steam lines allows a period.of time to restore the MSIVs to OPERABLE status given the fact that 1

MSIV closure will result in isolation of the main steam Yl line(s) and a potential for plant shutdown.

l. FERMI UNIT 2 B 3.6.1.3 - 5 Revision Sa, 05/10/99 l <

i 1 1

PCIVs B 3.6.1.3 BASES ACTIONS (continued) l For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path (s) must be verified to be isolated on a periodic oasis. This is necessary to ensure that primary 'I i

containment penetrations required to be isolated following an accident. and no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position. The Comp 1ction Time of "once per 31 days for isolation devices outside primary containment" is appropriate bec?use the devices are operated under administrative controls and the probability of their misalignment is low. For the devices inside primary containment, the time period specified " prior to entering MODE 2 or 3 from HODE 4, if primary containment was de inerted while in MODE 4, if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the ,

. devices and other administrative controls ensuring that !

5 device misalignment is an unlikely possibility.

i

@ Condition A is modified by a Note indicating that this Condition is only applicable to those penetration flow paths k with two PCIVs. For penetration flow paths with one PCIV.

Condition C provides the appropriate Required Actions.

hl Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas, and allows them to be verified by use of administrative means. Allowing verification by administrative means is considered acceptable, since access !

to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise j secured in position and allows these devices to be verified I closed by use of administrative means. Allowing verification by administrative means is considered I

acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper position, is low.

, a l FERMI UNIT 2 B 3.6.1.3 - 6 Revision Sa, 05/10/99 r.

L 1

l PCIVs B 3.6.1.3 BASES ACTIONS (continued) l IL1 l

4s With one or more penetration flow paths with two PCIVs inoperable, except for leakage (i.e.. secondary containment L

9-bypass leakage rate. MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV k leakage rate) not within limit, either the inoperable PCIVs must be restored to OPERABLE status or the affected l

l penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one ,

isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic valve. a i closed manual valve. and a blind flange. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months i

s C letion Time is consistent with the ACTIONS of l LC 3.6.1.1. l V Condition B is modified by a Note indicating this Condition 3 is only applicable to penetration flow paths with two PCIVs.

For penetration flow paths with one PCIV. Condition C tR provides the appropriate Required Actions.

C.1 and C.2 l 4 With one'or more penetration flow paths with one PCIV

$ inoperable, except for leakage (i.e., secondary containment i

bypass leakage rate. MSIV leakage rate, purge valve leakage i 5 rate. hydrostatically tested line leakage rate, and EFCV '

V leakage rate) not within limit, the inoperable valve must be ,

restored to OPERABLE status or the affected penetration flow 1 g path must be isolated. The method of isolation must include

% the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and s de activated automatic valve, a closed manual valve and a m blind flange. A check valve may not be used to isolate the

-p affected penetration. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for penetrations with a closed system is reasonable considering

.Y - the relative stability of the closed system (nence.

i l % -

reliability) to act as a penetration isolation boundary and

! Q the relative importance of supporting primary containment OPERABILITY during MODES 1, 2. and 3. The closed system l aust meet the requirements of Reference 4. The Completion l Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for EFCVs is also reasonable considering the instrument and the small pipe diameter of penetration (hence, reliability) to act as a penetration isolation 4

e "'

l FERMI - UNIT 2 B 3.6.1.3 - 7 Revision Sa, 05/10/99 i

'r

! PCIVs l B 3.6.1.3 BASES l

ACTIONS (continued) boundary and the small pipe diameter of the affected penetrations. In the event the affected penetration flow path is isolated in accordance with Required Action C.1. the affected 3enetration must be verified to be isolated on a periodic ) asis. This is necessary to ensure that primary containment penetrations required to be isolated following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration is isolated is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low.

~ Condition C is modified by a Note indicating that this M Condition is only applicable to penetration flow paths with Y only one PCIV. For penetration flow paths with two PCIVs, Conditions A and B provide the appropriate Required Actions.

Required Action C.2 is modified by two Notes. Note 1 applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of '

administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the pro)er position, is low. Note 2 applies to isolation devices t1at are locked. sealed, or otherwise secured in position and allows these devices to be l verified closed by use of administrative means. Allowing verification by administrative means is considered i acceptable since the function of locking, sealing, or l securing components is to ensure that these devices are not i inadvertently repositioned.

l l M 3 With one or more secondary containment bypass leakage rate M

(SR 3.6.1.3.11), MSIV leakage rate (SR 3.6.1.3.12), purge

' valve leakage rate (SR 3.6.1.3.6), hydrostatically tested line leakage rate (SR 3.6.1.3.13), or EFCV leakage rate {

4 h -

(SR 3.6.1.3.9) not within liait, the assumptions of the safety analysis may not be met. Therefore, the leakage must be restored to within limit. Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated l ,

l l FERMI - UNIT 2 B 3.6.1.3 - 8 Revision Sa, 05/10/99 r

PCIVs !

l B 3.6.1.3 l

l BASES ACTIONS (continued) penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are used to isolate the penetration, the leakage rate is assumed

' to be the lesser actual pathway leakage of the two devices.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for leakage on hydrostatically t* tested lines and for secondary containment bypass leakage is I reasonable considering the time required to restore the o leakage by isolating the penetration and the relative g importance of leakage to the overall containment function.

.i For MSIV leakage, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed. The I

q Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV leakage allows a period of time to restore the MSIVs to OPERABLE status given the fact that the MSIV closure will result in isolation of the

( main steam line(s) and potential for plant shutdown. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for purge valve leakage is acceptable considering the purge valves remain closed so that a gross breach of the containment does not exist. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for EFCV leakage is acceptable based on the instrument and small pipe diameter of the penetration (hence, reliability) to act as a penetration isolation boundary.

gj E.1 and E.2 I

If any Required Action and associated Completion Time cannot si be met in MODE 1. 2. or 3. the plant must be brought to a i MODE in which the LC0 does not apply. To achieve this

-f status, the plant must be brought to at least MODE 3 within J., 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed g Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

l l

o l

l FERMI UNIT 2 B 3.6.1.3 - 9 Revision Sa," 05/10/99

i l

PCIVs B 3.6.1.3

. ES 1

l ACTIONS (continued) 4l -

L1 l [-i If any Required Action and associated Completion Time cannot be met, the unit must be placed in a condition in which the g LC0 does not apply. Action must be immediately initiated to l

isolate the RHR Shutdown Cooling System. However, if the i

shutdown cooling function is needed to provide core cooling.

i these Requked Actions allow the penetration flow path to I

remain unisolated provided action is immediately initiated to restore the valve to OPERABLE status or to isolate the RHR Shutdown Cooling System (i.e.. provide alternate decay heat removal capabilities so the penetration flow path can

be isolated). Actions must continue until the valve is restored to OPERABLE status or the RHR Shutdown Cooling l

l System is isolated.

SURVEILLANCE SR 3.6.1.3.1 ,

REQUIREMENTS

, This SR ensures that the drywell and suppression chamber i purge system isolation valves (6 inch,10 inch, 20 inch, and 24 inch) and the containment pressure control valves (1 inch) are closed as required or, if open, open for an j '

allowable reason. If a purge or containment pressure control valve is o>en in violation of this SR, the valve is l considered inopera)le. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. Primary l containment purge and containment pressure control valves are only required to be closed in H0 DES 1. 2 and 3 (i.e.,

no isolation instrumentation functions of LC0 3.3.6.1 are l %l required to be OPERABLE for isolation of these valves l J, outside of MODES 1, 2, and 3). If a LOCA inside primary l R containment occurs in these MODES, the purge valves may not T be capable of closing before the pressure pulse affects i systems downstream of the purge valves. At other times i (e.g., during handling of irradiated fuel), pressurization ,

l concerns are not present and the purge and containment i

, ' pressure control valves are allowed to be open. The SR is l 1 modified by a Note stating that the SR is not required to be l met when the purge or containment pressure control valves are open for the stated reasons. The Note states that these l valves may be opened for inerting, de inerting, pressure control. ALARA or air quality considerations for personnel

, entry, or Surveillances that require the valves to be open.

~r

[

l FERMI - UNIT 2 B 3.6.1.3 - 10 Revision Sa, 05/10/99 s

l l

PCIVs B 3.6.1.3 i

BASES l SURVEILLANCE REQUIREMENTS (continued) i The purge valves (6 inch,10 inch, 20 inch. and 24 inch) and T

E the containment pressure control valves (1 inch) are capable of closing in the environment following a LOCA. Therefore, these valves i 'e allowed to be open for limited periods of l time. The 31 day Frequency is consistent with other PCIV requirements discussed in SR 3.6.1.3.2.

SR 3.6.1.3.2 I

This SR verifies that each primary containment isolation l Q manual valve and blind flange that is located outside 4 primary containment and is not locked, sealed, or otherwise Q secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits. ;

This SR does not require any testing or valve manipulation. !

Rather, it involves verification that those PCIVs outside l primary containment, and capable of being mispositioned, are in the correct position. Since verification of valve position for PCIVs outside primary containment is relatively easy, the 31 day Frequency was chosen to provide added assurance that the PCIVs are in the correct positions.

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

verification by administrative controls is considered '

acceptable since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons.

Therefore, the )robability of misalignment of these PCIVs.

once they have >een verified to be in the proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are m open. This SR does not apply to valves that are locked, i sealed, or otherwise secured in the closed position since R

X -

these were verified to be in the correct position upon locking, sealing, or securing.

n. ~~

l FERMI - UNIT 2 B 3.6.1.3 .11 RevisionSa[ 05/10/99

PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.3 This SR verifies that each primary containment isolation manual valve and blind flange that is located inside primary Nl containment and is not locked, sealed. or otherwise secured and is required to be closed during accident conditions is k closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary M containment boundary is within design limits. For PCIVs 7 inside primary containment, the Frequency defined as " prior

% to entering MODE 2 or 3 from H0DE 4 if primary containment k was de inerted while in MODE 4 if not performed within the previous 92 days" is appropriate since these PCIVs are l operated under administrative controls and the probability of their misalignment is low. This SR does not apply to i valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position upon locking, sealing, or securing.

Two Notes have been added to this SR. The first Note alloss valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during MODES 1. 2, and 3 for ALARA reasons. Therefore, the

>robability of misalignment of these PCIVs. Once they have

>een verified to be in their proper position, is low. A second Note has been included to clarify that PCIVs that are o>en under administrative controls are not required to meet t1e SR during the time that the PCIVs are open.

SR 3.6.1.3.4 The traversing incore probe (TIP) shear isolation valves are actuated by explosive charges. Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required. Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed. The 31 day Frequency is based on operating experience that has demonstrated the reliability of the explosive charge continuity.

l FERMI UNIT 2 B 3.6.1.3 - 12 Revision Sa. 05/10/99

PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.5

[ Verifying the isolation time of each power operated automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7.

The isolation time test ensures that the valve will isolate '

in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.6 For primary containment purge valves with resilient seals (6 inch,10 inch, 20 inch, and 24 inch), additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J. Option B (Ref. 3), is required to ensure OPERABILITY.

when tested atThisP. will ensureexperience Operating that leakage is s 0.05 L,d has demonstrate

. that this type oi seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between primary containment and the environment), a Frequency of 184 days was established.

Additionally, this SR must be performed once within 92 days

after opening the valve. The 92 day Frequency was chosen i

recognizing that cycling the. valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

The primary containment purge valves are only required to I

meet leakage rate testing requirements in MODES 1. 2. and 3.

L (i.e.. no isolation instrumentation functions of LCO 3.3.6.1 l are required to be OPERABLE for purge system isolation l -

outside of MODES 1, 2, and 3). If a LOCA inside primary containment occurs in these MODES. purge valve leaka be minimized to ensure offsite radiological release 'ge is must within limits. At other times (e.g., during handling of irradiated fuel), pressurization concerns are not present '

and the purge valves are not required to meet any specific leakage criteria. '

l FERMI - UNIT 2 B 3.6.1.3 - 13 Revision Sa, 05/10/99 L. !

I PCIVs B 3.6.1.3 I

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.7 )

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

l The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. This ensures that the calculated radiological consequences of these events remain within l 10 CFR 100 limits. The minimum stroke time ensures that l isolation does not result in a pressure spike more rapid than assumed in the transient analyses. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program. ;

SR 3.6.1.3.8 Automatic PCIVs close on a primary containment isolation

. signal to prevent leakage of radioactive material from '

l primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position

! on a primary containment isolation signal. The LOGIC SYSTEM ,

l l FUNCTIONAL TEST in SR 3.3.6.1.5 overlaps this SR to provide l complete testing of the safety function. The 18 month Frequency was developed considering it is prudent that this Surveillance be performed only during a unit outage since isolation of )enetrations would eliminate cooling water flow and disrupt t1e normal operation of many critical .

, components. Oper6 ting ex>erience has shown that these l

components usually pass t11s Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.6.1.3.9 This SR requires a demonstration that each reactor instrumentation line excess flow check valve (EFCV) is OPERABLE by verifying that the valve restricts flow on a simulated instrument line break. This SR provides assurance that the instrumentation line EFCVs will perform so that

- predicted radiological consequences will not be exceeded during the postulated instrument line break event evaluated in Reference 5. The 18 month Frequency is based on~the typical performance of this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating L

4;

l. FERMI UNIT 2 B 3.6.1.3 -14 Revision 5a.*05/10/99 e

PCIVs ,

B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued) experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency.

Therefore, the Frequency was concluded to be acceptable from 1 a reliability standpoint. l SR 3.6.1.3.10 The TIP shear isolation valves are actuated by explosive ;

charges. An in place functional test is not possible with !

this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib i shall be from the same manufactured batch as the one fired I or from another batch that has been certified by having one of the batch successfully fired. No squib will remain in ,

service beyond the expiration of its shelf life or its operating life. The Frequency of 18 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4). -

SR 3.6.1.3.11 This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of Reference 1 are met. The leakage rate of each by) ass leakage path is assumed to be the maximum pathway leacage (leakage trough the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de activated automatic valve, closed manual valve or blind flange. In this case, the leakage rate of the isolated bypass leakage )ath is assumed to be the actual pathway leakage through t1e isolation device. If both isolation valves in the penetration are closed, the y actual leakage rate is the lesser leakage rate of the two i valves. The frequency is required by the Primary g Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. Additionally, some secondary containment bypass paths (refer to UFSAR 6.2.1.2.2.3) use non PCIVs and therefore are not addressed by the testing Frequency of 10 CFR 50. A To address the testing for these valves the ppendix J. testing.

Frequency also includes a requirement to be in accordance with the Inservice Testing Program.

l FERMI UNIT 2 B 3.6.1.3 - 15 Revision Sa, 05/10/99

l PCIVs l L B 3.6.1.3 BASES l SURVEILLANCE REQUIREMENTS (continued)

Secondary containment bypass leakage is also considered part of L,. Therefore. Note 1 assures that any secondary I containment bypass leakage is appropriately evaluated against the criteria for overall containment leakage. l l

SR 3.6.1.3.12 The analyses in References 1 and 4 are based on leakage that !

i is less than the specified leakage rate. Leakage through '

l all four main steam lines must be s 100 scfh when tested at

= P (25 )sig). This ensures that MSIV leakage is properly t :

accountec for to assure safety analysis assumptions, )

regarding the MSIV LCS ability to provide a positive i pressure seal between MSIVs. remain valid. This leakage I test is performed in lieu of 10 CFR 50, Appendix J, Type C i test requirements, based on an exemption to 10 CFR 50, l Appendix J. As such, this leakage is not combined with the l Type B and C leakage rate totals. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

I SR 3.6.1.3.13 j l Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 ys are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the 1 g number of valves per penetration, not to exceed 3 gpm, when g (= 62.2 psig). Additionally, a combined tested leakageatrate 1.1lim P,it of s 5 gpm when tested at 1.1 P ;

(= 62.2 psig) is applied for all hydrostatically tested '

l PCIVs that penetrate containment. The combined leakage I rates must De demonstrated in accordance with the leakage rate test Frequency required by Primary Containment Leakage Rate Testing Program.

This SR has been modified by a Note that states that these valves are only required to meet the combined leakage rate in MODES 1, 2. and 3 since this is wisen the Reactor Coolant

' System is pressurized and primary containment is required.

- In some instances, the valves are required to be capable of automatically closing during MODES other than MODES.1, 2 and 3. However, specific leakage limits are not applicable in these other MODES or conditions.

I FERMI UNIT 2- B 3.6.1.3 - 16 Revision Sa," 05/10/99

I-7 3 '

PCIVs l B 3.6.1.3 BASES REFERENCES 1. UFSAR. Chapter 15.

i 1

2. UFSAR. Table 6.2 2.

3. 10 CFR 50, Appendix J. Option B.

4. UFSAR. Section 6.2.

5. UFSAR. Section 15.6.2.

j' l

l l

l' l

1 l

l i

I

'e- =>

, )

l FERMI UNIT.2 2 3.6.1.3 - 17 Revision Sa,' 05/10/99 s

i

5peancAnoio .r U.3 CONTAINMENT SYSTEMS hl.5ose.s,$ptcihca/753.6././)

3/4.6 CONTAlf' MENT SYSTEMS (Al5O$44 $ g cj [ cgh i g,y }

3/4.6.1 PRIMA (Y CONTAINNENT PRIMARY CONTAINSENT INTEGRITY

[f MITING CON 01 TION FOR OPERATION 1 I

M.1.1 PRIMARY CONTAINMENT INTEGRITY shall be maintained.

APPlfCABILITY: OPERATIONAL CONDITIONS 1, 2* and 3.

544 Spu,lhcaib ACTION:

34*U Without PRIMARY CONTAINMENT INTEGRITY. restore PRIMARY CONTAINMENT INTEGRITY within I hour or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SVRVEllt ANCE REOUTREMENTS 4.6.1.1 PRIMARY CONTAINMENT INTEGRITY shall be demonstrated:

e-~~ .-

a .' After each closing of each penetration subject to Type B testing, S u_ except the primary containment air locks, if opened following Type

[ A or B test, by leak rate testing the seals with gas at Pa 56.5 58gg;g-* psig, and verifying that when the measured leakage rate for these 5

\ 55 seals is added to the leakage rates determined pursuant to

( Surveillance penetrations, theRecuirement combined leakage4.6.1.2.b for all rate is less than other or equal to Type B and N

1 C

" L8 %

Upo Acnoas)

SR 3.M,34 b. / At least once per 31 days by verifying that all primary containment penetrations exceot those inside the centainment or in j

k f, ce hich radiation areasU '*:2 -- T:::: - . -i lnot g ; .,

e of being\ closed by UFcMdLE containment automatic f

. gT;.g $ 42; isolation valves and requirea txbe clofed durino accident 7 d-

.' T

$8)#j p c,2,n\ conditions

~

are closed byQockesclosed valves, blank flanges, or l, ,

~

$3 c t,1fa tQKI_IT_ofit iFv aTQfTu;FQd F.gTLt fD. e x c e p t f o r ,&g SR %,l3,1 Nole.1 vaTves th'Et are open uWer administrative control as pergtted by

$4 3 (r l 3 3 4k. *L q Specification 3.6.3. y4 w 41 h Ad-A,2. f Valves, flanges, and eacTivaled automatic valveb which are

-h @

gg3,4*l'3'3 1.

located inside the conlainme'Et,Td a~rell"otfi?C 6 sealed or_ g otherwise secured in the closed position shall be verified , T closed during each COLD SHUTDOWN except such verification need not be performed when the primary containment has not k"**

been deinerted since the last verification or more of ten than once per 92 days. @) gf g,(,,f,y,1 e f A D D S R 3 6 */* 3

3 # 8FI#

See special Test Exception 3.10.1. 3 , 58 L.d g

\ Sewd e oWwwlse secxed " C FERMI UNIT 2 3/4 6 1 Amendment tio. O,102 .!.

'k

$ EE 8 s

~

PAGE l 0F 09 'Fa/n 8

r.

l 5 pet.:ricartos, J.(,.t.3 (Alw atSpec;(icabg 5.c.t.I)

CONTAINMENT SYSTEMS PRIMARY CONTAINHENT INTEGRITY gegg y Acj,g f, ', . - ,

SURVEf tl ANCE REOUTREMENTS (Continued) g4 3,(,, j ,3,'2 2. Lock sed valves. flanges, Ind faeEtga at'j 7,y7Jocatefou,0 g va ves ;;;; - ::M: " ' 1.1 !" wT ich tside -

the containment d withinQ"oc'e3)hich radiation areas shall be , 1 ,

verified closec(c. ___ _

-- ,performeo ( )

within the previous 31 ca

_ 4 A D D '5 s.--T. G.13.'2. eJo7e I'm( ,l

c. By verifying each primary containment air lock is in compliance S e4. with the requirements of Specification 3.6.1.3.

bee dkiCNo d. By verifying the suppression chamber is in compliance with the 3.411 m reauirements of specification 3.6.2.1.

I I

SR.J.6,l 3.1"The TIP Flange (Penetration X 35A) may be verified by review of high i

y Alof g, ) radiation area access controls if the TIP Room remains a high f-radiation area during COLD SHUTDOWN. , , J,,

h FERMI - UNIT 2 3/4 6 la Amenoment No. 49 e

PAGE S OF 09 F

i i

Spe /% r + 3.6 .l . 3, (Also s e e Spec #ic a w J ,6 , E /)

CONT 1HuiNT Sv'~'"~

P R I M *.c ' CONTAINwib- LEAKAGE (Alb See bfrCif'CaYron 5' S tIMITIN, CONDIT W '0: ODEp:TinN l

1 l

3.6.1.2 Primary containment leakage rates shall be limited te:

a. An overall integrated leakage rate of less than er eoual to: La.

0.! :e-:e-t by vet;" -' tt: :: .tzinment zi per ne::r: :: P, 56.5 esig.

See. '

. A t.ombined leakage rate of less than or equal to 0.60 L for l

$/. '. b,f *I'.*4 primarycontainmentpenetrationsandprimarycontainmen! isolation I F.f- valves subject to Type B and C tests when pressurized to P, in accoraance with the Primary Containment Leakage Rate Testing l Program cescribed in Specification 6.8.5.g exce:t for main steam ,

i i

line isolation valves

and primary containment isolation valves l ich are hydrostatic 611y tested. l sg. 3 4.1.3.12. c. *Less than or equal to 100 scf per hour for all four main steam lines when tested at 25.0 psig. i

d. IA e .. i n 1 age t e o f 1 *A + h = a av metIal to 5 com id a1D b nta' e isol o{valvesinhydrostaticallytestedlines -

j pen ra the mary,pontainment, pnen testea p 1.lu r a..,p .2 9 Lhf l SRJJ.f. 3. f3 es ett ha r equa on no o i spm ~ es the num o exceed of vaives one ner een ration far line 4

( Aoo NOTE Ipen ating tainment 4 hydrostatically tested 1.10 g E nsier -

APPLICABILITY: When PRIMARY CONTAINMENT INTEGRITY is required per Lco 3w Specification 3.6.1.1.

ACTION:

bhtn:

a. [Themeasuredoverallintegratedprimarycontainmentleakagerate exceeding 0.75 L or

.6e e b. The measured com$,ned 1 leakage rate for primary containment Sp ecif:' cation penetrations and primary containment isolation valves subject to 4'TypeBandCtestsinaccordancewiththePrimaryContainment 3.6.l.l [

l l Leakage Rate Testing Program, except for main steam line isolation l

E# l valves

and primary containment isolation valves which are or j

c. Oh (Thedrostatically measured leakage tested, rateexceeding 0.60 exceeding 100 scLa,f per hour for all four main steam lines, or g

d. The measured combined leakage ~ rate for all containment isolation

//CTroA/ D valves in hydrostatical 1y tested lines which penetrate the primary y e.

contair. ment m.a ., ,_ uma or_

- /J).f -

Theleakagerateofanyhydrostaticallytestedline[p'enetrating dE primary containmest e .. u.y ^ ym r.. . d .t . . . . u mn ment is alvet ner nen E;tion or a tpumy,rofconyt

._ _r .. .. ...ola __

y,2 (prior to increasing reactor coolant system temperature above 200* restore:

e e- Ine overall integrateo leakage rate (s) to less than or equal to S p ect 6,c.t.,oa ?

SE--

3.G,t.f 0.75 La, and -

\

@; stW. t: ^;;nn 2 c' M CP ":rt 57 FERMI - UNIT 2 ,, 3/4 6-2 Amendment No. 192, 108 l

PAGE 3 0F 09. M !

4 l t L-

l 1

l Sp ec, f,'c a%. 1.6 . I. 5

[Also s c e 5pe r ofic e.1.on s' . b . ' )

Coniainuin~ SYT~~u* ( 8 Is o cee Sp ecif/c e.1;o n 5, g)

(TM1 TING CONOTTION ": nDED1 TION (Coatinum?'

ACTION: (Continued)

E :: ::ne: icaxage rate for :n ary ::r.;ainme..; penetrati:ns ar.:

I o. I I

gee primary centainment isolation vaives suoject to Type B and C tests in accorcance with the Primary Containment Leakage Rate Testing 6Fecd, ',cd.od Program, except for main steam line isolation valves

and primary f, y containment isolation valves which are hydrostatically tested, tests t: less than or equal to 0.60 L , and

c. The leamage rate to less than or equal to 100 scf per hour for all four main steam lines, and l

d. / The comoined leakage rate for all containment isolation valves in g gppyp i

4 hydrostatically tested lines whi5h penetrate the primary l

containment {oj essj aan or p al p gpp and 6'

e. The leakage rate of any hydrostatically tested linehetrating _ h primary containment (t iuss snaya wpm pay bulsiifn valve I/mes ) %

Ahe palmber of contai nt isolf. ton valve nor ndstrationAr _liis ationg Qur 3 gpm/6er pen SURVEILLANCE REOUTREMENTS l l

l l 4.6.1.2 Perform required primary containment leakage rate testing in

, '-7 accordance Specificationwith the Primary Containment Leakage Rate Program described in 6.8.5.g.**

- 5e c.

l' Specifico fien 3.(, . \ .\

1 ,

k 1 i S(L 3 6. I 3,12. Fragency

~

SR. 3 6 . I. 5 a13 Fre.peny MDl 54 3 la.l.3 ll f / lcm ~trn C, h \

Semom Wrm osr y (d y t

Exemption to Appendix J of 10 CFR Part 50

/ Sec 6feciWcafi *Except for LPCI Loop A and B Injection Isolation valves, which are

f. f hydrostatically tested in accordance with Specification 4.4.3.2.2 in lieu of this requirement.

, FERMI - UNIT 2 3/4 6-3 Amendment No. J92,108 PAGE .I 0F 09 ev R

l I

Spect p1cAnw 3h,I.3 CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM LIMITING CONDITION FOR OPERATION 3.6.1.8 The drywell and suppression chamber purge system '0 ...a. 10 ...G .

SR34.13.l ^^ in d , -f ?' '-k "a "ad may be in operation with the supply and exhaust -

M isolation valves in one supply line and one exhaust line open for inerting, 'i- I deinerting or pressure control. Nitrogen VENTING / makeup and pressure control 1 is also allowed through the 1-inch valves.

00T0 ;h ll i: 'init:f *e 60 h;;. : =:5 ??? d y:

."a b / v; ..

p..t;.... ....;;;h th; k APPLICABILITY: OPERATIONAL CONDITIONS 1,g2 and 3. j ACTION:

0 De AcitoNS No7t t ;-- [.g y 6

((god A06 Ac7; ens NorE X-)Ac77 EMS pl0TE 3 > -

A ffcTtoM b

a. With a drywell and suppression chamber purge system supply and/or 4 exhaust isolation valve open, except as permitted above, close the valve (s) or otherwise isolate the penetration (s) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD AcTioO b SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With a drywell and suppression chamber purge system supply and/or js-O bcw D exhaust isolation valve (s) with resilient material seals having a measured leakage rate exceeding the limit of Specification h#

Z 4.6.1.8.2, restore the inoperable valve (s) to OPERABLE status d within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least HOT SHUTDOWN within the next 12 hCR0d g hcurs and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , ljtc SURVETLLANCE RE0VIREMENTS

~ -

64% l3*I 4.6.1.8.1 [Before beino opened hr purge / vent operation b; d SETSJ the k tJpTE drywell ana suppression chamber purge supply and exhaust butterfly isolation valves shall be verified not to have been open for purge / vent operatio threwgh SCT: fe - e th:. 00 .'..... ... tr. -- "::: ?!! d;,;.- , L.- l 543.(,,l.3.4 4.6.1.8.2 At least once per[92 days]

-.a.'

ation for each L .. 2 , ;.;h d2

---'.m >- '

- -- ' drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals sha_ll be demonstrated OPERABLE by verifying that the measured leakage rate f- ' :: " "]

{ ;a..; ;. ix . = '. , ":- - ::: r- :-- ~ "_

l M Ml,3sl _* Primary containment nitrogen VENTING and pressure control is permitted I through the 1-inch valves =d i: =t :dhtt *e th- "O H : m 255 d; MartT~ l'

,N l

l 1

- FERMI - UNIT 2"e 3/4 6-14 Amendment No. 58 !

=

09 da'n PAGE_ [0- 0F 1

W

See c iricArm ht.3

/ CONTAINMENT SYSI211 3/4.6.3 PRIMARY CONTAINMENT ISOLATION VALVES O*I y J

LIMITING CONDITION FOR OPERATION d

[reacwp4(dk .+o.suppuurimck=4u 3 WCM breakW)5 3.6.3 Each primary containment isolation valved:d -- -*-- "P r----tit'--[H u__ _ _ _ _ _ n .. . _ m u .' shall be OPERABLE.**

APPLICABILITY: OPERATI AL CONDITIONS 1, 2, and 3.(400 4cnarJ F po Add: When regoind by mshetat'* 3 !.

McTiods poTE 2%. A.g g4gg ge7,3g g k

$@O$4 D a. With one Dr mard of the primary con ainment isolation valves

go7ES 3/f inoperable.fmainmn at iesst one isoiation vaive unKABLE in eacy Q[Lectea nanatration that is open anq(iilthin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ettner:

{ -- - ,.

...._.__._47 ;n L - m.tus.,e i

2. Isolate each affected penetration by use of at least one Regoind Acfiea deactivated automatic vaive secured in the isolated d 4,l position,' or j L U E

3. Isolateeachaffectedpbtrationbyuseofatleastone ocke closed manual valua a- ki=ak m aa* * *7 ,o M c h eck vabc withttuGow seco/sp l.10 ,g Otherwise, be in at least HOT SHUTDOWN within the next 1Z nours w.

AC'I'iOg g and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , g b With one or more of the reactor' instrumentation line excess flow bCDOM C-10 check valves inoperable, operation may continue,.i.; m... --...;.- l t :::li:: M rovided that within 4 l hours either: n L3 ;I'.

s

. ine inopersose vaive is returned to OPERABLE status, on p k W C,0 v. The instrument line is isolated rand the associatea j $:

2nstrument is aeciarea inoperapie.

Acom err 3 Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AcTierJ E and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , f lN 77dN b !') %

Nc71od Mom I *lsolation valves closed to satisfy these requirements may be reopened on an inttraittent basis under administrative control.

No7E 2. + : 1* TECH:2 ;7 20 !^) closed valves may be opened on an intermittent basis under administrative ontrol.

j id

.,gg g ,g,3 4 1

- 54 34.n.3 -

h,Q

, FERMX - UNIT {,, 3/4 6 20 Amendment No. N , 102 PAGE ~7 0F 09

T{)[C i F /C AT10 ed 3- (* l* *)

CONTAINMENT SYSTEMS SURVEILLANCE REOUIREMENTS 4.6.3.1 ach primary contains isolation valve shall demonstrated j OPERAB prior to returning t valve to service after aintenance, repair o rep 1 ment work is perfo on the valve or its as ciated actuator, con ol /8,1 or er circuit by cyclin the valve through at le t one complete cycle f W1 travel and verifyino ha iea4aa +4== ' '

o gg g ,g,3,g 4.6.3.2 Each primary corttainment5"'""" automatie isolation fvalve shall be demonstrated OPERABLE brinv 2 months by verifying that on a containment isolation est_ signal each automati

^- r r"r'- Nt least once per 18 ;g isolation valve actuates to its isolation position. adual er sinustak g g ,g,y, f4.6.3.3 The isolation time of each primary containment power operated or automatic valve shall be determined to be within its limit when tested l pursuant to Specification 4.0.5.

g g g'g,3'g 4.6.3.4 Each reactor instrumentation line excess flow check valve shall be demonstrated OPERABLE at least once per 18 months by verifying that the valve l

12 h[0W- (fperic3J) -

1 4.6.3.5 Each traversing in-core probe system explosive isolation valve shall be demonstrated OPERABLE:

h 5 A3.(**l.~5,LI a. At least once per 31 days by verifying the continuity of the explosive charge. Ml

_ $. WTd Bas -

g 3,(,,3 *'j,lO b. At leas iit Teas.L onceJer t one 18,,,mo,nths(by explosive valve such that'reInoYing tTesquib the explosive explosive Yquib fro in eLetu 5xplogiyt_ral.ye will be tested at least once per 90,_pg,nths[aB

~

initiatino the exoEsITe soui[ ~nhGl.1... ....., L su 3 I expl ed squib shal be from the sa manufactured ba h as the one ired or from nother batch wh h has been certi ed by Ih ha ing at least e of that bate successfully fire . No squ L N'N all remain in se beyond the piration of its s elf-life peratin_g life as applicable, f

!!h; h. *$5

"" " " ~ " * '

, FERMI - UNIT 4. 3/4 6-21 Amendment No. 102 PAGE fi 0F 09 Ra&

SPEC Ficansra 5. <,. t. 5 PEACTOR COOLANT SYSTEM 3/4.4.7 MAIN STEAM LINE ISOLATION VAtVES l1MITING CONDITION FOR OPERATION LM 3*b'I'3 3.4.7 Two main steam line isolation valves (MSIVs) per main steam line shall be OPERABLE with closing times greater than or equal to 3 seconds and less N W'3 *7 than or equal to 5 seconds. gg g ,

APPLICABillTY: OPERATIONAL CONDITIONS 1, 2, and ,

ACTION: r-*( ACT1oNS 4oTE 2_h 6 E l ( Ac7 tour motes 3 gQ %

With one for more}MSIVs inoperable: Add $c.T10M 8 L. 2.

gy 4 a.

1. { Maintain at least one MSIV OPERABLE in each affected main steam 3 Lline that is ooen/fiid within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , either:

[q o . . . . u . 4 --- . . o : m . . ; , , n r ef m . . . . . . . e Aq b) Isolate the afJ1cted main steam line by use of a j te

(' deactivated M5 :10in the closed position. [,ff 1 Od g 2. Otherwise, be in at least HOT SHUT 00WN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months k and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

I i

~

<O Y

SURVElltANCE REOUTREMENTS -f g,g,p 4.4.7 Each of the above required MSIVs shall be demonstrated OPERABLE oy verifying full closure between 3 and 5 seconds when tested pursuant to k

Specification 4.0.5.

FERMI - UNIT 2 3/4 4 24 Amendment No. 83 s

C PAGE 0F 09 fev si

1 DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specificatias (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 (BWR) Standard Technical Specifications NUREG 1433. Rev. 1.

A.2 CTS 3.6.1.2.c refers to footnote "*" which is solely an l@

informative note (informing that the requirement is associated 1 with an exemption to Appendix J). The informational Note is not k retained in ITS SR 3.6.1.3.12. This is a presentation preference, with no change in requirements or intent. Therefore, the change is administrative with no impact on safety.

A.3 CTS LC0 3.6.3 explicitly addresses all PCIVs, including an explicit requirement for reactor instrumentation line excess flow I check valves (which are also PCIVs). However. CTS LC0 3.6.4.2 addresses all necessary requirements for the reactor building to-suppression chamber vacuum breakers (which are also containment ,

isolation valves), without reliance on the PCIV Specification.

The intent and implementation of the CTS requirements is to lk j l

exclude the reactor building to suppression chamber vacuum k '

breakers from CTS LC0 3.6.3, PCIVs. ITS LC0 3.6.1.3 provides a l l human factored improvement to explicitly exclude these vacuum ;

breakers from the PCIV Specification. ITS also eliminates the redundant mention of excess flow check valves. Since all necessary requirements continue to be addressed, this presentation preference is considered an administrative change.

A.4 CTS 3.6.3. Actions a.1, b.1, and CTS 3.4.7, Action a.1.a) requires restoring inoperable isolation valve (s) as an option to isolating the affected penetration. ITS 3.6.1.3 Actions A and B do not contain the restoration action, but rather rely upon the guidance of LC0 3.0.2 which allows restoration within the time limits of the specified Required Actions. The CTS has been revised to delete this restoration action since the option to restore an inoperable component always exits, and is inherent in the ITS.

Durincj this reformatting, no technical changes (either actual or

, interpretational) were made to the TS. The change is consistent with NUREG 1433. ,.,

FERMI UNIT 2 1 REVISION Sa, 05/10/99l

1 DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 . PCIVs l

1 O

A.5 Not used. d.

A.6 CTS 3.6.3, Action b, contains an allowance, "the provisions of lk l l

Specification 3.0.3 are not applicable." This allowance does not appear to serve any function: non compliance with the specified Actions (which is the cause for entry into Specification 3.0.3) would require failure to shutdown the plant. It is acknowledged l that the intent of failing to comply with a required shutdown would not be to also allow 3.0.3 to be not applicable. Given the existing interpretation that this " allowance" would never actually be effective, its deletion is considered administrative.

A.7 CTS 4.6.3.2 requires the performance of a system functional test of the primary containment automatic isolation valves, which includes the requirement for each automatic isolation valve to actuate on a " test signal." ITS SR 3.6.1.3.8 permits the system functional to be initiated by an " actual or simulated" isolation l signal. This change allows satisfactory automatic isolations to !

be used to fulfill the system functional Surveillance requirement. l Operability is adequately demonstrated because the isolation j valves can not discriminate between " actual" or " test" isolation l signal. Since this is a reasonable interpretation of the existing l requirement, this is an administrative change. '

A.8 ITS LC0 3.6.1.3 Actions are modified by Note 2, which provides clarification that, for the purpose of the associated LCO,

" Separate Condition entry is allowed for each penetration flow path." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV. Complying with the Required Actions will allow for continued operation: subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on safety because the clarifications provided by Note 2 are consistent with the existing interpretation of the CTS.

A.9 ITS 3.6.1.3, Actions Notes 3 and 4 are added. These Notes facilitate the use and understanding of the ITS intent. Any system made inoperable by inoperable PCIVs is inoperable and its Actions also apply. This requirement is the existing interpreted

~

intent of the CTS. Therefore, Note 3 explicitly clarifies this

, intent,, Note 4 clarifies that these " systems" include the primary containment. With ITS LC0 3.0.6, these intents would not g FERMI - UNIT 2 2 REVISION Sa, 05/10/99l

\

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs necessarily apply. Since the clarifications are consistent with the intent and interpretation of the CTS, this change is considered administrative with no impact on safety.

A.10 CTS 3.6.3 Actions b.1 and b.2 detail specific methods of restoring _

inoperable EFCVs. Since the specific Operability criteria q associated with EFCVs is that they actuate to restrict flow (which I is essentially a qualitative leakage rate requirement), EFCV are p also included in ITS Action D for leakage not within limit. For .1 simplicity in presentation, ITS 3.6.1.3 Action D combines the actions for all the various PCIV leakage rate failures into a q i single action to " restore leakage rates to within limits." This is equivalent to the CTS options to return to Operable status, or isolate the instrument line. As such this change is considered 1 administrative only.

A.11 CTS 3.6.1.8 and 3.4.7 required purge valve penetrations and MSIV penetrations respectively to be isolated in the event the l associated PCIV is inoperable. Similarly, CTS 3.6.3 provides requirements for all PCIVs (including purge valves and MSIVs), but ,

includes an allowance to " reopen on an intermittent basis under 3 l administrative control" any penetrations isolated to comply with t4 !

the Actions. Consistent with the CTS 3.6.3 allowance, this d i explicit allowance is provided in ITS 3.6.1.3 Actions Note 1.

This is an administrative change with no impact on safety since k

the allowance is considered consistent with the existing i interpretation of the CTS. '

l

\

s p,. N f 38 FERMI - UNIT 2 3 REVISION Sa, 05/10/99l e

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 4.6.1.1.b.2 requires verification of valve position for valves located within high radiation areas "during each Cold Shutdown if not performed within the previous 31 days." ITS SR 3.6.1.3.2 requires a verification every 31 days, but allows the verification to be "by administrative means" for those valves located in high radiation areas (i.e., Note 1 to SR 3.6.1.3.2). Since the high radiation area is a controlled access area, and each closed valve is also administrative 1y controlled, the 31-day verification could !

consist of an on paper verification that the position of those valves has not changed. This represents an increased surveillance frequency since the ITS will not allow deferral of all verification until the next Cold Shutdown, and as such, is a more restrictive change, with no negative impact on safety.

M.2 CTS 3.6.1.2 Actions for primary containment leakage above established limits only restrict reactor coolant heatup beyond 200*F (which would allow a startup and control rod withdrawal from I cold conditions, i.e., < 200*F). Furthermore, if primary containment leakage above established limits were discovered while operating, the CTS Actions are non specific as to the appropriate required actions. Under the same conditions. ITS LC0 3.0.4 will not allow a reactor startup to commence with containment leakage outside' limits: just as CTS requires. However, a restriction is _ ;

added by ITS 3.6.1.3 Action E to require a plant shutdown to Mode l tQ 4, if leakage rates are discovered outside established limits and T cannot be corrected within the times provided in ITS Action D. lf i The Completion Times provided in ITS Actit.1 D (i.e., (a) MSIV leakage is required to be restored within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , consistent with lk restoration (or isolation) time for inoperable MSIVs: and l (b) hydrostatically tested valve leakage is required to be a restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if on a closed system and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if not G on a closed system, based on the available water seal) present a 1 '

restriction beyond CTS requirements. While ITS 3.6.1.3 is more E l restrictive, it provides appropriate Actions, commensurate with l the type of leakage failure experienced, to ensure the plant is i

placed in a configuration consistent with the design basis.

Therefore, this change will result in an improvement in plant safety and has no negative impact on safety.

t1 FERMI - UNIT 2 4 REVISION Sa, 05/10/99l

l 1

)

DISCUSSION OF CHANGES I ITS: SECTION 3.6.1.3 - PCIVs l

)

1 M.3 CTS 3.6.3 Applicability for PCIVs only include Modes 1. 2. and 3.

ITS 3.6.1.3 adds an Applicability (When associated instrumentation is required to be Operable per ITS LC0 3.3.6.1 " Primary Containment Isolation Instrumentation") which effectively adds a .

Mode 4 and 5 requirement to the RHR Shutdown Cooling System l isolation valves. Also. ITS 3.6.1.3 Action F provides appropriate actions when these valves cannot be isolated or restored to Operable within the applicable Completion Time, while the unit is in Mode 4 or 5. This change is more restrictive on plant operation, since it adds Operability requirements for Mode 4 and 5 that do not exist in CTS. The addition of an applicable restriction in Modes 4 and 5 has no negative impact on safety.

Additionally, since hydrostatically tested valves

1eakage rate acceptance criteria need not be applied to Operability outside of Modes 1, 2. and 3. ITS SR 3.6.1.3.13 has a Note stating that the SR is only required in Modes 1. 2. and 3. This Note reflects an administrative change necessitated by the added conditions; but is discussed here for completeness.

H.4 CTS does not include requirements for secondary containment bypass -.

leakage paths. However. UFSAR Section 6.2.1.2.2.3 describes these paths and the associated leakage requirements. ITS 3.6.1.3 }.

Action D and SR 3.6.1.3.11 are included, as more restrictive requirements. to address this issue. This change is consistent with NUREG 1433.

l{T TECHNICAL CHANGES - LESS RESTRICTIVE

" Generic" LA.1 CTS Table 4.6.1.1 1, and various references to it in CTS LC0 3.6.1.1. will be relocated from the Technical Specifications to the Technical Requirements Manual (TRM). The specific relocation of component lists from Technical Specifications is consistent lh with the direction of Generic Letter 91 08 " Removal Of Component Lists From Technical Specifications." Relocation of the list of valves. their location, and associated penetrat. ion number,sto the TRM maintains the consistency with NUREG-1433. These details can be adequately defined and controlled in the TRM where changes will be controlled by the provisions of 10 CFR 50.59. These h

detail.s are not required to be in the ITS to provide adequate protection of the public health and safety since the requirement l for valve Operability remains in the Technical Specifications, c.

FERMI UNIT 2 5 REVISION Sa. 05/10/99l t

f

l i

DISCUSSION OF CHANGES 4 ITS: SECTION 3.6.1.3 - PCIVs l l

LA.2 CTS LC0 3.6.1.8 and 4.6.1.8.2 include details relating to purge system design (e.g., valve flow path diameter). ITS 3.6.1.3 makes 7 l generic reference to " purge system isolation valves" and does not o j include the details of system design. These details are relocated 6 l to the Bases. This is acceptable because these details do not - 1 impact the requirement to maintain the valves Operable and the ITS definition for Operability ensures that all equipment required to k ,

! maintain Operability is functioning. These details can be i I adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Esses Control Program. These details are not required to be in the ITS to l provide adequate protection of the public health and safety l acceptable because these details do not impact the requirement to

! maintain the equipment Operable.

l l

LA.3 CTS 4.6.1.8.2 details the purge valve leakage acceptance criteria.

ITS SR 3.6.1.3.6 presents only the requirement to perform the test, with the details of the acceptance criteria relocuted to the Bases. The acceptance criteria are used in the testing of the purge valves, but are not a direct assumption of accident lh ]

analysis. The 0.6 L acceptance criteria for combined Type B and C leakage rate testing still provides the 10 CFR 50 Appendix J limit, and the purge valve leakage is included in this total. The CTS purge valve acceptance criteria is used to monitor for gross leakage / failure and the specific value can be controlled outside l of Technical Specifications. Therefore, this requirement can be ad?quately defined and controlled in the Bases, which requires change control in accordance with ITS 5.5.10. Bases Control !

frogram. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the Appendix J requirements for valve leakage remains in the Technical Specifications.

l LA.4 CTS 4.6.3.5 requires periodic testing of the TIP System explosive isolation valve. This requirement provides details for the I selection of the replacement charge. ITS SR 3.6.1.3.10 requires i this same test but relocates the details regarding the selection i of the replacement charge from the Technical Specifications to the ITS Bases. These details can be adequately defined and controlled l in the Bases which require change control in accordance with I 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-end safety acceptable because these details do not impact !

the requirement to maintain the equipment Operable. ,,

FERMI - UNIT 2 6 REVISION Sa. 05/10/99l s

I DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs LA.5 CTS 3.6.1.2 LCO items d and e, and Actions d and e contain explicit acceptance criteria for the hydrostatic leakage test l limit. ITS SR 3.6.1.3.13 maintains the required hydrostatic leakage test, however, the specific acceptance criteria are relocated to the Bases. These details can be adequately defined -

and controlled in the Bases which require change control in .L !

accordance with ITS 5.5.10. Bases Control Program. These details ( l 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.

LR.1 CTS SR 4.6.3.1 requires a demonstration of operability after maintenance or repair on an isolation valve. The change removes )

this explicit requirement form Technical Specifications.

Verifying proper Operability, including stroke time, of these valves after maintenance on these valves is normal maintenance and operating practice. In addition. the requirement to verify the correct stroke time of these valves per the IST Program is required by ITS SR 3.6.1.3.5. Consequently. Operability of these valves is specifically required, and periodically verified. I Therefore, removal of the requirement to verify operability of the l l valve after maintenance is considered acceptable. The relocation l l of CTS SR 4.6.3.1 maintains consistency with NUREG 1433.

Regulatory control of changes to these requirements (e.g..

l Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and safety since Operability requirements for the valves remains a Technical Specification requirement. 9s LR.2 Not used.

l LR.3 Not used.

l Nl7 l

LR.4 Not used. le s

l l

g ,

si FERMI - UNIT 2- 7 REVISION Sa, 05/10/99l

.e

1 l

l l

I DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs 1

! ' TECHNICAL CHANGES LESS RESTRICTIVE

" Specific" i 1 i L.1 CTS 3.6.1.8 and 4.6.1.8.1, time limits on opening primary containment purge valves while aligned to SGTS. are replaced with specific criteria for opening. In conjunction with this, the surveillance frequency to monitor compliance is revised froa g "before being opened" to a nominal 31 days (which is typical of g other valve lineup SRs). These criteria are also applied to the . ;

1 inch valves (as a more restrictive change discussed here for completeness). The time limits were based on engineering judgment and/or early plant operating experience, and not based on any analytical requirements. ITS 3.6.1.3 limits on when the valves are permitted to be open are provided in the Note to SR 3.6.1.3.1.

The new limits will allow the valves to be open for inerting and de inerting. ALARA or air quality considerations for personnel l entry, as well as for Surveillances that require the valves to be open. Thus, use of the purge system will still continue to be ;

minimized and limited in extent. The operating history indicates that these valves are only opened for the specified reasons and for cumulative periods that are generally less than the current allowed cumulative times. In addition, these valves are fully qualified to close in the required time under accident conditions.

Therefore, this less restrictive change will have a negligible impact on safety.

L.2 CTS 3.6.1.8 and CTS 3.6.3 Actions for inoperable containment lrT isolation valves, and CTS 3.4.7 Actions for inoperable MSIVs, which require maintaining one isolation valve OPERABLE, would not g i be met in the event both valves in a penetration are inoperable. l In this event, an immediate shutdown (per CTS 3.0.3 for 3.6.1.8, CTS 3.6.3 Action a. or CTS 3.4.7 Action a.2, "otherwise ") is required. ITS 3.6.1.3, Action B provides I hour for restoration, prior to commencing a required shutdown. This 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period is consistent with time allowed for an inoperable containment, and is therefore an appropriate allowance.

1 3

FERMI - UNIT 2 8 REVISION Sa, 05/10/99l

DISCUSSION OF CHANGES i J

ITS: SECTION 3.6.1.3 - PCIVs i

l L.3 CTS 3.6.3 Action b allows only 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore EFCVs to Operable status or to isolate the associated instrument line flow path. Furthermore. CTS 3.6.3 Actions result in an immediate shutdown for penetrations that have a single PCIV that is inoperable. ITS extends the restoration time for these single valve penetrations to either 4 or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

. ITS 3.6.1.3 Actions C and D for inoperable EFCVs (also refer to ,

Discussion of Change "A.10" for administrative changes to the l presentation) allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the instrument line ;

flow path, and allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Each of these instrument lines at Fermi is designed with a small diameter, have an installed l restricting orifice, and terminate at an instrument transmitter l or similar device (which serves as another boundary).

Furthermore, an assumed instrument line break, with the failure ;

of the EFCV would still result in a response within the bounds i of the safety analysis. I

. Other single valve penetrations have extended restoration times 5 of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , unless they are on a closed system, in which case f j the time is extended to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Four hours is consistent -

with all other penetrations with a single inoperable PCIV. The 7 ,

g 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for single valves on a closed system recognizes the -

containment boundary afforded by the closed system. The majority of these single valve penetrations also terminate

(

below the minimum level of the suppression pool such that they are expected to retain a water seal (fission produce barrier) throughout the accident.

Allowing an extended restoration time to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , to potentially avoid a plant transient caused by the forced shutdown, is reasonable based on the limited time. Allowing an extension to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to potentially avoid a plant transient caused by the forced shutdown, is reasonable based on the probability of an EFCV or closed system line break (i.e., loss of the second containment boundary) ar.d represents a negligible impact on safety. (Note also, that approved generic changes to NUREG 1433 (TSTF 30 ,and TSTF 323) support 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for these penetrations.)

L.4 Not used.

D L.5 Not used. lg a

, x 33 FERMI - UNIT 2 9 REVISION Sa, 05/10/99l

I I

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs L.6 CTS 4.6.1.1.b. and 4.6.1.1.b.1 require periodic verification that the isolated penetration remains closed. ITS 3.6.1.3. Notes 1 and A

2 to Required Actions A.2 and C.2. and Note 1 to SRs 3.6.1.3.2 and

3. allow for administrative verification when the isolation device is in an area with limited access due to high radiation or is locked, sealed, or otherwise secured in the closed position.

h These allowances are acceptable alternatives for periodic re-verification. These controls on high radiation areas are required C by Regulation and are sufficient to assure the position of the isolation device has not changed, in lieu of the personnel d exposure that would be received in performing local verifications.

Sufficicn training and control of " locked, sealed. or otherwise secured" valves exist to justify not removing the lock or sealing y device simply to periodically reconfirm the position of the valve.

Therefore, this change is does not involve a significant impact on safety. The change is consistent with NUREG 1433. ;

L.7 CTS 4.6.1.8.2 requires leak testing the purge valves with resilient seals once per 92 days. ITS 3.6.1.3.6 requires this testing every 184 days, with the added limitation of once within 92 days after opening the valve." Since the re-closing of an opened purge valve that has resilient seals is a major factor in deterioration of the sealing capability, extending the leak test from 92 days to 184 days for purge valves that have not been opened is deemed acceptable. Furthermore, plant specific .

experience with purge valves that have not been opened I demonstrates the continued expected leak tightness of these valves when tested at the current 92 day frequency. Therefore, extending I the frequency ~to 184 days (in accordance with NUREG 1433) does not involve a significant impact on safety.

L.8 CTS 4.6.1.1.b requires the periodic verification of the closed status of non automatic PCIVs. If this requirement can not be met, the Actions of 3.6.1.1 require restoration in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to l commencing a shutdown. ITS 3.6.1.3 provides these SRs as part of the PCIV specification, and results in restoration times of from 4 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to commencing a shutdown. These extended Completion Times are consistent with NUREG 1433 (as modified by 4.

approved TSTFs), and are in recognition of the limited impact on the overall containment function and the reasonableness of a limited time to affect repairs prior to commencing a plant shutdown transient.

si FERMI - UNIT 2 10 REVISION Sa, 05/10/99l l- ,

L

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs L.9 CTS 4.6.3.4 requires testing to verify that each EFCV " checks fl ow. " ITS SR 3.6.1.3.9 (consistent with NYREG 1433) requires verification that each EFCV " restricts flow." While actual implementation, practice, and interpretation is unchanged by this revision, the CTS wording " checks flow" could be interpreted to 6 >

require a zero-flow acceptance criteria, while the ITS wording

" restricts flow" is interpreted to limit leakage to some positive w value, but to within values that support the " radiological %

assumptions." This relaxation is acceptable since the result continues to provide assurance that the radiological consequences of analyzed events remains within assumed limits.

L.10 CTS 3.6.3. Action a.3, explicitly lists some, but not all, possible acceptable isolation devices that may be used to satisfy isolating a penetration with an inoperable isolation valve. Many penetrations are designed with check valves as acceptable isolation barriers. With forward flow in the line secured, a check valve is essentially equivalent to a closed manual valve. M Therefore, the action has been modified to provide a more explicit i list of acceptable isolation devices, which includes a check valve with flow secured. Since the result of the action continues to be

{

an acceptably isolated penetration for continued operation and is consistent with the intent of the CTS action, the change does not involve a significant impact on safety.

L.11 CTS 4.6.1.1.b and 3.6.3 Action a.3 contain a requirement for a

\

manual valve (which is closed to isolate a penetration) to be locked. CTS 3.4.7 Action a.1.b) requires use of a deactivated j M5IV, which. in the case of the third MSIV, is a type of " locked" j ma.wl valve. With a penetration closed using a manual valve, a '

passive barrier is established, i.e., one not subject to a single !

active failure. ITS 3.6.1.3 Actions, ITS SR 3.6.1.3.2, and SR 3.6.1.3.3 do not detail the locking (or deactivating) of manual I valves used to isolate penetrations. Regulatory control of changes to these requirements (e.g., Technical Specification 4-amendment or 10 CFR 50.59) is not necessary to provide adequate 1 protection of the public health and safety since Technical.

Specifications continue to require that position and since the k

safety significant position of the valve is adequately assured.

This change is consistent with NUREG-1433 and with approved generic change TSTF-45.

c.

FERMI - UNIT 2 11 REVISION Sa, 05/10/99l )

t

r i

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs l L.12 CTS 4.6.3.2 requires an automatic isolation valve test, but restricts performance of this test to "during Cold Shutdown or l Refueling." ITS SR 3.6.1.3.8 requires this same test, but removes

)

I details regarding requisite plant conditions and scheduling. ;

These details do not impact the requirement to maintain the valves e Operable, and the ITS SR continues to ensure that all automatic '

PCIVs function properly. Therefore, this change will not have any d.

negative impact on safety. Removal of this restriction was recommended by and supported in Generic Letter 9104, and is ( !

consistent with the ISTS NUREG 1433. It is further noted that the I ITS Bases continue to acknowledge that, at least for many of the PCIVs, it is prudent to conduct the testing during outages.

Evaluation of prudent scheduling will continue in recognition of the potential plant disturbance some isolations can cause.

1 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 3.6.1.3 consistent with the BWR STS, NUREG 1433. Rev. 1.

FERMI UNIT 2 12 REVISION Sa, 05/10/99l

l i

PCIVs ;

3.6.1.3 )

3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs) CT5 LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE. M M'h 4

APPLICABILITY: MODES 1, 2, and 3,

{

When per LCO associated instrumentation 3.3.6.1, " Primary Instrumentation."

Containment Isolationis required to be OPE ACTIONS g 4 1

_________________________________ NOTES _------------------------------

4

1. Penetration flow paths Fa-rar+ #-

rg . .. e....irai.iw Tia RO.4}dmadC l t,9cnoar) be unisolated intemittently under administrative controls.

y,g,3 9 )

2. Separate Condition entry is allowed for each penetration flow path. (poc48)

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs. 4 Doc. A.1 )

Q.s.3 kt;rn b,1)

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, " Primary j Containment," when PCIV leakage results in exceeding overall containment \g 4'qs/

leakage rate acceptance criteria in MODES 1, 2, and 3.

CONDI710N REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Isolate the affected Only applicable to penetration flow path 4hoursexcepth.3Mwa%

for main steam penetration flow paths by use of at least line with two PCIVs. hM,$,/kwu of one closed and -

de-activated automatic valve, Ngl Q 4-One or more closed manual valve, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ' for main "

penetration flow paths blind flange, or steam line with one PCIV check valve with flow g,q' bg\/

inoperable gexcept done through the valve h'ut )o; f E ; 1 --e 1 es kage secured. '

, .S notwithinlimity.

f5 S

$.Q (continued) iM V4 SV6 3.6-8 8-" 4, O'.l^7/95-E N 4 4

3%

N

1 l l l PCIVs 3.6.I.3 l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) -

A. 2 @high------NOT Isolation devices in radiation areas [4.G.I. l .b) may be verified by '

use of administrative i INS W l 3.<,.i.3 - I -f ?. N .....

Verify the affected Once per 31 days l C3 penetration flow path for isolation 1 is isolated. devices outside ,

,. imary I containment i AND Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside l

primary d containment (continued) l l

a;/4 07$ 3.6-9 h v 1 . - M /.w y ss .

l

p

{

I PCIVs 3.6.1.3 f 1

l l

Insert 3.6.1.3 1

2. Isolation devices that are locked, sealed, or otherwise secured l

may be verified by use

of administrative means.

.n ,

S$

FERMI UNIT - 2. Page 3.6 9 (INSERT) REVISION Sa. 05/10/99l s

f 4

PCIVs 3.6.I.3 ACTIONS (continued) p j CONDITION REflUIRED ACTION COMPLETION TIME I'

-f f

B. --------- NOT E-------- B.I Isolate the affected I hour E Only applicable to penetration flow path V penetration flow paths by use of at least with two PCIVs. one closed and de-activated get. 2. )

automatic valve, One or more closed manual valyc, penetration flow paths or blind flange.

OP.g D

with two PCIVs (dw, ge -d notwithinlimitg. D C. --------NOTE--- --- C.I Isolate the affected l[4}_hoursexcept 9 only applicable to penetration flow path or excess flow 9 penetration flow paths by use of at least y 1

check valves I with only one PCIV. one closed and (EFCVs) ,

de-activated ,

automatic valve, E l One or more closed manual valve, ;

oc i penetration flow paths with one PCIV inoperablev feyce_p_t-gD or blind flange, h

ours EFCVsk (for _ __

g) f feb 64o fealca4L hof _

g , y J., C.2 --------NOTf------- 4 kAd P"(kab>

4 Mfk a dostd

l. Isolation devices in

_~~ high radiation areas may be verified by

'g Dg" ./

f / NSEtT use of administrative V l

,{2.(,.l.3-2-- ~means.

Verify the affected Once per 31 days penetration flow path is isolated.

l0. Secondary bypass akager.tainment rate Jrff Restor eakage rate ihours to hin limit.

)(not hin limit.

a <

(continued) [

.L C i4 sys 3 6-10 r

mseer 1 22 1. M/07/05 $

f4 3.4.l.3-33 '

9 m

4

l PCIVs Insert 3.6.1.3-2

2. Isolation devices that are locked, sealed.

l or otherwise secured l may be verified by use l of administrative means.

Insert 3.6.1.3 3 l

l CONDITION REQUIRED ACTION COMPLETION TIME l

D. One or more secondary D.1 Restore leakage rate 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for leakage on Lt.1 containment bypass to within limit. hydrostatically tested (Ad"5 leakage rate, MSIV line leakage rate. purge valve leakage rate. M hydrostatically tested line leakage 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for secondary (DocM) rate. or EFCV leakage containment bypass l rate not within leakage 4 l limit.

M .

1 l

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV (DocM.t) leakage M

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for purge I

valve leakage 3Web M I- )

M 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for EFCV /3 L3 leakage (Hab 1

I l4 .

FERMI UNIT 2 Page 3.6-10 (INSERT) REVISION Sa. 05/10/99l l

2

PCIVs l 3.6.1.3 l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. (c tinued) E.3 Perform SR 3.6 .3.7- Once pe for the resil ent [92) ys seal purge 1ves ;

closed to aply with Required etion E.1.

Required Action and f.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

' ' D'* " 8 associated Completion 3.63, Sened a,b)

Time ondition A, AliD B, C.

in MODE L'not met 2, or 3. .2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months O C A'N 4'h 5

I' r

[ Required etion and G.1 ------NOTE------ --

1 associat Completion Time of ondition A, LCO 3.0.3 is not applicable.

g B, C, , or E not met - - - - - - - - - - - ------

p,% for P IV(s) required to OPERABLE durin Suspend no nt of Immediat y ement of irradia d irradiate fuel

" el assemblies in assembli s in

[secon ry)

/c. ontainment.

secondary] cont nt.

H. Req red Action and 'H.1 Suspend C Imedi ely as ciated Completion ALTERATI S.

p,% me of Condition A

, C, D, or E not t for PCIV(s) requ ed to be OPERABLE ring CORE ALTERATI .

/

(continued) h WR/4-373- 3.6-12 Acv-1,01/07/05-SI 4

a

PCIVs 3.6.I.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME (eh -

F) -

f,s( Required Action and

., . Initiate action to Innediately associated Completion esapend 07;~! isololt / \

of _ Time of Condition A, R gR- bWown B, C,*Dr-ee-E-not met k0#c M'32 forpFCIV(s) required QB cog l,0 59 34ew NN~ to be OPERABLE during .2 Initiate action to Immediately MODE 4 or 5 = i 'r-l restore valve (s) to 7 :

)/ :; netien; ith-: b OPERABLE status. I l

?!55'}

".C. .' " .' "L' OL.

v . r , ..

k fI',J,

. '. .-~' [

<t g

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3. - - - - - - - - - -

---NOTE- - - - - -

Only require to be met in MODES 1 ,

and 3.

Verify each 1: 18 31 day purg valvenss)ealed'closedexinch ptprimary for co ainment one urge valve in a penetrati n flow p while in Condition E of his LCo.

(cont'inued) 96/4-CM 3.6-13 6 1, 00/07/05 R5y G

=>

l l l i

l l

PCIVs 1 3.6.1.3 l l SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY R 3.6.1.3. --------- --NOTE --------- - - - - - - -- ,,. P M p,>; .,, n -

W'?nviWWNN, ~

x dvd f>r W g. Not required to be met when ther-

/

[E"f[MfY % ,'istisr are open for inerting, ' ' J.6,f S, lh4Ne@ l de-inerting, pressure control, ALARA MI crftenmat -hgWf th or air quality considerations for ,nggg.g s p<<ssure personnel entry, or Surve111ances -

ce@l that require the valves to be ope . Utsv re unio (

g:,',' (andad Wre ssionckauw po% Sys4ex Q usatak I

?

Verify each fib" i..a L 1--r-

-valve is closed.

: -- O 31 days .b l .%.. )

SR 3.6.1.3 -

NOTE S --------------

1. Valves and blind flanges in high 4.G.I.I.b.2-radiation areas may be verified by pd g,,

use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

4lall O 3,y,3 g Verify each primary containment isolation 31 days manual valve and blind flange that is (46.t.l.bb.7g/ y and located is required outside to beprimary containm% accident closed during conditions is closed.

l

/ (continued)

C.\ "" "^ '**d awla ?

e oSuwise .recond E QC

"- 1,04/07/95 M./t STS 3.6-14

, $5V &

51 J

r

1

(

PCIVs l 3.6.1.3 SURVEILLANCE REOUIREMENTS (continued) !

i SURVEILLANCE FREQUENCY l

SR 3.6.1.3. - - - - - - - --NOTES------------------

1. Valves and blind flanges in high poc L,6N radiation areas may be verified by /

use of administrative means.

2. Not required to be met for PCIVs that are open under administrative b I"'I'I' D )

controls. (3.G.'3**)

Verifyfeachprimarycontainmentlaanual Prior to P.4 (isolation) valve and blind flange that is enteringMODE2(Q.4.1.1,b. i located inside primary containmen and is or 3 from requiredtobeclosedduringaccid(ent MODE 4 if conditions is closed. primary ,

containment was '

ad IS Cd de-inerted !

lockel, sealeJ. while in O ar 04euT5c. MODE 4, if not .1 C.l (.5zcv r<A Pi[i,1, $

previous 92 days SR 3.6.1.3 Verify continuity of the traversing 31 days incore probe (TIP) shear isolation valve (t/,(,,3 g, gh explo'sive charge.

SR 3.6.1.3 Verify the7 isolation time of each power In operated G5d_::"0 automatic PCIQ, except accordance

/q,(e.J3)

N forMSIVs,{iswithinlimits with the '

g Inservice Testing '

Program w=-

AW:- )4

? -

(continued)

BWR/4 :T: 3.6-15 he 2, et/07/es (fg 4 5

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY h3.6.1.3. /

97 -

NOTEk- -----------

-.{.L- &,b .e.,,.i. J iu uw =v6 in 6 5E5 i,

' ' ) -- [dppl;caloft 4o],,,,

% Results be era',uated shallcriter against .

acceptance a d=SE 3.6.1.1.1 . .

3. . m ,e.. u m se er. -- -

L _.r

. _ _g.w rg- v. _.- a7-K. . - "' :' "

_h.

i rr - - - - .

g,g D

-ort hd _ Verifysecondary the combined containmentleakage rate for all bypass leakage- T-S Z3.0. --NOT --] i

'pog;3egi / pathstis s t i.,}-when pressurized to s not i 2 4 psig)r, a (ppli ble i W'A ^ ,

0.04 , -J j StAl5fshp %'T ;

~

, In accordance tkPrima/ OorM.omi with fel ..- bCakay NNnj en i J. T b

5 "' fi' !

frv0(8* CLWd y rov d .)g< 1 p,l lnsayvice Tashog y ng ,J

( Pro v a m f -

60 0 - - -

SR 3.6.1.3 Verif leakage ratt,64v=. :. -- ' RR is ----

TE

/

5, ,

y scfh whenftested at SR .0.2 (.5411.c.

Condrded 2 :psig. ' pw ag ,G not (4.0.flh M51V *i 4, g ng a ,,

i, PPli

- l' [

I

/ In accordance I

with ri lmm i

}a. Prima /1 % inn *Ml;; 37 aWified-LL ea(cap cak.T4sh,nj frbgram J vy p m veu em u uni JC h- -

, (continued)

"'.l"/4 -070- 3.6-17 Rev 1, O'/^7/95- i g M h

% A

l PCIVs 3.6.1.3 ;

l l

SURVEILLANCE REQUIREMENTS (continued) , j SURVEILLANCE FREQUENCY l l

~ -

\

SR3.6.1.3.}I -=-

NOTE--- -

Only required to be met in MODES 1, 2, (Doc M 3) i

,and 3. 9' ' i Ns )

Op.s -

l Verify combined leakage ' "' rategP" ;--

P NOTE --] q.6.i.L fthrough S 3.0.2 ,g,4 y

+4 . +L. .-- -

hydrostatically tested lines that not i appli le penetratetheprimarycontainmentisp:-

c-4=^ "-~ +'- e 4 c- - - - - - - - '%

] teh*I4-- :&::.

, h=etd +?i =*4a '

d.

p,] In accordance W" @8 bin II'Er -b' Q Cm b eut h M.dkTeskaq ,[P"gyl

[Lutcap ifi 8topom J by lax pr ed t ns) i SR 3.6.1 .15 ------------- --NOTE------------

Only requir to be met in MODES 1 ,

and 3.

f .) Verify ch [ ] inch primary ntainment [18] mon s purge lve is blocked to res ict the valve rom opening > [50]%.

l l

l 4

m /: STS 3.6-18 am 1, ^:/^7/^'r II d I r

1 PCIVs !

B 3.6.1.3 I y B 3.6 CONTAINMENT SYSTEMS B 3.6.1.3 Primary Containment Isolation Valves (PCIVs) l BASES l t

BACKGROUND The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs) to within limits. Primary containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a D8A.

The OPERASILITY requirements for PCIVs help ensure that an adequate primary containment boundary is maintained during and after an accident by minimizing potential paths to the environment. Therefore, the OPERABILITY requirements l provide assurance that primary containment function assumed in the safety analyses will be maintained. These isolation devices are either passive or active (automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that i Y

@, no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that i exceeds limits assumed in the safety analyses. One of these lbj$GTLT- . barriers may be a closed system. S 6 3.W 34'* The reactor building-to-suppression chamber vacuum breakers serve a dual function, one of which is primary containment isolation. However, since the other safety function of the vacuum breakers would not be available if the normal PCIV actions were taken, the PCIV OPERABILITY requirements are not applicable to the reactor building-to-suppression chamber vacuum breakers valves. Similar surveillance requirements in the LCo n for reactor building-to-suppression chamber vacuum breakers provide assurance that the isolation i f,tf capability is available without conflicting with the vacuum relief function. __

(continued) r/' n! B 3.6-14 " f 1, ^'/07/95 r

,g

1 l

l 1

PCIVs B 3.6.1.3 l

BASES APPLICABLE (conte pr:d::t; 4nment te th; c'JirTrftbi.iW a n nt i; ;e.3-e' 'i :in t> hat re'eara st ;11;d.

T.N SAFETY ANALYSES (continued)

Ah : ^** n:1ysi; n :x:: ti.

.;U,i, e .... 2 : -:nc 1 l eccident, iselatien ef the priee y eeatei - a+ i is ea-late-f indage in i.. ; net W , sassps for tne maximum ii .Lig i k- '

leet; 7.te , L . ": ;-' r y ::-tt'- rt ' e! tice tet:1 l ymenaaea t4mm at 6n earnade inelm4me einaal Am1mv discal

ste- startep (fer less ef e'fsita.nament ead *CIV st-ake tf w I

ins ULT,j' y 3 (The single failure criterion required to be imposed in the i F2 3 conduct of unit safety analyses was considered in the original design of the primary containment purge valves.

Two valves in series on each purge line provide assurance that both the supply and exhaust lines could be isolated evenifasinglefailureoccurred.)

e primary containment purge valves may oe unanie 6 ' rest-In vironment following a LOCA. Therefore f the purge valv required to remain sealed c1 during MODES 1, 2, and . n this case, the single failure criterion remains app e to the primary containment o1 I' purge valve due to failu control circuit associate with each valve. T rimary conta t purge valve desig precludes a s failure from compromis he primary contai undary as long as the system is o at(in

_ _:::: rith 4+

LCa '

P.l0 PCIVssatisfyCriterion3of@th:""O".,1;---Otet:--'Q FR SDM(O%

LC0 PCIVs form a part of the primary containment boundary. The PCIV safety function is related to minimizing the loss of reactor coolant inventory and establishin the primary containment boundary during a DBA.

The power operated.$ u b ic isolation va ves are required to have isolation lines within limits and actuate'on an The L'*' i-9 pr ;: " '--- - -*

automaticisolationsig:nal."

"" ^

'-d "

nir.s,] . 2. " 1.

M er: e. actorn building-to-suppression d ';r S.n $ d t: pr; n nt t',1-chamber vacuum breakers isolate primary containment penetrations A

-4 hey are excluded from this Specification. Controls on \ g their isolation function are adequately addressed in LCO i

(continued)

" /d MS B 3.6-16 *:v 1, ^'/07/^5 N I

a,*.

s E

I PCIVs B 3.6.1.3 Insert B 3.6.1.3 3 The Main Steam Line Break (MSLB) is of particular importance due to the radiological consequences of the steam release outside of the primary containment. The closure time of the MSIVs is a significant variable from a radiological standpoint. The MSIV closure is assumed to occur no later than 10.5 seconds following the event initiation. The requirement that the MSIVs close within 3 to 5 seconds is consistent with this assumption.

The accident analyses assume that PCIVs that automatically close have stroke times no greater than that given in Reference 2. In addition to the stroke time, an additional delay of 13 seconds is assumed for isolation signal delay, and diesel generator startup (for loss of offsite power). Following the completion of the automatic containment isolation the analyses assume that containment leakage is terminated , except for the maximum allowable leakage rate, L,.

The PCIVs are also required to function to minimize the loss of reactor coolant inventory and thus minimize the radiological consequences of postulated failures outside of containment of systems that directly connect to the reactor coolant system.

These failures are also evaluated to assure that the ability to safely shutdown the plant is maintained.

3

= ,

Y*

FERMI UNIT - 2 Page B 3.6 16 (INSERT) REVISION Sa, 05/10/99l t

I PCIVs B 3.6.1.3 BASES h

I w

LCO 3.6.I.7, ' Reactor Building-to-Suppression Chamber Vacuum (continued) 'k Breakersy*

their assoc iated stroke times in Reference 2.The valves covered by this LCO are lis

,Tk anrmally closed Pcive are raa=4a...A nornaar_ r f-p.... 1 .. ... ... e n ad,x :;= e = = = = =

=;H

t: :f-tai:tr:tiv: satre u , st;ntie selve; . . x N

f. 'A & Mtiv:ted rd :=:r:d in tMk :in;d p. i6 ion, uiind--

flea Or: h pi n;, ..~ 6; v vu .y. i. . .. . inteet. TMn }j passk: h e'eti 'cav=1va' =ad daui'^' e-- th M ' St:d b -

.Jteferene; 2.

~

GCrMjnMEt40 Purge valves with resilient seals, secondary bipass vaFres, f,1 MSIVs, and hydrostatically tested valves must meet Wr te1eakage rate requirementsy"Primarr are addressed by LCO 3.6.1.1, Co_ntaineeJfther " PCIV leakage gg as ype 8 or C testing. j; w g This LC0 provides assurance that the PCIVs will perTorm their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive saterial to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitatians of these MODES. Therefore, most PCIVs are not required to be OPERABLE - ' - - '--- sateh ..; p., v. i ... .. . ..et-P.2 n;:ind t h :n kd ;h ad in MODES 4 and 5. Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.I, " Primary Containment Isolation Instrumentation." (This does not include the valves that h isolatetheassociatedinstrumentation.) g ,

ACTIONS The ACTIONS are modified by a Note allowing ' penetration flow 4

[.3 path (s))@,. set '.. ;.r; :1 x " n ;:'M- M to be g unisolatedintermittentIyunderadministrativecontrols.

These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous p

~

i (continued) ,

C/i US B 3.6-17 ?_ ; 1, etl0?l95

(

.,. =,

l 6

{

j PCIVs B 3.6.1.3 BASES

}

ACTIONS communication with the control room. In this way, the (continued) penetration can be rapidly isolated when a need for primary containment isolation is indicated. Due to the size of the primary containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves is not allowed to be opened under administrative controls. A sin;'e p rg: she 1,. . -

pe-et-etien 5 p!!'- y 9 - :r.;d b eTiect repairs-te :n Of.7- inoM-eMe =:h., es ell;ud q % 0.0.i.3.1.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve). Note 4 ensures appropriate remedial actions are taken when the primary containment leakage limits are exceeded. Pursuant to LCO 3.0.6, these actions are not required even when the associated LC0 is not met.

Therefore, Notes 3 and 4 are added to require the proper actions be taken.

(itJsewr 4 P.3 a.i and a.2 , g s, c,.i. 3 - s La. I With one or more penetration flow paths (with one PCIV inoperable fexcept for 7 r:e v? ue1 leakage +not within k

limitt, the affected penetration flow paths must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be a'dversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. For a penetration isolated in accordance with Required Action A.1,

~

(continued) nung eTe B 3.6-18 ";; I, 0i/07/ L

+..

~Av L 4

p PCIVs B 3.6.1.3 Insert B 3.6.1.3 12a (i.e.. secondary containment bypass leakage rate MSIV i leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV leakage rate) l 1

l l l i

l

. 1 1 -

s.

FERMI UNIT - 2 Page B 3.6-18 (INSERT) REVISION Sa, 05/10/99l L .

PCIVs )

B 3.6.1.3 BASES ACTIONS A.1 and A.2 (continued) the device used to isolate the penetration should be the 1 closest available valve to the primary containment. The Required Action must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Q

Completion Time (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam lines). The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the time required to isolate the penetration and the relative importance of supporting primary containment OPERASILITY during MODES 1, 2, and 3. For main steam lines, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed. The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the main steam lines allows a period of time to restore rd the MSIVs to OPERABLE status given the fact that MSIV to I

closure will result in isolation of the main steam line(s) and a potential for plant shutdown. R I For affected penetrations that have been isolated in T

accordance with Required Action A.1, the affected penetration flow path (s) must be verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following i an accident, and no longer capable of being automatically l isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside primary containment' is appropriate because the l devices are operated under administrative controls and the probability of their misalignment is low. For the devices inside primary containment, the time period specified ' prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days' is based on engineering judgment and is considered reasonable in view of the inaccessibility of the s devices and other administrative controls ensuring that M device misalignment is an unlikely possibility. f Condition A is modified by a Note indicating that'this E Condition is only applicable to those penetration flow paths E f'3 with two PCIVs. For penetration flow paths with one PCIV, cr Condition C provides the appropr eautred Ae+1ons.

Gr.Rek 1) h Required Action A.2 is modified NotH ths> applies to isolation devices located in high radiation areas, and J (continued) r /4 m B 3.6-19 h 1, 04/07/5

" '~

~

_,,RemJ5~A

PCIVs B 3.6.1.3 BASES ACTIONS A.1 and A.2 (continued)

C3 aiiows them to be verified by use of aeministrative means.

Allowing verification by administrative means is considered INSE/zT acceptable, since access to these areas is typically restrictec.4 Therefore, the probability of misalignment of' bbIbl these devices, once they have been verified to be in the a

proper position, is low.

$3 u With one or more penetration flow paths with two PCIVs 1 )

g

/A/S M inoperable,+either the inoperable PCIVs must be restored to %

B M t 3- r 2. ; OPERABLE status or the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must '(

include the use of at least one isolation barrier that cannot be adversely affected by a single active failure.

Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LCO 3.6.1.1. ,

to Condition B is modified by a Note indicating this Condition -f is only applicable to penetration flow paths with two PCIVs. @a, For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions. g N5ET2-T-l C'I f,6 '"d C'I

% I,3- l'2 - g a With one or re penetration flow paths with one PCIV VI inoperable,Vthe inoperable valve must be restored to g OPERABLE status or the affected penetration flow path must <w be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers s that meet this criterion are a closed and de-activated n automatic valve, a closed manual valve, and a blind flange. .

A check valve may not be used to isolate the affected E penetrationgevised ,tdier, '.1 :=t M rghtd dt"=

4h. [G ix. 2;hth: "

9 The Completion Time of J.

oursjis reasonable considering the relative stability f.b , tne closed system (hence, reliability) to act as a T<

penetration isolation boundary and the relative importance For pcxdroFms q of supporting primary centainment OPERABILITY during w;& a closed DM (continued)

SWRt4 STS- B 3.6-20 h 1, 04/C7/;5 e, *%

l PCIVs B 3.6.1.3 Insert B 3.6.1.3 11 Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.

l l Insert B 3.6.1.3 12 (2 places) l

.. except for leakage (i.e., secondary containment bypass leakage rate. MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV leakage rate) not within limit, _

l 1

l I

l FERMI UNIT - 2 Page B 3.6 20 (INSERT) REVISION Sa. 05/10/99l l

ls

l J

PCIVs B 3.6.1.3 BASES ACTIONS C.1 and C.2 (continued) ,

MODES 1, 2, and 3 + The Completion Time of M hours'is M Tl'e cggg ,Y4 reasonable considering the instrument and the small pipe g gvsf Mett tIAL diameter of penetration (hence, reliability) to act as a -

penetration isolation boundary and the small pipe diameter- Z NTMuv.cuil o f of the affected penetrations. In the event the affected g

((, @eret. N .. penetration flow path is isolated in accordance with Required Action C.1, the affected penetration must be -

verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations k

f.fo required to be isolated following an accident are isolated.

The Completion Time of once per 31 days for verifying each ,

affected penetration is isolated is appropriate because the i valves are operated under administrative controls and the probability of their misalignment is low.

Condition C is modified by a Note indicating that this Condition is only applicable to penetration flow paths with only one PCIV. For penetration flow paths with two PCIVs, Conditions A and B provide the inte R==? d Actions.

. MAe o ,

Required Action C.2 is modified applies to No l valves and blind flanges located in high radiation areas and )

allows them to be verified by use of administrative means. i Allowing verification by administrative means is considered l acceptable, since access to these areap is typically i restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper po:ition, is low. ~

o it.e o r m o%

-S

% IASE W g g I

- With h secondary containment bypass leakage rate ;r "I!Y 1*% rm not within limit, the assumptions of the safety f,h f analysis may not be met. Therefore, the leakage must be h restored to within limit,;;ith'r t he r;. Restorationcanbe.) ,x l

accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated O automatic valve, closed manual valve, or blind flange. When W a penetration is isolated, the leakage rate for the isolated ~

penetration is assumed to be the actual pathway leakage .~A- l through the isolation device. If two isolation devices are 2 used to isolate the penetration, the leakage rate is assumed

. b (continued) 1T/4 S'S B 3.6-21 L 1, 04/07/95 s-a k

PCIVs j B 3.6.1.3 Insert B 3.6.1.3-13 Note 2 applies to isolation devices that are locked, sealed.

or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.

Insert B 3.6.1.3 4

_ (SR 3.6.1.3.11). MSIV leakage rate (SR 3.6.1.3.12), purge valve leakage rate (SR 3.6.1.3.6), hydrostatically tested line leakage rate (SR 3.6.1.3.13), or EFCV leakage rate (SR 3.6.1.3.9) _

i 1

FERMI UNIT Page B 3.6 21 (INSERT) REVISION Sa, 05/10/99l

/

PCIVs B 3.6.1.3 I

BASES e

.-l%4ed IiM.5 Wi hovt a clo 3 ACTION D J (continued) QMdbyhd$ MO

sed SS lea kD W

"ISlSh

\n p.s to se the iesser actuai a,..ay >eas ge of the t.o devices.

.1 The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time 91s reasonable considering the s M time required to restore th'e laaksge by isolating the M( T:r

-- pene.tration

-* and the relative importance of sura. der, PC/V g7 m. .4

" -- leakage to the overall containment M.G.I.'5 - C i "Y -

E.1. E.2. r.d E ! .

In e event one or more containment purge y s are not within he purge valve leakage limits, p valve leakage must be cred to within limits or affected penetration t be isolated. Th thod of isolation must be by the use o least one ation barrier that cannot be adversely affect a ngle active failure. Isolation barriers that meet thi iterion are a >[Tclosed and de-activated automa va closed manual valve, and blind flange % If a e valve w resilient seals is utilized I to satisfy R p.'$ demonstra red Action E.1,

- SR 3.6 . 7. The specified Completto must have been to meet the leakage re recents of ime is reasonable, /

Y:I

)

[ cons ering that one containment purge va s hat a gross breach of containment does n exist.

remains closed

/

~ accordance with Required Action E.z, snis pennrsiipp f1 ath must be verified to be isolated on a peri e basis. The periodic verification is necessary to sure that con neent penetrations required to be i ated i following a ccident, which are no longer able of being i automatically lated, will be in the ation position should an event o r. This Require tion does not require any testing valve mani ation. Rather, it involves verification t th isolation devices outside j containment and potentia 11 apable of being mispositioned I are in the correct posi n. F r the isolation devices I inside containment, e time pa(rt specified as " prior to entering MODE 2 from MODE 4 if t performed within th i previous 92 d " is based on engineer judgment and is fconsidere easonable in view of the inac sibility of t isolat devices and other administrative e rois that wil nsure that isolation device misalignment an

_ 4halv anetibilitw a

~

(contknued)

/4 ns s 3.6-22 5; :, 0e/07/05

~ '

_,. . (EV h.

9

=

1 PCIVs l B 3.6.1.3

]

Insert B 3.6.1.3-5

. . For MSIV leakage, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed.

The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV leakage allows a 1 period of time to restore the MSIVs to OPERABLE status given the fact that the MSIV closure will result in isolation of the main steam line(s) and potential for plant shutdown.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for purge valve leakage is acceptable considering the purge valves remain closed so that a gross breach of the containment does not exist. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for leakage on hydrostatically tested lines on a closed system is acceptable based on the l available water seal expected to remain as a gaseous fission !

product boundary during the accident and the associated l closed system. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for EFCV leakage !

is acceptable based on the instrument and small pipe !

diameter of the penetration (hence, reliability) to act as a l penetration isolation boundary. j l

l . - -

FERMI UNIT 2 Page B 3.6 22 (INSERT) Revision Sa, 05/10/99l

1 l

1 PCIVs i B 3.6.1.3 j l

BASEL ACTIONS U . 51. .nu t.s won 6.nuva) j r the containment purge valve with resilient seal th s is61sted in accordance with Required Action E.1, SR 3.6.I'.3. must be performed at least once y [] days.

This provid{s-assurance e that degradattoru he resilient seal is detected'amLconfirms that t eskage rate of the containment purge valile dges o crease during the time the penetration is isola e' s he normal Frequency for i SR 3.6.1.3.7 is 184 Since'more e reliance is placed on a single valve in this Condittorr, sit is prudent to perform th more often. Therefore, a FFequency of once I per ays was chosen and has been shown to be acceptibi K b on operating experience. N

/' -

m 5.1 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

T.I. 1.1. anu _ _ _j 1.m w

If any Required Action and associated Completion Time cannot be met, the unit must be placed in a condition in which the LC0 does not apply, ff !;;14-91e C^^' ^.' TE".T!"' -d .

irreu; tev fuel ssemblies st be i te y Es.;;.;*vi ed. Susp sion of ese acti ties shall f'I p ude comp 1 ion of emen - - aaad +

-di t kr . A.;; if .pp.i; dl.(t a'I'ctionhustbeimmediately

=nd initiated to uspena operations witn a potential for 3 ra n n e sa rv (0PDR imi t proba t o y el raind a bse n te tal Igo(Mt

' y fo s V are s n r en et an eas alv Ac a

s epn inu estored OPE ntil e st s sus di an 0 V dr uit clo g th I (hp ,g (od8]

si he ( s down el iso ion

,,,,,,h k . sn to tive equ ed Act ni prov ed t ,,,,,,

Sj5TW * -

(continued) r/' "5 B 3.6-23 ";. 1, 04/07/g',

s p # /

gev5; I

e

l PCIVs B 3.6.1.3 _

7 BASES ;-

ACTIONS .1 1 1. i.i. ana Q (continued) -l1ETrj$5/2T f m i d ittely initi:t 20tiaa t: n:t:n th: d ve(s) to

                           ' UPERABLE status. Thi. .iivws snR tv , -.in in .....e;             t.ile b, N I 3-7 h               et % in M ,r 4 W n te-- * %

y - -- J \ SURVEILLANCE ^ SR 3.6.1.3.1 1 REQUIREMENTS E h [18] inch primary containment purge valve is requir to verified sealed closed at 31 day intervals: This/3R i is d 'igned to ensure that a gross breach of primary / contai nt is not caused by an inadvertent or spur 16us . opening f a primary containment purge valve. Detafiled I analysis the purge valves failed to conclusivrfy ' demonstrate heir ability to close during a LOCK in time to limit offsite oses. Primary containment pur 'e valves that l are sealed clogd must have motive power to he valve l operator removed.s This can be accomplish by de-energizing i the source of elec ic power or removin he air supply to l the valve operator. In this applicati , the term " sealed * ' has no connotation o 'eak tightness The 31 day Frequency is a result of an NRC eric Issue B-24 (Ref. 4), related to pr%itiative, i ry cont G nt purge valve use during unit operations. / This SR allows a valve that i open under administrative controls to not meet the S ur g the time the valve is open. Opening a purge va e unden is restricted to one valv'e in a pen't.tration administrative flow path controls at a given time (refer to d,tscussion for Ngte 1 of the ACTIONS) in order to effect rppairs to that valve. This allows one purge valve to be 9pened without resulti in a failure of the Surveillance d resultant entry into e ACTIONS for this purge val provided the stated rest ctions are met. Condition E beenteredduringthisallohnce,andthe valve opened nly as necessary for effecting regairs. Each purge valv in the penetration flow path may be alternately opened, ovided one remains sealed closed, if nec ssary, to complet repairs on the penetration.

                         -                                                                  \      -

Th SR is modified by a Note stating that primary ntainment purge valves are only required to be sealed closed in MODES 1, 2, and 3. If a LOCA inside primary . (continued)

        ?M/* FS                                 B 3.6-24                         .": ; I, 04/07/;';

PCIVs B 3.6.1.3 BASES SURVEILLANCE 6 .1.3.1 (continueo) REQUIREMENTS contti ccurs in these MODES, the purge Jvvefinay not I be capable o loQgbeforethepressurepuTseaffects ' n systems downstream of W urge ves'or the release of (g radioactive material will e limits prior to the closing of the purge valves. ther t hen the purge valves are required capable of closing e. during handling of irra fuel), pressurization concerns ar present

          ,                                                    e nurae valu--         ~ === allowed in he anan

((,, a nt h 101d, MiO

w_, k,r ,,4,,,,,w p ,,,,,,,g ,,,9 ,gj l

      ').4 Inc.h ) dd conMriWMY             ,                                                     g         jq         g mg ,.y L pus 5vec can4<of VAlHS                         SR      3.6.1.3.                             '

da, 67 p,rge s yf te e 1 ( t gcQ V5a/a hoe r . - i This SR ensures that the pmY5=~-----ta===L;" ;:/ valves 3 G -3 are closed as require r, if open, open for an allowable %

                                %                 reason. If a purge a ve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve                                             'q           i
                      ,                           is not otherwise known to have excessive leakage when                                                              ]

(j,e, no isola closed, it is not considered to have leakage outside of 4

                     ,gelafi                      limits. . % So h m: di't.: ;,,                                  .p. um. b ,,              yc. d ai wa l

g E W ofLto334.1/ sht' ; tist$rimary containment purge

valves are only f'g5j.[l required to be closed in MODES 1, 2. and 34 If a LOCA on (4f ttirk N opg ads frynolake insiae primary containment occurs in Inese MODES, the purge l

                                              , valves may not be capable of closing before the pressure of WsegaW3              A pulse affects sys ens downst aam gtg purge a ves, erd he A                                      ,                  g Y"""'-                            _,__4.-

(nisid1 ef Mo0E5l,2,od) - ' '

2. I.... f. ' '.*. ._ ". ' !",~ .K_.."E.

_ . .,.a..

                                                                                                   ._At
                                                                                                        . o th'.b. t i"',b. "".,y"-"(e". g"~ , ^~d u ri ng handling of irradiated fuel), pressurization concerns are                                                   9 cmkieM gle                                not present and the purge

valves are allowed to be open.) ';

pNss e gg gm The SR is modified by a Note "' t-- ^} stating that the SR is not required to be met when the purge 4 valves are open for j t the stated reasons. The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or e Surne< 11ances that require the valves to be open. The <- d lN gM ,10 mCb

                                         ,- ~!Z-';O. purge valvesere capable of closing in the env'ronment following a LOCA. Therefore, these valves are Mg 24 mch) ^^j (t                  I allowed to be open for limited periods of time. The 31 day Frequency is consistent with other PCIV requirements 4
        ' g conbin                    g(      _ discussed in SR 3.6.1.3.Y.                                                                           _

passe 9 4# g ( g 'iocO (continued) r./' !?! B 3.6-25 h 1, 04/0'/% O f ffyb 1

PCIVs B 3.6.1.3 BASES SURVEILLANCE sR 3.6.1.3.h REQUIREMENTS This SR verifies that each primary containment isolation gs (continued) manual valve and blind flange that is located outside l dyd not ladCed, orimary containment /and is required to be closed during 588('j' g accident conditions is closed. The SR helps.to ensure that ,y$ post accident leakage of radioactive fluids or gases outside 04f4M'IL the primary containment boundary is within design limits. Seceed This SR does not require any testing or valve manipulation. Rather, it involves verification that those PCIVs outside (, / primary containment, and capable of being mispositioned, are in the correct position. Since verification of valve position for PCIVs outside primary containment is relatively easy, the 31 day Frequency was chosen to provide added assurance that the PCIVs are in the correct positions. Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered a cceptabl e s i nce _ ._ , . . ___ . ., . - - _ _ - - _ - - _ _ . ... . ... .... access to these areas is typically restricted during - 94 MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these PCIVs, once they have C. I . been verified to be in the proper position, is low. A r second Note has been included to clarify that PCIVs that are m g$ggy f open under administrative controls are not required to meet T the SR during the time that the PCIVs are open. 3 1 B3.u V l+o ,4 L SR 3.6.1.3 A I.$0lq ' This SR verifies that each primary containeen manual Op,y Il 49-t % valve and blind flange that is located inside OC'.. primary containmentgtnd is required to be closed during a nd nof loc M accioent conaitions is closed. The SR helps to ensure that

    @Wg                          post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.                                     m MM                          For PCIVs inside primary containment, the Frequency defined
     $MN                         as ' prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed
                                                                                                                                ~

within the previous 92 days' is appropriate since these Q PCIVs are operated under administrative controls and the probabilityoftheirmisalignmentislow.3 ci GNseer N l L 8 $No.lo3 lll ; (continued) r_r./t m B 3.6-26 hv 1, 04/07/M e

1 I PCIVs B 3.6.1.3 j Insert B 3.6.1.3 14 (2 places) 1 This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position upon locking, sealing, or securing. s i 1

                      #  6 ss FERMI UNIT - 2            Page B 3.6 26 (INSERT)          Revision Sa, 05/10/99l

1 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3 (continued) REQUIREMENTS I Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since the primary containment is inerted and access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the prob:bility of misalignment of these PCIVs, once they have been verified to be in their proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open. SR 3.6.1.3 The traversing incore probe (TIP) shear isolation valves are l actuated by explosive charges. Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required. Other administrative controls, such as those that limit the shelf life of the explosive charges, must be followed. The 31 day Frequency is based on operating experience that has demonstrated the reliability of the explosive charge continuity. SR 3.6.1.3 g Verifying the isolation time of each power operate automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7. The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are>F$n accordance with the requirements of the Inservice Testing Program,;r % 4 Pg ^ m (Gina, win.ek',20 Inehnd) [1R 3.6.1.3 Q ihk b For primary containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements _,,of10CFR50,AppendixJ(Ref.3),isrequiredtoensure y Of h'e n O (continued)

  -8WR/4 5i5                              8 3.6-27                   hv 1, 04/07/%

3 A I e

PCIVs l B 3.6.1.3 BASES SURVEILLANCE ""' SR 3.6.1.3 (continued) __ REQUIREMENTS

       ~71d3 .lcsl wilj X                  OPERABILITY.j0peratingexperiencehasdemonstratedthat                        _
                                }          Ints type of seal has the potential to degrade in a shorter t M g d CO b j e.                   time period than do other seal types. Based on this is 4 0 05 L.a u)hth                  observation and the importance of maintaining this pg                      penetration leak tight (due to the direct path between
                  ,                        $        s a        a i    d Additionally, this SR aust be performed once within 92 days

l after opening the valve. The g2 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

              ,q                           Th 5" i: rfift:d b" : ht: :t: ting tht[he primary containmentpurgevalvesareonlyrequiredtomeetleakage rate testina reautrements in NODES 1. 2. and 3.#If a LOCA

( j.e,3 no uolafim F 1nside primary containment occurs in these MODES, purge valve leaka e must be minimized to ensure offsite M*d N. #" radiologica release is within At other timesluhust I fuggs of Lcof3.t..I . ' . - _ - . . . - - . . ,,,,4 ..,e . . lim g i --g t s . ; g ;;;gg on f niyef 4e k < (e.g., during handling of irradiated fuel), pressurization

                                    }      concerns are not present and the purge valves are not ope # M N f "'P'                   required to meet any specific leakage criteria.
                                      -                                                                            ~~

GyS4un ISDI4ti#t odsidt aMMS @ SR 3.6.1.3 b1pA 3) Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in T ( /ggr the DBA analyses. This ensures that the calculated radiological consequences of these events remain within g 3,(,,(,3 - 9 10CFR100 limits./TheFrequencyofthisSRis$n

accordance with the requirements of the Inservice Testing Prograsg r " x th;). (continued)

                  """/' "S                                      B 3.6-28                         " .1, "4/07/Z e                                 .

PCIVs B 3.6.1.3 BASES SURVEILLANCE sR 3.6.1.3 REQUIREMENTS (continued) Automatic PCIVs close on a primary containment isolatien signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position-on a primary containment isolation signal. The LOGIC SYSTEM

             /d           FUNC"IONAL TEST in SR 3.3.6Moverlaps this SR to provide            A comp'ete test'ng of the safety function. The$8fmonth
                    ~

O[E- Frequency was developed considering it is prudent that this Surveillance be performed only during a unit outage since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components. Operating experience has shown that these components usually pass this Surveillance when performed at the $ 87 month Frequency. Therefore, the Frequency was conc' uded to be acceptable from a reliability standpoint. SR 3. 6.1.3 M This SR requires a demonstration that each reactor gg instrumentation line excess flow check valve (EF s OPERABLE by verifying that the valve %&m . ow *e-F3 ph on a simulated instrument line break %. This SR provides assurance that the instrumentation iine EFCVs will perfors so that predicted radiological consequences will not De exceeded during the postulat1d instrument line break event evaluated in Reference.4Cir/The118& month Frequency is i L ased on thl..... .. ,..... this Survei' lance under the r* T,@[g[,, conditions that apply during a plant outage and the i N I potential for an unplanned transient if the Surveillance J. f.N fer-{orp# Ob were performed with the reactor at power. Operating experience has shown that these components usually pass this %e Surveillance when performed at the 118) month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. t SR 3.6.1.,3 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with thf design. The explosive squib is removed and tested to pr: ede assurance that the valves will actuate when

(continued) l rj' ': B 3.6-2g L 1, 04/07/g; 1

                   , . .                                                                         l 1

e

l PCIVs B 3.L.1.3 BASES

                                                      /8 1

SURVEILLANCE SR 3.6.1.3 b (continued) REQUIREMENTS required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired gn W b J llr m in or from another batch that has been certified by having one of the batch successfully fired.3 The Frequency of 18 months inScWiC8 b' #d b on a STAGGERED TEST BASIS is considered adequate given the t ira 4(m # If5 administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1. g y l:fc w Of 'D0 II (f SR 3.6.1.3. H s L. g fN This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than th specified leakage rate. This provides assurance that th assumptions in the radiological evaluations of Reference are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage through the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed __N to be the actual pathway leakage throuch the isolation g [c;g(o hwd ) device. Ifth'both isolation valves in the penetration are :

                                                      ***"'I     1**k'"     t' 15-"==+4'wiaa th' l'5$'" ==-ilk'8'    t' l W $6 Ro k Tes

of the Cld'two valves. 7 -

fagrada p . . ..., . . . ..,. . . . . .t t: 5: ":-d #a" thii Sk fi a -J W 7 ) I'?? E'Ih 7 ' " "' ' "" ' ' " ' ' ' " '" ' ' h / i'J i^ 0 :"'.*.^.'.".".'rf I

              -                      6 ....ii;-v           r           rr "i+' Saa-adi 1) dhe Frequency i s                    -

g{ required

                                                     ^ C
                                        .n;t4... byf.;a .    +T; "", .."+;r-f'N

k. r ?.

                                                                                   -~rr

fi-d ky : ;r=" 4

                                                , ,,s k...ra
                                                             .yyn ..,, ...... e.; tuti ; :;            .r.;.,,y.
                                                                                             ,;;;7,;;; ,; ;;
                                                                                                                  .,; ; -p.

3- 'r;: l~8 3 6 l'3,3p 0 tut- This SR siaply iapos's additional Net: I t: : i r Ta YM: :n r.icir

                                % acceptance
                                      .+=t ! th:t criteria.

th;;. ,el .e ere er.ly r;;;ir:d t: =:t thi:- p'3 w =e. u -it e m s 3. :. =: :. :7. 22 == - Ier.ditier.;, ii,. R.. d v. ;..;.n. ^7. - ,. on ,, e.e., ; .d and-speci.'; pr imary-trt:trc- :02:;: "m&t,s-are hut" r;;;ir.J. 6cmde/ - ass leakage is 9%'R .: r: c "y cr--t:f red part of L,. j".. . ;. " ,,v a ; cmhtitt j _ p,q ctSSu(tS -lhtd Ady' ;itamtlatf Lorsin M& kypess lea ha AMy uduaU

qainst Ha. cc;y %ie is fueafsprofr orera.d c<m 4aJ n raew4 l ea kup (continued) a

               -' ./' n:                                     8 3.6-30                             ..=  1, et/07/95

.. =i fG\f 0.

PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3 . 6.1. 3 , Mbb foo REQUIREMENTS (continued) The analyses in References and are based on leakage that is less than the specified leakage rate. Leakage through aII four Ch ". Sly must be s scfh when tested at 2 P fna /r (feam >4 20.0) psig). The "' .eeS;r nt: =-t 5: -- i'i- ' te 5:_ _ f ,.g 4-accordance with-the-le;L;;e ts.; ry i. . ;.t: Of h l 10 CrA 3G, "yy.., Jim J 'R.T. 3), .. __: fifid by =aamed exempt 4 ens. Net. 1 i. _dd;d t: t'4e (# which it tr th:t- g i g p,l t'- e =hn in uly n;.ind ternt tMs-leakage-.14mH4p f.q - MODEM'i-2; and97-In-the other coMitir- . the- ";;;terj 4g f aal a_n_t Evetam ie nnt nemeege4 ;j ;7,j ; rit4.-7-in 7j c..t..-.a.i.d.y. ?'-ft: :n =t n-"f =d[This ensures (s that MSIV leakage is properly accounted for ' j t.. ...ing - o l She ern11 p-f=ry Gr.teir ;;.t 1 ek;;: rete. The Frequency f.2, is required by PJ Cr" 50. ^;;:sf!: J, ;; ;;;,dif t:F5y

= =d u. ti.r.., ;;..., = :.0.: '.;hi;h :ll e, . r. .w...c,-

p15EM3,l,.l q 6--teri:=) dn. ,,vi

                                                                                  .;;Ur'~ 1%e l'erem ar y Contaien,an t r
                          /NSE&t'                           3.6.1.3.M
                                                                                                         #'                   'N          P*

f.6 1 6 3.c t.3 -15 SR - me,g by. Surveillance of hydrostatically tested lines provides t assurancefthat the calculation assumptions of Reference 2 wa ry are met.)P The combined leakage rates must be demonstrated in f M2 E 'e-

, accordance with the leakage rate test Frequency W *<

l [oni4'"**^4 C- CT" %, .",4;i. dix 013..". ^,), => mooiiiso py app, vv.tF-

4.co / cog e [of C e :g +4aae: thy grrn , imkich .sig, ". n.;..cy-

             ,                   pf.g c.            -extensionsbdoes-not-app +yr--

34ThisSRhasbeenmodifiedbyaNotethatstatesthatthese

                                   ..                valves are only required to meet the combined leakage rate f,'7

in MODES 1, 2, and 3, since this is when the Reactor Coolant System is pressurized and primary containment is required.

In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1, 2, and 3. However, specific leakage limits are not applicable in these other MODES or conditions.t

                                                        ..  . _- . a . w-
                                                                ~..

Reviewer's Note: SR is on1 for those plants with purge valves wi . sais allowed to be open , during[ MOD

                                                                                                      ~
                                                                            ,  , or 4     and hav reanently instal'1 ed on the valves.      n devices that                      I tr                                                                         ~

l ,K' L* (continued) l l i

                              """ ^^^

l B 3.6-31 nr , 0 l07j;; l

   ,                                         s q'.

[ eda

PCIVs B 3.6.1.3 Insert B 3.6.1.3 6

                -  to assure safety analysis assumptions, regarding the MSIV-LCS ability to provide a positive pressure seal between MSIVs, remain valid. This leakage test is performed in lieu of 10 CFR 50.

Appendix J. Type C test requirements, based on an exemption to 10 CFR 50, Appendix J. As such, this leakage is not combined with the Type B and C leakage rate totals. Insert B 3.6.1.3-15 l The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the number of valves per penetration, not to exceed 3 gpm, when tested at 1.1 P. (2 62.2 psig). Additionally, a combined leakage rate limit of s 5 gpm when tested at 1.1 P. (2 62.2 psig) is applied for all hydrostatically tested PCIVs that penetrate containment. l l S f A- N 4 e FERMI UNIT - ?. Page B 3.6-31 (INSERT) Revision Sa, 05/10/99l

                                    ~                  '

/

n i JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.3 - PCIVs l NON BRACKETED PLANT SPECIFIC CHANGES I l P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license l requirements and commitments. 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. Additional rewording, reformatting, and revised numbering i is made to incorporate these changes consistent with Writer's Guide conventions. Some of these changes are specifically discussed below: i

a. Secondary containment bypass leakage is not explicitly required I to be surveilled or limited in CTS. However, the analyses assume )

a leakage limit on these bypass paths. As discussed in DOC M.2 1 ITS Surveillance (SR 3.6.1.3.11) and Actions (Action D) are included to address these requirements. Since some of these p l secondary containment bypass valves are not covered by the i l Primary Containment Leakage Rate Testing Program, the Frequency for ITS SR 3.6.1.3.11 must also include and Inservice Testing g Program." (Refer to UFSAR 6.2.1.2.2.3 for complete discussion.)

b. In the case of purge valves, the Fermi-2 design is such that purge valves are capable of closing in a post accident environment and therefore are not required to be sealed closed or restricted to partial opening. The specific leakage acceptance criteria that was in CTS is added to the Bases for ITS SR 3.6.1.3.6.

h P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. Some of these changes are specifically discussed below:

a. In the case of purge valves, the Fermi-2 design is such that purge valves are capable of closing in a post-accident environment and therefore are not required to be sealed closed or restricted to partial opening.

b. Instances of Bases detail (e.g., SGT excess flow dampers.'MSIVs role in most limiting event, and 60 second isolation time assumption) that is not directly applicable to Fermi-2 analysis or design is deleted without replacing with Fermi specific detail. Removal of this detail is deemed not to reduce the

  ,                 intent of effectiveness df the Bases.

SS FERMI - UNIT 2 1 REVISION Sa, 05/10/99l s

L l JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.3 - PCIVs 1

c. MSIV leakage Bases clarified to reflect the Fermi 2 specific Appendix J exemptions, and MSIV LCS supporting design.

d. The Bases Background includes a clarifying discussion regarding oo test vent and drain connections. This clarification was included 7 in the Fermi 2 CTS Bases for section 3/4 6.1.1 and is transferred into the ITS.

P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification change JFD for additional detail. P.4 Editorial change made for clarity and consistency between Bases and the Specification. Additionally, the Bases discussion of normally closed PCIVs is eliminated. This editorial preference is based on incomplete (and therefore potentially misleading) discussion of these valves, as well as an inconsistent level of detail when compared to other isolation devices. Elimination of this detail does not modify the requirements, or the interpretation of those requirements. The LC0 Bases are intended to provide a few details regarding OPERABILITY. These details are not all-encompassing, but only serve to outline salient features (in this case of PCIV OPERABILITY). The paragraph discussing abnormally closed PCIVs attempts to define OPERABILITY of these valves, but makes statements that are not true in all cases. There are lines with normally closed PCIVs where the PCIV is an automatic isolation valve (e.g., ECCS test return lines). These valves are NOT required to be deactivated and secured in their closed positioned e-to be OPERABLE. Also, blind flanges are a separate isolation ? boundary, and do not support OPERABILITY of other normally closed ' PCIVs. Furthermore, OPERABILITY of normally closed PCIVs is not contingent on the status of any associated closed system (that closed system would reflect on containment OPERABILITY: not on OPERABILITY of an isolation valve in the line). Even with elimination of the erroneous discussions, this paragraph provides no necessary detail regarding OPERABILITY, and can be deleted without loss of information useful to the Operator in determining OPERABILITY. It is not deemed necessary to expound on any OPERABILITY criteria for normally closed PCIVs.

                                                                        .7 /

FERMI UNIT 2 2 REVISION Sa, 05/10/99l

~

i I JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 I ITS: SECTION 3.6.1.3 - PCIVs 4 l 1 i P.5 Potential inconsistencies exist in the Actions for inoperable ; MSIVs. EFCVs. and hydrostatically tested valves, depending on whether the valve is inoperable due to excessive leakage or otherwise inoperable. These changes are consistent with a ! i proposed revision to TSTF 207 (currently under NRC review). l The NUREG-1433 Action A would apply to all failures (including b excessive leakage rates) for MSIVs. EFCVs. and hydrostatically tested valves. This would allow isolating the penetration as opposed to the more appropriate action of restoring the leakage rate to within limit (as is provided in NUREG Action D for secondary containment bypass leakage). In order to eliminate this l inconsistency. ITS Action D is revised to accommodate leakage rate l failures for MSIVs. EFCVs, and hydrostatically tested valves as well as for secondary containment bypass leakage failure. Along I with this change in the Condition, the change incorporates the i(n applicable Completion Times: MSIVs (8 hours found in NUREG 1433 Action A): EFCVs (72 hours found in TSTF 323 approved change to 4 NUREG 1433 Action C): and hydrostatically tested lines without a closed system (4 hours - found in NUREG 1433 Action A). ( Note: hydrostatically tested lines on a closed system is provided f with a Completion Time of 72 hours in TSTF-30 approved change to NUREG 1433 Action C. However, Fermi 2 design does not include any hydrostatically tested lines with a closed system. As such, this portion of the Completion Time (as proposed in TSTF 207 revision) l 1s not adopted in the ITS. As a result, the 4 hour Completion Time for all other hydrostatically tested lines (which is all that are hydrostatically tested at Fermi) does not need the modifier "without a closed system." Additionally. NUREG 1433 Action E (action for purge valve leakage p not within limit) is editorially incorporated into ITS Action D. l since the Fermi design does not support the " bracketed" allowance of NUREG Action E. This portion is an editorial presentation preference to combine all leakage failures into one Condition. l t 2 1 a - . sS FERMI UNIT 2 3 REVISION Sa. 05/10/99l a

JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.3 PCIVs P.6 NUREG 1433 Action C is a separate Action for inoperable PCIVs on penetrations that have only one PCIV. TSTF 323 approves a 72 hour Completion Time for the EFCVs. TSTF-30 approves a 72 hour s Completion Time for single valve penetrations on a closed system. M Each of these approved changes has editorial presentation Y corrections that are the subject of a proposed revision to 9 TSTF 30. currently under NRC review. The Fermi 2 ITS incorporates Q the approved times and follows the proposed format for resolving the presentation problems. 4 P.7 The ITS details of leakage rate tests are relocated to the Primary Containment Leak Rate Testing Program, which is being added to Section 5. Administrative Controls. This presentation is generally consistent with CTS presentation (which already includes an Administrative Controls Program for primary containment leak rate testing). These changes are in general accordance with (unapproved) Generic Change TSTF 52. application of 10 CFR 50. Appendix J. Option B. P.8 ITS incorporates more restrictive provisions requiring isolation capability during shutdown Modes. NUREG 1433 has a variety of options for potential shutdown Mode requirements. For Fermi 2 the applicable provisions are retained, i.e., those related to RHR SDC isolation. which are incorporated into the Instrumentation Chapter of ITS. Other bracketed provisions on NUREG 1433 (Actions G and H) are not applicable to the Fermi requirements and are therefore not included in ITS. P.9 Note 1 to ITS SR 3.6.1.3.1 (NUREG SR 3.6.1.3.2), the Note to ITS SR 3.6.1.3.6 (NUREG SR 3.6.1.3.7), and Note 1 to ITS SR 3.6.1.3.11 (NUREG SR 3.6.1.3.12) explicitly limits the application of the associated surveillance to Modes 1. 2. and 3. Also ITS SR 3.6.1.3.12 (NUREG 1433 SR 3.6.1.3.13) Bases references a similar Note (that does not exist in the SR - but is proposed to - be added by an EC proposal "TSB 13"). These explicit exceptions j are not retained since the overall Applicability of this ] l Specification to the valves associated with these SRs is already N l limited to Modes 1. 2. and 3. The exception of the Note would I apply only to plants incorporating PCIV requirements for these valves in shutdown Modes. Therefore, this change reflects a f' Fermi specific presentation preference consistent with Writer's N ' Guide ~ conventions. 21 FERMI - UNIT 2 4 REVISION Sa. 05/10/99l . i

i i JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.6.1.3 PCIVs P.10 The reference to the NRC 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).

P.11 ITS SR 3.6.1.3.9 applies to testing each EFCV " actuates to restrict flow." The procedures for conducting this test are typically performed with the RCS at elevated pressures (which are required to create the flow necessary to actuate the EFCV on a simulated line break). As such. testing can be (and sometimes is) I performed in non outage conditions. Therefore, a Fermi specific d change.is made to the Bases to correct the discussion stating g there is a "need to perform this Surveillance during a plant 5 outage.' N 1 Additionally. ITS SR 3.6.1.3.10 includes an additional statement regarding TIP shear valve replacement. CTS 4.6.3.5.b has this requirement that is being relocated to the ITS Bases (refer to DOC "LA.4"). This presentation preference is necessitated by is a Fermi specific CTS requirement. , GENERIC CHANGES e C.1 TSTF 45: NRC approved change to NUREG-1433. s' l C.2 TSTF 46: NRC approved change to NUREG 1433. C.3 .TSTF 269: NRC approved change to NUREG-1433. s @ ! 6 I e' FERMI - UNIT 2 5 REVISION Sa. 05/10/99l A

i

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs

       . TECHNICAL CHANGES     LESS RESTRICTIVE (Soecification 3.6.1.3 "L.3" Labeled Comments / Discussions) i Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.

The bases for the determination that the proposed change does not involve a l' significant hazards consideration is an evaluation of these changes against l each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below. l

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

This change would allow additional time to isolate an excess flow check valve penetration and penetrations with a single PCIV. PCIV isolation lc is not considered an initiator of any previously analyzed accident. l Therefore, this change does not significantly increase the probability - l of such accidents. The proposed change increases the allowed out of i service time for single valve penetrations with less than the required isolation capability. The excess flow check valves are designed with a l$7 flow orifices which limits the rate of flow even with the failure of the L EFCV. This design provides a passive backup to the EFCV and ensures that even with an inoperable EFCV, any leakage from a primary k containment instrument penetration will be limited. Other single valve l penetrations either have a marginal increased restoration time (4 hours) or are part of a closed system, which serves as a second containment V

boundary, thus, justifying the 72 hour allowance. Therefore, this change does not significantly increase the consequences of any l

previously analyzed accident.

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

The proposed change does not involve any physical changes to plant

             ' systems, structures, components (SSC), or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.'

l FERMI UNIT 2 5 REVISION Sa. 05/10/99l ) l t

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.3" Labeled Comments /Discussioul)

3. Does this change involve a significant reduction in a margin of safety?

This change impacts only the Required Action Completion Time for inoperable EFCVs and other penetrations with a single PCIV. The l_ methodology and limits of the accident analysis are not affected, nor is n the containment response. The excess flow check valves are designed f with a flow orifices which limits the rate of flow even with the failure y of the EFCV. This design provides a passive backup to the EFCV and , ensures that even with an inoperable EFCV. any leakage from a primary g containment instrument penetration will be limited. Other single valve g-penetrations either have a marginal increased restoration time (4 hours) or are part of a closed system, which serves as a seconJ containment boundary, thus, justifying the 72 hour allowance. The increased allowed out of service time for these PCIVs is offset by the potential benefit of avoiding an unplanned transient. Therefore, the change does not involve a significant reduction in the margin of safety.

p. *4 s.o FERMI UNIT 2 6 REVISION Sa. 05/10/99l

1 NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.5" Labeled Comments / Discussions) Not used. in

,t.

k a ,

                                                                                        .i FERMI - UNIT 2                             8                                REVISION Sa, 05/10/99l

l 1

N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES.- LESS RESTRICTIVE (Soecification 3.6.1.3 "L.6" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the deters.;ination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change allows for administrative verification of position I when the isolation device is in an area with limited access due to high radiation or is locked, sealed, or otherwise secured in the closed position. The method of verification of the status of the containment h@ isolation function is not considered an initiator for any previously j evaluated accident. Therefore, the probability of an accident 1 previously evaluated is not significantly increased. g i The proposed alternatives to verifying the isolated status of I containment penetrations are consistent with NUREG 1433. Based on the T strict administrative controls applied for entry into high radiation I areas, controls on locked, sealed, or secured valves, in addition to l9 other controls imposed on manipulation of plant equipment, the isolation device is not expected to be mispositioned as a result of this change. Therefore, this change will not introduce a significant increase in the consequences of a previously analyzed event.

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

The proposed change does not involve any physical changes to pla'nt systems, structures, components (SSC), or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

e FERMI - UNIT 2 9 REVISION Sa. 05/10/99l e

N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.6" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The proposed change allows for administrative verification of position when the isolation device is in an area with limited access due to high radiation or is locked, sealed, or secured in the closed position. This alternative to verification of the status of the containment isolation A l function is acceptable because: there is no detrimental impact on any J equipment design parameter: the plant will still be required to operate e with the required containment barrier; the strict administrative 4 controls applied for entry into high radiation areas: the strict O administrative controls on locked, sealed, or secured valves; and the d-other controls imposed on manipulation of plant equipment. As a result, the isolation device is not expected to be mispositioned as a result of this change. Additionally, the proposed change has the potential for significantly reduced personnel exposure. Therefore, the change does not involve a significant reduction in the margin of safety. l l l t FERMI UNIT 2 10 REVISION Sa, 05/10/99l

1 N0 SIGNIFICANT HAZARDS' EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES - LESS RESTRICTIVE

        - (Specification 3.6.1.3 "L.7" Labeled Comments / Discussions)
        - Detroit Edison has evaluated the ' proposed Technical Specification change         l identified as "Less Restrictive" in accordance with the criteria specified by        l 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.

The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change extends purge valve leak testing to every 184 days, with the added limitation of "once within 92 days after opening the valve." The frequency of testing is not considered an initiator for any previously evaluated accident. Therefore, the probability of an accident previously evaluated is not significantly increased. The proposed frequency verifying the leak-tightness of the purge valves is consistent with NUREG-1433. The leak rate limit remains unchanged; thus the consequences associated with this leak path remains unchanged. Therefore, extending the frequency to 184 days will not introduce a significant increase in the consequences of a previously analyzed event.

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

The proposed change does not involve any physical changes to plant systems, structures, components (SSC), or changes in normal plant operation. Therefore.' these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated-s '. FERMI UNIT 2 11 REVISION Sa, 05/10/99 't

I J I N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs TECHNICAL CHANGES - LESS RESTRICTIVE (SDecification 3.6.1.3 "L.7" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The proposed change extends purge valve leak testing to every 184 days, with the added limitation of "once within 92 days after opening the valve." Since the re closing of an opened purge valve that has resilient seals is a major factor in deterioration of the sealing , capability, extending the leak test from 92 days to 184 days for purge valves that have not been opened is deemed acceptable. Furthermore, plant specific experience with purge valves that have not been opened demonstrates the continued expected leak tightness of these valves when tested at the current 92 day frequency. Therefore, extending the frequency to 184 days does not involve a significant reduction in the margin of safety.

l l l l J 8

FERMI UNIT 2 12 REVISION Sa, 05/10/99 Q b

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.8" Labeled Comments / Discussions) i Detroit Edison has evaluated the proposed lichnical Specification change identified as "Less Restrictive" in aco dane with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against I each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

This change would allow additional time to isolate or restore an inoperable non automatic PCIV. These manual isolation valves are not y considered an initiator of any previously analyzed accident. Therefore, t4 i this change does not significantly increase the probability of such d. l accidents. The ' proposed change increases the allowed out of service time for non automatic PCIVs. Neither the requirement of operability k not the required restoration action is effected by this change. Any l consequences as a result of an accident while operating with an l inoperable PCIV is unaf? acted by this change. Therefore, this change l does not significantly increase the consequences of any previously analyzed accident.

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

The proposed change does not involve any physical changes to plant systems, structures, components (SSC), or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. 1

p. . #.'

Ja ' FERMI - UNIT 2 13 REVISION Sa, 05/10/99l y

a N0 SIGNIFICANT HAZARDS EVALUATION

ITS: SECTION 3.6.1.3 - PCIVs > TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.6.1.3 "L.8" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

This change impacts only the Required Action Completion Time for 5g inoperable non automatic PCIVs. The methodology and limits of the i accident analysis are not affected, nor is the containment response. The increased allowed out of service time for these valves is offset by the potential benefit of avoiding an unplanned transient. Therefore, the change does not involve a significant reduction in the margin of safety. I i l I i I i l l , 28 FERMI UNIT 2 14 REVISION Sa, 05/10/99l

e

I NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.9" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a 3 significant hazards consideration is an evaluation of these changes against ) each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the ) evaluation are presented below. i l

1. Does the change involve a significant increase in the probability or j consequences of an accident previously evaluated? I The change revises " checks flow" (which could be interpreted to require a zero flow acceptance criteria) to " restricts flow" (which is interpreted to limit leakage to some positive value). The specific leakage of any EFCV is not considered an initiator for any previously hg evaluated accident. Therefore. the probability of an accident previously evaluated is not significantly increased. Since the EFCV k' leakage acceptance criteria remains within values that support the

         " radiological assumptions." this relaxation does not significantly increase the consequences of any previously analyzed accident.

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

The proposed change does not involve any physical changes to plant systems. structures, components (SSC). or changes in normal plant operation. Therefore. these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. a , c. FERMI - UNIT 2 15 REVISION Sa, 05/10/99l c

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs l TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.9" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The change revises " checks flow" (which could be interpreted to require b a zero flow acceptance criteria) to " restricts flow" (which is interpreted to limit leakage to some positive value). The leakage limit s for each EFCV remains within values that support the " radiological assumptions." Therefore, the change does not involve a significant reduction in the margin of safety. l l l I l

   .                    =,

j r. FERMI - UNIT 2 16 REVISION Sa, 05/10/99l 1 l t-,

N0 SIGNIFICANT HAZARDS' EVALUATION ITS: SECTION 3.6.1.3 - PCIVs TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.6.1.3 "L.10" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR E0.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change adds an alternative to the action required for an inoperable PCIV to include a check valve with flow secured. The method of isolating a penetration is not considered an initiator for any Q previously evaluated accident. Therefore, the probability of an accident previously evaluated is not significantly increased. k The proposed additional method for isolating a penetration is consistent with NUREG 1433. The basic requirement to effect isolation of the penetration and maintain the primary containment boundary remains unchanged; therefore, this change will not introduce a significant i increase in the consequences of a previously analyzed event.

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

The proposed change does not involve any physical changes to plant systems, structures, components (SSC). or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated, 1 1 l

n. l FERMI - UNIT 2 17 REVISION Sa. 05/10/99l

. l

o ( NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs t TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.10" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The proposed change adds an alternative to the action required for an inoperable PCIV to include a check valve with flow secured. With ll forward flow in the line secured, a check valve is essentially kk equivalent to a closed manual valve. Since the result of the action continues to be an acceptably isolated penetration for continued operation and is consistent with the intent of the CTS action, the change does not involve a significant reduction in the margin of safety. l l 4 1 i

 .n                       .

FERMI UNIT 2 18 REVISION Sa, 05/10/99j I , [-

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.11" Labeled Comments / Discussions) ; l I Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or i consequences of an accident previously evaluated?

4 The proposed change eliminates the requirement for locking (or deactivating) of manual valves used to isolate penetrations, and if the valve used to isolate a penetration is " locked, sealed, or otherwise secured," periodic verification of the position of the valve is d excepted. With a penetration closed using a manual valve a passive 3 barrier is established, i.e., one not subject to a single active q failure. As such, even without locking the valve, the assumptions of M the safety analysis can be met. Furthermore, if a closed valve is locked, sealed, or otherwise secured inadvertent mispositioning becomes an even more remote possibility. Since neither the locked status nor the frequency of verification is not considered an initiator for any previously evaluated accident, the probability of an accident previously evaluated is not significantly increased. Since no operability or performance requirements are affected, the change will not introduce a significant increase in the consequences of a previously analyzed event.

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

The proposed change does not involve any physical changes to plant I systems, structures, components (SSC), or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. *

~'

FERMI - UNIT 2 19 REVISION Sa, 05/10/99l ] s

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.11" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The proposed change eliminates the requirement for locking (or deactivating) of manual valves used to isolate penetrations, and if the 3 valve used to isolate a penetration is " locked, sealed, or otherwise ~_ secured," periodic verification of the position of the valve is J. excepted. With a penetration closed using a manual valve a passive fj{ barrier is established, i.e., one not subject to a single active failure. As such, even without locking the valve. the assumptions of I the safety analysis can be met. Furthermore, if a closed valve is locked, sealed, or otherwise secured inadvertent mispositioning becomes an even more remote possibility. Since all operability requirements remain unchanged, the change does not involve a significant reduction in the margin of safety. l l l e , FERMI - UNIT 2 20 REVISION Sa, 05/10/99l

N0 SIGNIFICANT HAZARDS EVALUATION l ITS: SECTION 3.6.1.3 PCIVs 1 1 LESS RESTRICTIVE l

    -TECHNICAL CHANGES (Soecification 3.6.1.3 "L.12" Labeled Comments / Discussions)

Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against l each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below. i

1. Does the change involve a significant increase in the probability or !

consequences of an accident previously evaluated? The proposed change removes details regarding requisite plant conditions j and scheduling for performance of PCIV isolation testing. These details j do not impact the requirement to maintain the valves Operable, and the ITS SR continues to ensure that all automatic PCIVs function properly. O The performance of isolation valve testing is not considered an 7 J l initiator for any previously evaluated accident. Therefore, the [d-probability of an accident previously evaluated is not significantly % increased. Since the details regarding requisite plant conditions and scheduling do ' not impact the requirement to maintain the valves Operable, and the ITS SR continues:to ensure that all automatic PCIVs function properly, this i change will not introduce a significant increase in the consequences of a previously analyzed event. l 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? l The proposed change does not involve any physical changes to plant systems, structures, components (SSC), or changes in normal plant operation. Therefore, these changes will not create the possibi,lity of a new or different kind of accident from any accident previously evaluated. La , si

   . FERMI - UNIT 2                         21                   REVISION Sa. 05/10/99l

I i NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.3 "L.12" Labeled Comments / Discussions)

3. Does this change involve a significant reduction in a margin of safety?

The proposed change removes details regarding requisite plant conditions [} and scheduling for performance of PCIV isolation testing. Since the 2, details regarding requisite plant conditions and scheduling do not impact the requirement to maintain the valves Operable, and the ITS SR f(( ! continues to ensure that all automatic PCIVs function properly, this change does not involve a significant reduction in the margin of safety. ! 1 I l l l l l l l a I SS FERMI UNIT 2 22 REVISION Sa. 05/10/99l

                                                                                         ~~~J

Drywell Air Temperature i B 3.6.1.5 BASES 1 SURVEILLANCE SR 3.6.1.5.1 l 1 REQUIREMENTS l l Verifying that the drywell average air temperature is within ' l the LC0 limit ensures that operation remains within the temperature limits for the primary containment. Drywell air temperature is monitored in all zones and at various l elevations. Due to the shape of the drywell, a volumetric ! ! average is used to determine an accurate representation of I the actual average temperature. This is accomplished by I averaging at least one reading at each of the following elevations: 1 a. 590 ft. O inches (azimuth 90*, 135*, 270*. or 316*) - I N b. 597 ft. O inches (azimuth 35*, 75* 93*, 135*, 175*, l 200*, 246*, 272*, 306*, or 345*) l

c. 621 ft, 8 inches (azimuth 0*, 90*. 180*. 270*)

d 648 ft, 6 inches (azimuth 45*, 135*, 225*, 315*) ) i

e. 662 ft, O inches (azimuth 0*, 90*, 180*, 285*) '

f. 685 ft, 6 inches (azimuth O' or 180')

l The 24 hour Frequency of the SR was developed based on operating experience related to drywell average air i temperature variations and temperature instrument drift I during the applicable MODES and the low probability of a DBA occurring between surveillances. Furthermore, the 24 hour i Frequency is considered adequate in view of other ' l indications available in the control room, including alarms, l to alert the operator to an abnormal drywell air temperature condition. I l REFERENCES 1. UFSAR, Section 6.2.

2. UFSAR, Table 6.2-1.

 *                           ~'

l FERMI UNIT 2 B 3.6.1.5 3 Revision Sa. 05/10/99 L<

I DISCUSSION OF CHANGES j ITS: SECTION 3.6.1.5 DRYWELL AIR TEMPERATURE l 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 (BWR) Standard Technical Specifications ' NUREG 1433. Rev. 1. TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANrER 1 M S RESTRICTIVE

      " Generic" I

LA.1 CTS 4.6.1.7 requires the drywell average air temperature to be determined and details how the SR is to be performed. ITS (RexS\ ra SR 3.6.1.5.1 requires that the drywell average air temperature be determined, but does not specify how the SR is to be performed. This is acceptable because these details do not impact the ITS requirement to determine the drywell average air temperature. Furthermore, the methods of performing a surveillance are not directly required to support the Operability of the ITS components. The " volumetric average" computational method and specific temperature monitoring locations are relocated to the ITS Bases, where changes are controlled by the Bases Control program. 4

&G

( A M -1 TECHNICAL CHANGES - LESS RESTRICTIyf

      " Specific" None l

RELOCATED SPECIFICATIONS-None - t TECHNICAL SPECIFICATION BASES FERMI - UNIT 2 1 REVISION Sa, 05/10/99l

Drywell Air Temperature B 3.6.I.5

 ,.             BASES (continued)

APPLICABILITY In MODES I, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining drywell average air temperature within the limit is not required in MODE 4 or.5. ACTIONS A.J With drywell average air temperature not within the limit of p,g the LCO, drywell average air temperature must be restored within 8 hours. The Required Action is necessary to return operation to within the bounds of the primary containment i ;;;1y;i;. The 8 hour Completion Time is acceptable, Agersturd considering the ;;;;tti.;ty er t h ;; 1;;i: t: ::.ri;ti;;: in-fyjg this parameter, and provides sufficient time to correct minor problems. Por o ftc e of B.1 and B.2 If the drywell average air temperature cannot be restored to within limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.1.5.1 REQUIREMENTS Verifying that the drywell average air temperature is within the LC0 limit ensures that operation remains within the pne; W11mits.asumED for the primary containment.;;.ly.;;.- Drywell air temperature is monitored in all - and at f,2 h I e<- d ed various elevations { - fe e red te r ::: h ::1); Due to 8.'[ the shape of the drywell, a volumetric average is used to , detemine an accurate representation of the actual average temperatur ( NSYT r 1 8 lS' ' l (c.ontinued)

               ;nj, sis-                                B 3.6-36                     Rw 1, G4/e7/4
                             ** i O

21 k I J

Drywell Air Temperature B 3.6.1.5 Insert B 3.6.1.5 4 This is accomplished by averaging at least one reading at each of the following elevations:

a. 590 ft, O inches (azimuth 90", 135*, 270 , or 316*)

b. 597 ft, O inches (azimuth 35*, 75 , 93 , 135 , 175 , 200*,

246*, 272 , 306 , or 345 )

c. 621 ft, 8 inches (azimuth 0*, 90 , 180 , 270*)

d 648 ft, 6 inches (azimuth 45*, 135 , 225 , 315 ) e, 662 ft. O inches (azimuth 0 , 90 , 180*, 285*)

f. 685 ft, 6 inches (azimuth 0 or 180 )

l 1 1 , l

      *                   *s 1

FERMI UNIT 2 Page B 3.6-36 (INSERT) Revision Sa, 05/10/99l l .

Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES BACKGROUND (continued) The process gas circulating through the heater. the reaction chamber, and the cooler is manually regulated to 150 scfm. l The process gas is heated to 1300*F. The hydrogen and l oxygen gases are recombined into water vapor. which is then condensed in the water s) ray gas cooler by the associated residual heat removal suasystem and discharged with some of the effluent process gas to the suppression chamber. The majority of the cooled, effluent process gas is mixed with the incoming process gas to dilute the incoming gas prior to the mixture entering the heater section. The primary containment hydrogen recombiner provides glT APPLICABLE b SAFETY ANALYSES the capability of controlling the bulk hydrogen concentration in primary containment to less than the lower Q flammable concentration of 6.0 v/o following a DBA. This

     &y    l control would prevent a primary containment wide hydrogen burn, thus ensuring that pressure and temperature conditions assumed in the analysis are not exceeded. The limiting DBA relative to hydrogen generation is a LOCA.
   '                             Hydrogen may accumulate in primary containment following a LOCA as a result of:

a. A metal steam reactinn between the zirconium fuel rod cladding and the reactor coolant or

b. Hydrogen contained in the water in the Reactor Coolant System from radiolytic decomposition and the hydrogen water chemistry control program.

To evaluate the potential for hydrogen accumulation in primary containment following a LOCA, the hydrogen generation is calculated as a function of time following the initiation of the accident. Assum)tions recommended by Reference 3 are used to maximize t1e amount of hydrogen calculated. The calculation (Ref. 4) confirms that hydrogen and oxygen can be safely and effectively controlled to the limits of Table 1 of Reference 5. - l l l i s l , 1 FERMI - UNIT 2 B 3.6.3.1 - 2 Revision Sa: 05/10/99 r L

n Primary Containment Hydrogen Recombiners B 3.6.3.1 83.6 CONTAllelENT SYSTEMS B 3.6.3.1 Primary Containment Hydrogen Recombiners BASES BACKGROUND The primary containment hydrogen recombiner eliminates the. potential breach of primary containment due to a hydrogen - oxygen reaction and is part of combustible gas control required by 10 CFR 50.44, " Standards for Combustible Gas , n control Systems in Light-Water-Cooled Reactors" (Ref.1), and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2). The 7% primary containment hydrogen recombiner is required to 4 reduce the hydrogen concentration in the primary containment following a loss of coolant accident LOCA). containment hydrogen recombiner accomp(lishes this byThe primary recombining hydrogen and oxygen to forn water vapor. The vapor remains in the primary containment, thus eliminating any discharge to the environment. The primary containment hydrogen recombiner is manually initiated since flaunability limits would not be reached until several days after a ) Design Basis Accident (D8A). l ODN Y " The primary containment hydrogen recombiner functions t pn/ suff maintain the hydrogen gas concentration within the 4 cgAMh e.cW) containeen t or below the flammability limit of +ee volume i i _ N p e /o) following a postulated LOCA. It is fully redundant and consists of two 1005 capacity subsystems. l Each primary containment hydrogen recombiner consists of an enclosed blower assembly, heater section, reaction chamber, direct contact water spray gas cooler, water separator, and associated piping, valves, and instruments. The primary n containment hydrogen recombiner will be manually initiat d w from the main control room when the hydrogen gas concentration in the primary containment reaches o ?> gg) y o. ' When the primary containment is inerted (oxygen i v concentration < 4.0 v/o), the primary containment hydrogen recombiner will only function until the oxygen is used up (2.0 v/o hydrogen combines with 1.0 v/o oxygen). Two recombiners are provided to meet the requirement for redundancy and independence. Each recombiner is powered from a separate Engineered Safety Feature bus and is provided with separate power panel and rentrol panel. The process gas circulating ater, the reaction h ch

                                  $15 r, and the cooler is M=th!?; regulated to scfmAy-the-use af aa arifica alate incialled in the        f (continued) c r/; sis-                                  B 3.5-7s                     new-3r44f07/g5-U l

i INSERT THIS PAGE IN FRONT OF VOLUME 11 Volume 11: CTS MARKUP COMPILATION Remove Replace 3.6.1.3 CTS M/U (3/4 4-24) pg 9 of 9 3.6.1.3 CTS M/U (3/4 4-24) pg 9 of 9 Rev SA l 3.6.1.3 CTS M/U (3/4 6-1) pg 1 of 9 3.6.1.3 CTS M/U (3/4 6-1) pg 1 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-1a) pg 2 of 9 3.6.1.3 CTS M/U (3/4 6-1a) pg 2 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-2) pg 3 of 9 3.6.1.3 CTS M/U (3/4 6-2) pg 3 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-3) pg 5 of 9 3.6.1.3 CTS M/U (3/4 6-3) pg 5 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-14) pg 6 of 9 3.6.1.3 CTS M/U (3/4 6-14) pg 6 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-20) pg 7 of 9 3.6.1.3 CTS M/U (3/4 6-20) pg 7 of 9 Rev SA 3.6.1.3 CTS M/U (3/4 6-21) pg 8 of 9 3.6.1.3 CTS M/U (3/4 6-21) pg 8 of 9 Rev SA I I i l 1 Rev SA 05/10/99 l

SPE CI Fl(AlltN 3.(o l. 3 REACTOR COO! ANT SYSTEM 1/44.7 MAIN STEAM tfNE 150lATf04 VALVES 1TMfTINr, CONDITION Foo OPFDATinN L CO 3 D'I'3 3.4.7 Two main steam line isolation valves (MSIVs) per main steam line snall be OPERABLE with closing times greater inan or ecual to 3 seconos and less 3 s 3.v.t.1.7 13,, ,7 ,qu,j to 5 ,,,,nes, g , N APPtitABILITY: OPERATIONAL CONDITIONS 1. 2. and 3 ACTION: ( ACTioMS 4oTE 2 h %

                                              < McmorJr oJo%s 3 j Q                                                 \

With one for more)MSIVs inoperable: Add Ac.TioPJ 8 L. 2. g y 4 a. Maintain at least one MSlv OPERABLE ' eten affected rain stea53

1. [Qine that is open/Tno witnin 8 nobrs,"eitner:

[2 :. +m.. , ,. 2 n - - . : : ._ . ,, f 7a n : ..,. -9 p,q b) Isolate the affteted main steam line by use of a lG (Beactivateo MSIV)in the closeo cosition. [,y

2. Otherwise, be in at least HOT SHUT 00VH within the next 12 hours k bgg ~7 and in 00LD SHUTDOWN within the following 24 hours.

l to Y SURVEf tt ANCE RE0Vf REMENTS f

     <              4.4.7    Each of the above reautred MSivs snall be cemonstrated OPERABLE by                     k "g 7,4'i3' 7 verifying full closure between 3 and 5 seconos wnen tested pursuant to Specification 4.0.5.

FERMI - UNIT 2 3/4 4-24 Amenoment No. 83 O PAGE 0F 09 &v Si

I

l 02 CJ fl M770 tU 5. N.l. b CONTAinurNT sv5TEMS l.50 -scA 884Ci b(4 /75 3 la /./ ) 3/4 6 CONTAINMENT SYSTEMS ISO $44. $ pdc / (*p d [,[ ] 3/4.6.i PRIMAPY CONTAINMENT PDIFADY CONTA!NWENT INTEGPITV t tuf T1Nr, CONOTTTON FDD OPFDETin'J

                    $5.1.1 PRIMARY CONTAINMENT INTEGRITY snall be maintained,                                                              i l                      APPLICABIt1TY: OPERATIONAL CONDITIONS 1. 2* and 3.

S e4 Spea hC A ELLD3; l 34 U Without PRIMARY CONTAINMENT INTEGRITY. restore PRIMARY CONTAINMENT INTEGRITY within I hour or be in at least HOT SHUTDOWN within the next 12 hours ano in COLD SHUTDOWN within the following 24 hours. l i SUDyriu aNer Dr0VTPFMENTS l l l 4.6.1.1 PRIMARY CONTAINMENT INTEGRITY snall be oemonstrateo: a.0 After each closing of eacn eenetration suo.1ect to Type B testing, s u. execpt the primary containment air locks, if opened following Type ( A or B test, by leak rate testing the seals with gas at Pa , 56.5 gfg.g } psig, and verifying that wnen the measured leakage rate for these % Sc seals is added to the leakage rates cetermined pursuant to N 1 ( Surveillance Reoutrement 4.6.1.2.b for all other Type B 2 and Cpe 0 00 Acmous) LA @ g 3,q,g,3 4 b. s At least once per 31 days by verifying inat all Ortmary containment penetrations exceot those instoe tne centainment or in j k 6 cKe hian radiation areas (- :^^ _:.- - 1not g ,j ;, 4 e of Detng\ closed by UFt w Lt containment automatic [R u;nd 0<U.2 ;dg

                                    -* i8conditions
                                                                                                                             '   .f 8)'"g g g,tr    isolation        valves    anc reoumpe are closed             elotedvalves.

byQockedicloseo curineblank accieent flanges, or T L,( . . .

                                       , $1ctjfatiT TJTorKRiTvaTh,CTEUQdE2gThiB. exceot for                               ;&g SR % .Q,7.Nok.1 5 A 3.6.l G J tJo k 1 vaTves th'it are open unoer acministrative control as pergtted by 5

doecification3.6.3. yase1,2.y.gAc.t/).2.f

Valves, flanges, and eac]iv_Redau'tomatic'va[lve9whichare h@ SR3,4,(,3,3 1. located insice the containment.7d are siocmec.; sealed er- g otherwise secured in the closed position shall De verified .l T closed during each COLD SHUTDOWN except such verification need not be performed when the primary containment has not k""" been deinerted since the last verification or more often than once per 92 days. g) gp_ g 4, f, y,"t gofe f

                                                                                   @ S R 'f . (p o I* $

5 N efll'

                        'See Special Test Exception 3.10.1.

d l. . d (ADD StG)td TO Sh3le l.3.h 3.*Slcer of OWwi$t Mnit% t d "loeke/, C FERMI - UNIT 2 3/4 6-1 Amenoment No. /9, 102 .i k

  .                                         ~

PAGE I 0F 09 EvG

1 l ! i 1 t l I i SPEC IFick1108) f. L.I. 3 (Alto >u Speci[icahL 341.1) l l CONTAINWENT SYSTEMS - FDIMADY CONT AINuENT INTEGRfTV Ecovered Ar 7 sa / . 2 ,, , , , ,

SUDVrit t Aycp croglprufNTS trmtinueO I

                                                                                                      ~
                                                                                                        - h~I
                                                   } sea valves f1ances, ho /$Tst@jyllTQatf                                  g          ,

g( 3,(,,l .3.7 2. (. - vasves ;; ;; .; - -

                                                                                                                               '       l a.Ine containment within             hton radiat1on areas rND ""' " 'M ..* 9 shall be wnten        are ([,locatec
                                                                                                                        //

{ outsice l verifted closec(03- " T M ' '" cerrormeo within the crevious g AO 31 D '5cays." R T. G .13.'l. rJOTC 3 m ( , l l 'E . By vertfying eacn ortmary contatnment air lock is in ecmoliance

           $4                    with tne requirements of Specification 3.f.1.3.

l

d. By verifvino the suooression enameer is in compliance with tne

j 3hdl recutrements of Specification 3.6.2.1. l 4 I i I SK J.6,l.3.7 **The TIP Flange (Penetration X 35A) may be verified by review of high ke high d A/ofg l radiation area access controls if the T!P Room remains a {,,[/ 1 radiation area during COLD SHUTOOWN. , k 3/4 6-la Amenoment No. 49 FERMI UNIT 2 PAGE S OF 09

                                                                                                        .$p e r .fic n i t o.-   3.6 . * %

i Als v . . c Soccife e a t on

                                                                                                         .                       t
                   -e.; v s.u n; e e :u :                                                      . A (3 s     -e $pc ci e oiav ys           .
                                                                                                                                         ~t

1wn c om p.- a.- _ r ent.:

a, :: r.::::- t r i. gu - ., - c nym - 3.E...: ' Primary cc.tainmer.t leakage rates snall be limite t::

a. An overall intecrated leakage rate of less than ca ecual tc: La.

0. ! : t -: r-- - e --- ' t : :: tr - ent : es r.:r: : *. ~

55.5 est;. . 1 3cc. i I

                             ./           A comoined leakaoe rate of less than or ecual to 0.60 La for
               . "' I'.
                            -(            primary containment oenetrations and primary containment isolation                                 I
      */f"G.b. f*
                                  \

valves subject to Tyoe B and C tests wnen oressurized to P, in accorcance with tne Primary Containment Leakage Rate Testing : I Prograr cescribed ir. Soecification 6.8.5.g. exce:t for main stear { line isolation valves

and primary containment isolation valves '

Qicn are hycrostatically tested. sg 3 6. l .3. ll e. *Less than or equal to 100 scf per hour for all four main steam lines wnen tested at 25.0 psig.

d. A cx bin g l Kage in o f 1 *A t h a n ne medal to 5 com 14 211'. b -

_Aontayafne isol of valves in hydrostatically tested lines ^ pe atra the imary,pontainmenT., pnen testeo pr 1.Av ar * *I 2 U' l SRJ.G. f 3.13 es ha r eQua ett ton not o exceed o 1 gpm fmes the numD(r of valves one ear pene(ention for y line k ( ADO AtoTS pen attne tainment 4 hycrostatically tested - 1.10 _ _ _ g at nmi f APPLICABILITY: When PRIMARY CONTAINMENT INTEGRITY is required per Lc o n .i,3 Specification 3.6.1.1. Ell 2: Witn: ..

a. / The measured overall integrated primary containment leakage rate exceeding 0.75 L or The measured como,,ned i leakage rate for primary containment See N b.

gp yjf,c nog i

                                    $ penetrations Type B and C and        testsprimary      containment in accordance                  isolationContainment with the Primary      valves subject to 6 S'[ /

3.6.l.i l Leakage Rate Testing Program, except for main steam line isolation I valves

and primary containment isolation valves which are ]

or l l

c. h drostatically e measured leakage tested,rate exceeding exceeding0.60 La,f per hour for all four 100 sc main steam lines, or g

d. The measured combined leakage rate for all containment isolation ,

ACTrotu D valves in hydrostatically tested lines which penetrate the primary y J containment m .a..., . wm. or_ 4/)g y ,

e. The leakage rate of any hydrostatically tested line[ penetrating oc {

                                      ;      primary containment y .. u.y                        y v. , . M . ^.      ..u. 6mn alvesnereenM. tion or o

([iumyr

                                               .._. 2 of -r conty. ment             isolat
                                                                           ... .+4--                                                        y                 i G rier to increasing reactor coolant system temocrature above 200*F restore:

et. SC ~ Ine overall integrated leakage rate (s) to less than or equal to Speer4 cat.,o^ ? 0.75 La, and 3 6.l.1

                   @sma :: ^;;=12 ' M T $:-t 57 4 A.                                                                                                        .
   ..                FERMI - UNIT 2 .                                               3/4 6-2                         Amendment No. JJ2,108 l

c PAGE 3 0F 09. M"

)

l 1

                                                                                                                                                      }
                                                                                                                          ^
                                                                                                                            - o   ?...        .o.i l f .*:

( f le, i n <, r r by c e frE ' on

                                                                                                                                  ^
                                                                                                                                            .      o
                          - s; v ,, u : ,. - e.- :v-                                    t li I.s r>        're       'PCU'A*0                    ')

t tuit ti; , c oi:n t- + r.. : : -:::ntni; rec-.e...- ACTION: (Continuec; 6 : : rt; itaAagi rati f:r :- 1 : ; r *. i ', nci .~. *. Dir. i

r 4 * : ~ ; 4-primarj ::r.;,ainment isolation vaives su:Je:t to Type 5 anc C tests '

ge . in accorcance with the Primary Containment Leakage Rate Testing I S pecifi cah. Program except for main steam line isolation valves

and primary containtrent isolation valves wnich are nyarostatically tested, !

f, y test: 1: less than or eaual to 0.60 La, and r-

c. IThe leakage rate to less than er ecual to 100 scf per nour for all l l four matn steam lines, anc

d. /Thecom:1ned leakage rate for all containment isolation valves in g fc,poy p 4 hydrostatically tested lines wniSh penetrate the primary 6-containment (o,Less, tun or 34calp gg and

e. The leakage rate of any hydrostatically tested linehetratinc _ }

W primary containmentft sess Ina 4 spm pep isvinpi vasve tjtnes )i Ahe r)amoer of contai nt isol ion valv6 ner nahetration/6r jls

                                               \t.huf 3 gem /0er pen ration /

SURVEIItaNCE DEOUTpEpFNTS 4.6.1.2 Perform required primary containment leakage rate testing in j

                   -7 accordance with the Primary Containment Leakage Rate Program described in g
              .'           Specification 6.8.5.g.**

t Se e. l i Sp etMico t ,*e n

3.(.\.\ l k

S (L 3 6 . f <3,12 Frey4ency S(L 3 6 . I. 5,13 Fre.yaney A00 : 54 34.1111 d Ahrn C h k h 5emum %ow y Iday

Exemption to Appendix J of 10 CFR Part 50

 / Se e.

6fec &lcAfi *Except for LPCI Loop A and B Injection Isolation valves, which are

f. f hydrostatically tested in accordance with Soecification 4.4.3.2.2 in lieu of this requirement.

Amendment No. Jp2,108 FERMI - UNIT t. 3/4 6-3 PAGE I - 0F 09 8ev E e

I SPEciR cATwo 3 G.i.3 CONTAINMENT SYSTEMS DRYWEtt AND SUPPRESSION CHAMBER PURGE SYSTEM t IMITING CONDITION FnQ OPEDLTinN cp, g,g 3,( 3.6.1.8 The drywell and suppression chamoer purge system {0 u n. 10 . . o. . . . 39 4 :- g y . ,- ma"ed may De in operatinn with the suoply and exnaust - isolation valves in one supply line and one exhaust line open for inerting, i deinerting or pressure control. Nitrogen VENTING / makeup and pressure control 1s also allowed through the 1-inch valves. I. - g i, . . . ; 6 ; . . ; . . . ., . . ;-in Oc

                                                                                                                    ,       Q 0070 ;.'.e!! 5: ' " ::: +a "" h;..; : xt ?55 R;n

APPllCABitfTY: OPERATIONAL CONDITIONS 1, 2 g and 3. y (A DO Ac.TIONS No7E / y .g y ACTION: dd A t.mNS NOTE 2- > - i

                                         @(A00 A cT7 EMS pl01E 3 > -

With a orywell and suppression enamber purge system supply and/or 1 f a. MT1oM A exhaust isolation valve open, except as permitted above, close the l valve (s) or otherwise isolate the penetration (s) within 4 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD Ac.Ttou E SHUTDOWN within the following 24 hours.

b. With a crywell and suppression chamber purge system supply and/or h-O ,

exhaust isolation valve (s) with resilient material seals having a 1 i

          $CTtoA)D               measured leakage rate exceeding the limit nf Specification 4.6.1.8.2, restore the inoperable valve (s) to OPERABLE status h#

f within 24 hours or be in at least HOT SHUTDOWN within the next 12 hCil0d g hours and in COLD SHUTDOWN within the following 24 hours. ljk 6g SURVEllt ANCE REOUTREMENTS , i N MM I 3*I 4.6.1.8.1(Beforebeinoopenea r purge / vent operation b ;.2 SCTST the W. tJ pTg- drywell anc suppression enameer purge supply and exhaust butterfly isolation valves shall be verified not to have been open for purge / vent operatio throwgh SCT: .., - +':. ;; ..... ,, ... - :r: 2!! d:,; . - l- I .! 4.6.1.8.2 At least once per[92 days) each

l. 7 ation for each & . .O M bqp g *4 M .n..'., n d 2^ i--5, -d 0 2 . U ---t

                                                                                               ...m.,

drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals shall be demonstrated OPERABLE by verifying that the measured leakage rate & Mr "' J { ;;..G ;; g.n ., t : ~ r- --- " M M le3s[

Primary c[ntatnment nitrogen VENTING and pressure control is perinitted 8 I

through the 1-inch valves =d i: n:t :djer' '- '" 90 "r : :er 255 :- Matt-l,ME f FT 'l - UNIT"2 3/4 6-14 Amendment No. 58 z: 09 6m/ 5 PAGE_ h 0F

                                                                                             $ 6 C If(f."Ots L . (c l . 'e CONTAINMENT SYSTEMS 3 /4. 6. 3 PRIMARY CONTAINMENT 150lATION VALVES 03                        g LIMITING CONDITION FOR OPERATION k

[r eachor h'.ldiq-to- Surprassdry.ckmbu Vacuus breakyp 3.6.3 Each primary conta,inment isolation valve 6- --' +-- '- !- ---!:t M-l 34_- --___n_._m_a . .. snall be OPERABLE.** .3 OPERATIQNAL CONDITIONS 1, 2, and 3(400 AnaM F eo APPLICABILITY: 3 M Add: p en ugvired by ms h vxm b b'd 1 A N.9 %c. Tion)s HotE 2,

                                                                         \        Ag              goo Acgg g                    'k 40 AcN5

a. With oneror mme) of the primary con ainment isolation valves NOTE S E,4 inoperable.fmaintain at iesst one isolation vaive unkABLE in eacy bffectea nenetratien that is ooen andfwithin 4 hours either:

t C -~. 2.

                                                               - . - - - - .              = =        . .

Isolate each affected penetration by use of at least one Q [eguired ScN06 deactivated automatic valve secured in the isolated d' A,l position,* or aJ E

3. Isolate each affected penetration by use of at least one ocke closed manual v'1ua ^" hl$nk C *"a* *" en Qckec.y ustae w;4ssuHow secotty L.80 g au Otherwise, be in at least HOT SHUTDOWN within the next 12 nours AWDg g and in COLD SHUTDOWN within the following 24 hours, g

b. With one or more of the reactor instrumentation line excess flow AC. M C.30 check valves inoperable operation may continue O mm .......;; l

[ e--- ' .__ , _.. i :::1 x ;Ol M rovided that within~) lW hours either: 7,. fl . ins inoperspie vaive iDeturned to OPERABLE status, un f-b i2. The instrument line is isolated [and tne associateo j $: ac instrument is ceciarea inopernoie, Acnws rarar 3 Otherwise, be in at least HOT SHUTDOWN within the next 12 hours Ac.T1DW E and in COLD SHUTDOWN within the following 24 hours. g 0 b77dN O b) Acnod MofE I *lsolation valves closed to satisfy these requirements may be reopened on an inttraitteht basis under administrative control. ' d Nam 2. -fe : I *W:h:2 r :::'_3 closed valves may be opened on an intermit. tent basis,under acministrative ontrol. 1

     - s A %.t.3.'t
     - 5A 34.n.3                                                                                             h           l 'Q
  ..                   FERMI - UNil.2                                 3/4 6-20                  Amenoment No. U , 102 PAGE        7           0F      09 W"

'Y

l 4 1

hf(i):fCAT1:a$.'es) l CONTAINMENT SYSTEMS l SURVElltANCE RE00ipfMENTS l '4.6.3.1 ach primary containm t isolation valve shall e demonstrateo l l OPERAB prior to returning t valve to service after aintenance, repair o repia ment work is perform on the valve or its as ciated actuator, con 01 [8./ l or wer circuit by cyclin the valve through at le t one complete cycle f '

                  %1 travel and verifyino ha 4en1*++^a '4-= 6                                                             o~

l l ' 17.

   ,q g ,g,3,g 4.6.3.2        Each primary containment automatie isolationivalve shall be                         ,    j ),

demonstrated OPERABLE (uur um C;0 '""" a. orr"E' "^at least once per 18 g months by verifying that on a containment isolationaest signal each automatic isolation valve actuates to its isolation position.1.[aduat a 5.,ned Q 1

    .gg g, g,y, f4.6.3.3 The isolation time of each primary containment power operated or automatic valve shall be determined to be within its limit when tested                         l pursutnt to Specification 4.0.5.

l I gg3,g ,3,g Each reactor instrumentation line excess flow check valve shall be l 4.6.3.4 demonstrated OPERABLE at least once per 18 months by verifying that-the valve '$ Th::]ow. ry3gc'4 g i 4.6.3.5 Each traversing in-core probe system explosive isolation valve shall 'k be demonstrated OPERABLE: g3,4,g,.3g a. At least once per 31 days by verifying the continuity of the explosive charge. - N W Test B M d bI

b. A_t leasi onceJer 18,pojthg'by rel.oving tTe Ixplostve Youib f70m g % .3,10 ist Teast one explosive va'lve such that the explosive souib]in enc]rt; yxploAiv_g_y.al.ve yLill bg tested at least once 2er 90Rth [aTd initiatina the exo Esive soui E f us .,,....-..;....3 .wi u.c 3 iexpl ed soutb snal be from the s manufactured ba h as the one tred or from nother batch wh h has been certi ed by in ha ing at least e of that bate successfully fire . No sou L ii'N all remain in se beyond the piration of its s. elf-life l perating life. as applicable.j l

l I LR.I (![559[b'"'B"j" """" "" """~"*" '

')

FERMI - UNIT'2 3/4 6 21 Amendment No. 102 i PAGE I 0F 09 Rev5i

                                                                 .                                                             l
 -                                                                                                                             J

INSERT THIS PAGE IN FRONT OF VOLUME 12 Volume 12: IMPROVED TECHNICAL SPECIFICATIONS . i i l Remove Replace 3.6.1.3 ITS pg 3.6-7 Rev 0 3.6.1.3 ITS pg 3.6-7 Rev SA J 3.6.1.3 ITS pg 3.6-8 Rev 0 3.6.1.3 ITS pg 3.6-8 Rev SA 3.6.1.3 ITS pg 3.6-9 Rev 0 3.6.1.3 ITS pg 3.6-9 Rev SA 3.6.1.3 ITS pg 3.6-10 Rev 0 3.6.1.3 ITS pg 3.6-10 Rev SA 3.6.1.3 ITS pg 3.6-1I Rev 0 3.6.1.3 ITS pg 3.6-11 Rev SA 3.6.1.3 ITS pg 3.6-12 Rev 0 3.6.1.3 ITS pg 3.6-12 Rev SA

3.6.1.3 ITS pg 3.6-13 Rev 0 3.6.1.3 ITS pg 3.6-13 Rev SA 3.6.1.3 ITS pg 3.6-13a Rev SA 3.6.1.3 ITS pg 3.6-13b Rev SA l I l l

Rev SA 05/10/99

l )l l PCIVs j 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs) l I i LCO 3.6.1.3 Each PCIV. except reactor building to suppression chamber I

      -                                     vacuum breakers. shall be OPERABLE.                                              l 6;

J APPLICABILITY: MODES 1. 2. and 3. ' When associated instrumentation is required to be OPERABLE per LC0 3.3.6.1. " Primary Containment Isolation ! Instrumentation." ACTIONS Q ..................................... NOTES -- - - -- - --- --- -

4. 1. Penetration flow paths may be unisolated intermittently under 6l s administrative controls.

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

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

4. Enter applicable Conditions and Required Actions of LC0 3.6.1.1. " Primary Containment." when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria in MODES 1. 2. and 3.

CONDITION REQUIRED ACTION COMPLETION TIME

r0

      -f        A.     --
                                   - NOTE - --          -

A.1 Isolate the affected 4 hours except

          -           Only applicable to                                  >enetration flow path     for main steam penetration flow paths                             )y use of at least        line I             with two PCIVs.                                    one closed and g                ......................

de. activated 6NQ automatic valve. One or more closed manual valve. 8 hours for main penetration flow paths blind flange, or steam line

     'O                with one PCIV                                      check valve with flow 18               inoperable, except due                             through the valve
     .4                to leakage not within                              secured.

g limit. 6N0 (continued) a. 1 FERMI UNIT 2 3.6 7 RevisionSE. 05/10/99

h i l PCIVS 3.6.1.3 l l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2 -.-..- NOTES --- --

        ;                              1. Isolation devices in high radiation areas may be verified by use of administrative means.

l : 2. Isolation devices l l that are locked. l sealed, or l otherwise secured

     .6 ll                                    may be verified by use of l

l administrative l means. Verify the affected Once per 31 days penetration flow path for isolation is isolated. devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4, i f primary containment was de inerted while in MODE 4. if not performed within the l previous i 92 days, for l isolation I devices inside primary containment (continued) s_ . i FERMI UNIT 2 3.6 8 Revision 5b[ 05/10/99

L PCIVs 3.6.1.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 5 Isolate the affected 1 hour

            ~ ;-    B. .   .--   -NOTE        - -

B.1 5 Only applicable to penetration flow path 3 cenetration flow paths by use of at least

            -          with two PCIVs.                 one closed and Q          ......................          de. activated automatic valve.

One or more closed manual valve. < penetration flow paths or blind flange, with two PCIVs y' inoperable. except due bl to leakage not within limit. (continued) l

i. .

1 i l

                 ! FERMI     UNIT 2                    3 .6 9..             Revision Sa. 05/10/99

L PCIVs l l 3.6.1.3 ACTIONS- (continued) CONDITION REQUIRED ACTION COMPLETION TIME . l C. -- - NOTE- - --- C.1 Isolate the affected 4 hours except l Only applicable to penetration flow path for excess flow

        ;         penetration flow paths                 by use of at least         check valves l         with only one PCIV.                    one closed and              (EFCVs) and
        ;          ......................                de activated               penetrations l

automatic valve, with a closed l One or more closed manual valve, system

        ;         penetration flow paths                 or blind flange.

with one PCIV AND

                                                                                    ~
     $;j           inoperable except due s-l           to leakage not within                                            72 hours for tl            limit.                                                            EFCVs and penetrations
     -il l

with a closed system Ql tj MQ

       -l'                                          C.2    -

NOTES - -

1. Isolation devices in high radiation areas may be l

verified by use of administrative means.

          !                                               2. Isolation devices j                                                     that are locked.

I sealed. or otherwise secured may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path is isolated.

l l l (continued) l FERMI UNIT 2 3.6 10 Revision Sa'. 05/10/99 l <

r PCIVs 3.6.1.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. One or more secondary D.1 Restore leakage rates 4 hours for b il containment bypass to within limit. leakage on l leakage rate. MSIV hydrostatically l leakage rate, purge tested line valve leakage rate. l hydrostatically tested 6NQ l line leakage rate. or l EFCV leakage rate not 4 hours for within limit. secondary a containment L$ bypass leakage w AND 8 hours for MSIV ' i leakage A1Q 24 hours for purge valve leakage AND l 72 hours for p! EFCV leakage

i E. Required Action and E.1 Be in MODE 3. 12 hours l Yl associated Completion l S Time of Condition A. 6N_Q 4 B. C, or D not met in l g MODE 1, 2. or 3. E.2 Be in MODE 4. 36 hours (continued) \ - l l l l FERMI UNIT 2 3.6 11 Revision !Ia'. 05/10/99

e

1 l l l l l l PCIVs 3.6.1.3 1 l l l l l ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME

     --       F. Required Action and          F.1       Initiate action to      Immediately

[3 ' associated Completion isolate RHR Shutdown l Cooling System. O Time of Condition A. 0 2l B. C. or D not met for

    -t           RHR SDC PCIV(s)              QR required to be Initiate action to     Immediately

{} l OPERABLE during MODE 4 F.2 restore valve (s) to or 5. , OPERABLE status. i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 - - - - - NOTE - - -- -- Not required to be met when the isolation

j valves for one purge or containement Ll pressure control supply line and one I purge or containement pressure control l d[} exhaust line are open for inerting, de- ;

inerting, pressure control. ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open. l -_ Verify each drywell and suppression 31 days

       ][                         chamber purge system and containment 3                           pressure control isolation valve is
      %                           closed.

l l (continued) l i l l FERMI UNIT 2 3.6 12 Revision Sa, 05/10/99 l l s u<

r l PCIVs ; l 3.6.1.3 i l SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.6.1.3.2 - -

                                                        --- -NOTES              - -----

l 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation 31 days manual valve and blind flange that is O! located outside primary containment and J. l is not locked. sealed, or otherwise gj secured and is required to be closed during accident conditions is closed. SR 3.6.1.3.3 - ------ - NOTES--- -- - --- - -

1. Valves and blind flanges in high radiation areas may be verified by ,

use of administrative means. l

2. Not required to be met for PCIVs that are open under administrative controls. .

Verify each primary containment manual Prior to i isolation valve and blind flange that is entering MODE 2 ! n'4 located inside primary containment and is or 3 from ; R not locked, sealed, or otherwise secured MODE 4 if T and is required to be closed during primary accident conditions is closed. containment was de inerted while in MODE 4. if not performed withinsthe previous 92 days (continued) men 15 t l FERMI UNIT 2 3.6 13 Revision Sa, 05/10/99 L-

PCIVs 3.6.1.3 l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.1.3.4 Verify continuity of the traversing 31 days incore probe (TIP) shear isolation valve explosive charge. SR 3.6.1.3.5 Verify the isolation time of each power In accordance l operated automatic PCIV. except for with the MSIVs. is within limits. Inservice Testing Program SR 3.6.1.3.6 Perform leakage rate testing for each 184 days primary containment purge valve with resilient seals. 8NQ Once within 92 days after opening the i valve ! SR -3.6.1.3.7 Verify the isolation time of each MSIV is In accordance l

                          = 3 seconds and s 5 seconds.                 with the Inservice Testing Program i

SR 3.6.1.3.8 Verify each automatic PCIV actuates to 18 months ! the isolation position on an actual or ' simulated isolation signal. l SR 3.6.1.3.9 - Verify each reactor instrumentation line 18 months EFCV actuates on a simulated instrument . line break to restrict flow. (continued) s ~> l FERMI UNIT 2 3.6 134. Revision 55. 05/10/99

PCIVs 3.6.1.3 SURVEILLANCE REQUIREENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.1.3.10 Remove and test the explosive squib from 18 months on a each shear isolation valve of the TIP STAGGERED TEST System. BASIS SR 3.6.1.3.11 - ----- - -

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

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1. Verify the combined leakage rate for all In accordance secondary containment bypass leakage with the paths that are not provided with a seal Primary system is s 0.04 L, when pressurized to Containment

                              = 56.5 psig.                                                      Leakage Rate Testing Program and Inservice

Testing Program SR' 3.6.1.3.12 Verify combined MSIV leakage rate for all In accordance four main steam lines is s 100 scfh when with the tested at = 25 psig. Primary Containment Leakage Rate-Testing Program SR 3.6.1.3.13 -- -

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

Only required to be met in MODES 1. 2, and 3.

    ~ bl.                  .

Verify combined leakage rate through In accordance i hydrostatically tested lines that with the penetrate the primary containment is Primary'

l. within limits. Containment Leakage Rate Testing Program

 -~                          ~,

l FERMI UNIT 2- 3.6 13 b Revision Sa, 05/10/99 !!A;

I 1 INSERT THIS PAGE IN FRONT OF VOLUME 13

Volume 13: IMPROVED TECHNICAL SPECIFICATIONS BASES Remove Replace B 3.6.1.3 ITS pg B 3.6.1.3-2 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-2 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-3 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-3 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-5 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-5 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev 5A B 3.6.1.3 ITS pg B 3.6.1.3-7 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-7 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-10 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-10 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-11 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-11 Rev 5A B 3.6.1.3 ITS pg B 3.6.1.3-12 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-12 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-13 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.313 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3 14 Rev 0 B 3.6.1.3 ITS pg B 3.6.1.3-14 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-15 Rev SA B 3.6.1.3 ITS pg B 3.6.1.3-16 Rev SA B 3.6.1.3 ITS pg B 3.6.1.317 Rev SA B 3.6.1.5 ITS pg B 3.6.1.5-3 Rev 0 B 3.6.1.5 ITS pg B 3.6.1.5-3 Rev SA l

B 3.6.3.1 ITS pg B 3.6.3.1-2 Rev 5 B 3.6.3.1 ITS pg B 3.6.3.1-2 Rev SA r as Rev SA 05/10/99

PCIVs B 3.6.1.3 BASES I BACKGROUND (continued) the isolation capability is available without conflicting with the vacuum relief function. The drywell purge and vent lines are 24 inches in diameter: and the suppression chamber purge and vent lines are 20 inches in diameter. The 24 and 20 inch primary containment purge valves are normally maintained closed in MODES 1, 2. and 3 to ensure the primary containment boundary is maintained. However, these lines are used for inerting and de inerting the primary containment in conjunction with planned shutdowns that will involve entry into the primary containment. The isolation valves on the 24 and 20 inch vent lines have 6 inch bypass lines. The nitrogen purge supply valves for the drywell and suppression chamber are 10 inches and 6 inches, respectively. In addition.1 inch lines are provided for containment pressure control. APPLICABLE The PCIVs LC0 was derived from the assumptions related to SAFETY ANALYSES minimizing the loss of reactor coolant inventory, and establishing the primary containment boundary during major accidents. As part of the primary containment boundary. PCIV OPERABILITY supports leak tightness of primary containment. Therefore, the safety analysis of any event requiring isolation of primary containment is applicable to this LCO. A spectrum of piping breaks inside of Primary Containment varying in size. type and. location are postulated. The break types include steam lines and/or liquid process system lines. In the analysis for each of these accidents (summarized in Reference 1), it is assumed that PCIVs are either closed or close within the required isolation times following event initiation. This ensures that potential paths to the environment through PCIVs (including primary containment purge valves) are minimized. The Main Steam Line Break (MSLB) is of particular importance

                       - due to the radiological consequences of the steam release N                         outside of the primary containment. The closure time of the T                         MSIVs is a significant variable from a radiological
  %                         standpoint. The MSIV closure ~is assumed to occur no later than 10.5 seconds following the event initiation. The Q                         requirement that the MSIVs close within 3 to 5 seconds is consistent with this assumption.                                 '

q , 1 FERMI - UNIT 2 B 3.6.1.3 - 2 Revision 5"a'. 05/10/99

PCIVs B 3.6.1.3 BASES APPLICABLE SAFETY ANALYSES (continued)

         '                      The accident analyses assume that PCIVs that automatically close have stroke times no greater than that given in bl                         Reference 2. In addition to the stroke time, an additional
     'i !                       delay of 13 seconds is assumed for isolation signal delay.
     '                           and diesel generator startup (for loss of offsite power).

kl l Following the completion of the automatic containment isolation the analyses assume that containment leakage is terminated, except for the maximum allowable leakage rate. ; L,. The PCIVs are also required to function to minimize the loss of reactor coolant inventory and thus minimize the radiological consequences of postulated failures outside of containment of systems that directly connect to the reactor coolant system. These failures are also evaluated to assure , that the ability to safely shutdown the plant is maintained. i The single failure criterion required to be imposed in the conduct of unit safety analyses was considered in the original design of the primary containment purge valves. Two valves in series on each purge line provide assurance , that both the supply and exhaust lines could be isolated ) even if a single failure occurred. PCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). l LC0 PCIVs form a part of the primary containment boundary. The PCIV safety function is related to minimizing the loss of reactor coolant inventory and establishing the primary containment boundary during a DBA. The power operated automatic isolation valves are required to have isolation times within limits and actuate on an automatic isolation signal. The reactor building to-suppression chamber vacuum breakers that isolate primary fl containment penetrations are excluded from this Specification, controls on their isolation function are

                             - adequately addressed in LC0 3.6.1.7. " Reactor Building to-Ql                           Suppression Chamber Vacuum Breakers." The valves .. covered by this LC0 are listed with their associated stroke times in Reference 2.

S l FERMI UNIT 2 B 3.6.1.3 - 3 Revision 5a 05/10/99 u

I

PCIVs B 3.6.1.3 BASES LCO (continued) Purge valves with resilient seals. Secondary containment bypass valves. MSIVs. EFCVs. and hydrostatically tested valves must meet leakage rate requirements in addition to the other PCIV leakage rates which are addressed by LC0 3.6.1.1. " Primary Containment." as Type B or C testing. This LC0 provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents. APPLICABILITY In MODES 1. 2. and 3. a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore. most PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves, however, are - j required to be OPERABLE to prevent inadvertent reactor i vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.1.

                                   " Primary Containment Isolation Instrumentation." (This does not include the valves that isolate the associated instrumentation.)                                                !

i 5 . ACTIONS The ACTIONS are modified by a Note allowing penetration flow hI path (s) to be unisolated intermittently under administrative

      .:.                           controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous Q                             communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated. Due to the size of the primary containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path containing these valves is not allowed to be opened under administrative controls.
                                                                                      ~

A second Note has been added to provide clarification that, for the purpose of this LCO. separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide

                            ,       appropriate compensatory actions for each inoperable PCIV.

w . l FERMI UNIT 2 B 3.6.1.3 - 4 Revision 5$. 05/10/99

    \                                                       ;

o K.IVs B 3.6.1.3 BASES ACTIONS (continued) Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions. The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary, if the affected system (s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve). Note 4 ensures appropriate remedial actions are l ! taken when the primary containment leakage limits are exceeded. Pursuant to LC0 3.0.6. these actions are not required even when the associated LC0 is not met. Therefore. Notes 3 and 4 are added to require the proper actions be taken. l A.1 and A.2

      ,3                           With one or more penetration flow paths with one PCIV g                             inoperable except for leakage (i.e., secondary containment       '

i bypass leakage rate. MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV leakage rate) not within limit, the affected penetration ' flow paths must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. , Isolation barriers that meet this criterion are a closed and de activated automatic valve a closed manual valve, a blind flange, and a check valve with flow through the valve secured. For a penetration isolated in accordance with Required Action A.l. the device used to isolate the

                                  - penetration should be the closest available valve to the primary containment. The Required Action must be completed within the 4 hour Completion Time (8 hours for main steam Y                           lines). The Completion Time of 4 hours is reasonable I                           considering the time required to isolate the penetration and the relative importance of supporting primary containment
      %  i OPERABILITY during MODES 1, 2 and 3. For main steam lines, l      '                         -    an 8 hour Completion Time is allowed. The Completion Time of 8 hours for the main steam lines allows a period of time -

to restore the MSIVs to OPERABLE status given the' fact that 1 MSIV closure will result in isolation of the main steam N- line(s) and a potential- for plant shutdown. g , I FERMI UNIT 2 . B 3.6.1.3 - 5 Revision 5"a'. 05/10/99 a

1 PCIVs B 3.6.1.3 BASES ACTIONS (continued) For affected penetrations that have been isolated in accordance with Required Action A.1. the affected penetration flow path (s) must.be verified to be inlated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following-

                                 - an accident, and no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside primary containment" is appropriate because the devices are operated under administrative controls and the probability of their misalignment is low. For the devices inside primary containment, the time period specified " prior to entering MODE 2 or 3 from MODE 4. if primary containment was de inerted while in MODE 4. if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the devices and other administrative controls ensuring that device misalignment is an unlikely possibility.
   -p
    +
    @                               Condition A is modified by a Note indicating that this
   - ,:                             Condition is only applicable to those penetration flow paths    '

l

    @                               with two PCIVs. For penetration flow paths with one PCIV.

Condition C provides the appropriate Required Actions. j Required Action A.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areass and allows them to be verified by use of administrative means. Allowing verification by administrative means is considered acceptable..since access to these areas is typically restricted. Note 2 applies to - isolation devices that are locked, sealed, or otherwise ! secured in position and allows these devices to be verified closed by use of administrative means. Allowing - verification by administrative means is considered acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of , misalignment of these devices, once they have been verified ! to be in the proper position. is low. l s

                                ~ ~
              ~
                                                                                                     \

I FERMI UNIT 2 B 3.6.1.3 - 6 Revision Sa. 05/10/99 l e

l PCIVs B 3.6.1.3 l BASES ACTIONS (continued) BJ With one or more penetration flow paths with two PCIVs 4,, inoperable except for leakage (i.e.. secondary containment Y bypass leakage rate. MSIV leakage rate purge valve leakage rate, hydrostatically tested line leakage rate and EFCV 9 6 leakage rate) not within limit. either the inoperable PCIVs must be restored to OPERABLE status or the affected penetration flow path must be isolated within 1 hour. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve and a blind flange. The 1 hour Completion Time is consistent with the ACTIONS of y

LC0 3.6.1.1. Y Condition B is modified by a Note indicating this Condition 4 is only applicable to penetration flow paths with two PCIVs. Q For penetration flow paths with one PCIV. Condition C provides the appropriate Required Actions. s C.1 and C.2 4 With one or more penetration flow paths with one PCIV

   $                              inoperable. except for leakage (i.e., secondary containment    l
     .                            bypass leakage rate. MSIV leakage rate. purge valve leakage 5                             rate, hydrostatically tested line leakage rate. and EFCV M                              leakage rate) not within limit, the inoperable valve must be    ,

restored to OPERABLE status or the affected penetration flow I g path must be isolated. The method of isolation must include

       %                          the use of at least one isolation barrier that cannot be       !

adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and s de-activated automatic valve, a closed manual valve, and a m blind flange. A check valve may not be used to isolate the

   -f                             affected penetration. The Completion Time of 72 hours for      4
    %                             penetrations with a closed system is reasonable considering

the relative stability of the closed system (hence.

reliability) to act as a penetration isolation boundary and k the relative importance of supporting primary containment OPERABILITY during MODES 1. 2. and 3. The closed system must meet the requirements of' Reference 4. The Completion Time of 72 hours for EFCVs is also reasonable considering the instrument and the small pipe diameter of penetration (hence, reliability) to act as a penetration isolation 7- , l' FERMI UNIT 2 B 3.6.1.3 - 7 Revision 5 . 05/10/99 a

PCIVs B 3.6.I.3 BASES ACTIONS (continued) boundary and the small pipe diameter of the affected l penetrations. In the event the affected penetration flow

path is isolated in accordance with Required Action C.1, the

        ;                          affected penetration must be verified to be isolated on a
        ;                          periodic basis. This is necessary to ensure that primary
        ;                          containment penetrations required to be isolated following l

an accident are isolated. The Completion Time of once per

        ;                          31 days for verifying each affected penetration is isolated l                         is appropriate because the valves are operated under administrative controls and the probability of their
         !                         misalignment is low.

I H_ Condition C is modified by a Note indicating that this lj Condition is only applicable to penetration flow paths with tl only one PCIV. For penetration flow paths with two PCIVs.

r: Conditions A and B provide the appropriate Required Actions.

Required Action C.2 is modified by two Notes. Note 1 k , applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of l administrative means. Allowing verification by

           '                        administrative means is considered acceptable, since access to these areas is typically restricted. Therefore. the
                                     )robability of misalignment of these valves, once they have
           ,                         )een verified to be in the pro)er position, is low. Note 2 i                        applies to isolation devices t1at are locked. sealed. or
           !                        otherwise secured in position and allows these devices to be
            '                       verified closed by use of administrative means. Allowing          !

verification by administrative means is considered i acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not 1 inadvertently repositioned. i I D.d a With one or more secondary containment bypass leakage rate

       -                             (SR 3.6.1.3.11). MSIV leakage rate (SR 3.6.1.3.12), purge M                                valve leakage rate (SR 3.6.1.3.6), hydrostatically tested line leakage rate (SR 3.6.1.3.13), or EFCV leakage rate (SR 3.6.1'.3.9) not within limit, the assumptions of the safety analysis may not be met. Therefore, the le be restored to within limit. Restoration can be ,akage must accomplished by isolating the" penetration that caused the limit to be exceeded by use of one closed and de activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated

_ .a j FERMI UNIT 2 B 3.6.1.3 - 8 Revision Sa, 05/10/99

l PCIVs l B 3.6.1.3 i l BASES 1 ACTIONS (continued) penetration is assumed to be the actual pathway leakage through the isolation device. If two isolation devices are i used to isolate the penetration. the leakage rate is assumed i to be the lesser actual pathway leakage of the two devices. l l The 4 hour Completion Time for leakage on hydrostatically tested lines and for secondary containment bypass leakage is ! {l reasonable considering the time required to restore the l o leakage by isolating the penetration and the relative upl importance of leakage to the overall containment function. 4j For MSIV leakage, an 8 hour Completion Time is allowed. The Completion Time of 8 hours for MSIV leakage allows a period q! Of time to restore the MSIVs to OPERABLE status given the l (j l fact that the MSIV closure will result in isolation of the main steam line(s) and potential for plant shutdown. The 24 i l hour Completion Time for purge valve leakage is acceptable considering the purge valves remain closed so that a gross i i breach of the containment does not exist. The 72 hour I Completion Time for EFCV leakage is acceptable based on the instrument and small pipe diameter of the penetration (hence, reliability) to act as a penetration isolation i boundary, j l E.1 and E.2 f If any Required Action and associated Completion Time cannot 1 i I R be met in MODE 1, 2. or 3. the plant must be brought to a i MODE in which the LC0 does not apply. To achieve this

    -f                              status, the plant must be brought to at least _HODE 3 within J.                              12 hours and to MODE 4 within 36 hours. The allowed              l Completion Times are reasonable, based on operating Q                                experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

i

i 1 ie, , l FERMI UNIT 2 B 3.6.1.3 - 9 Revision SW, 05/10/99

I PCIVs B 3.6.1.3 ES ACTIONS (continued) j 4l El 1 If any Required Action and associated Completion Time cannot l i- be met, the unit must be placed in a condition in which the i 2 LC0 does not apply. Action must be immediately initiated to q isolate the RHR Shutdown Cooling System. However. if the shutdown cooling function is needed to provide core cooling, i these Required Actions allow the penetration flow path to l remain unisolated provided action is immediately initiated to restore the valve to OPERABLE status or to isolate the RHR Shutdown Cooling System (i.e. provide alternate decay heat removal capabilities so the penetration flo".' pth can be isolated). Actions must continue until the valve is , restored to OPERABLE status or the RHR Shutdown Cooling System is isolated. SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR ensures that the drywell.and suppression chamber purge system isolation valves (6 inch.10 inch. 20 inch. and

          '                       24 inch) and the containment pressure control valves (1 inch) are closed as required or, if open, open for an      !

j' allowable reason. If a purge or containment pressure control valve is open in violation of this SR. the valve is ! considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is ' not considered to have leakage outside of limits. Primary l ' containment purge and containment pressure control valves l are only required to be closed in H0 DES 1, 2. and 3 (i.e. . no isolation instrumentation functions of LC0 3.3.6.1 are ' El required to be OPERABLE for isolation of these valves outside of MODES 1. 2. and 3). If a LOCA inside primary

      .1 containment occurs in these MODES, the purge valves may not l
     %q,                           be capable of closing before the pressure pulse affects i                           systems downstream of the purge valves. At other times l

(e.g., during handling of irradiated fuel) pressurization I concerns are not present and the purge and containment I pressure control valves are allowed to be open. The SR is 1 modified by a Note stating that the SR is not required to be

            !                      met when the purge or containment pressure control valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de inerting. pressure control. ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open.

l FERMI UNIT 2 B 3.6.1.3 - 10 Revision Sa, 05/10/99

PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

i. The purge valves (6 inch. 10 inch 20 inch, and 24 incn) and y the containment pressure control valves (1 inch) are capable T; of closing in the envirnnment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other PCIV requirements discussed in SR 3.6.1.3.2.

SR 3.6.1.3.2 This SR verifies that each primary containment isolation Q manual valve and blind flange that is located outside 1l primary containment and is not locked. sealed, or otherwise Qj secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits. , i This 5.' - not require any testing or valve manipulation. l i Rather.1t involves verification that those PCIVs outside i primary containment. and capable of being mispositioned, are in the correct position. Since verification of valve position for PCIVs outside primary containment is relatively l easy, the 31 day Frequency was chosen to provide added assurance that the PCIVs are in the correct positions. Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered ! acceptable since access to these areas is typically restricted during MODES 1. 2. and 3 for ALARA reasons. Therefore the probability of misalignment of these PCIVs. once they have 3een verified to be in the proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are en open. This SR does not apply to valves that are locked. i sealed, or otherwise secured in the closed position since ft these were verified to be in the correct position upon T - locking, sealing, or securing. 4

?-        ,

_l FERMI. UNIT 2 B 3.6.1.3 -11 Revision 55. 05/10/99 e'.

I l l l 1 L l PCIVs l B 3.6.1.3 1 i BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.6.1.3.3 l This SR verifies that each primary containment isolation , manual valve and blind flange that is located inside primary

    \l                        containment and is not locked, sealed, or otherwise secured i                       and is required to be closed during accident conditions is
      \                       closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary 1    M                         containment boundary is within design limits. For PCIVs 7                        inside primary containmer.t. the Frequency defined as " prior
    '                         to entering MODE 2 or 3 from MODE 4 if primary containment Q                          was de inerted while in MODE 4. if not performed within the previous 92 days" is appropriate since these PCIVs are              ,
   -l                         operated under administrative controls and the probability          l Of their misalignment is low. This SR does not apply to Nl                       valves that are locked sealed, or otherwise secured in the closed position since these were verified to be in the l                     correct position upon locking, sealing, or securing.                ,

1 Two Notes have been added to this SR. The first Note allows l valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing l verification by administrative controls is considered acceptable since the primary containment is inerted and l access to these areas is typically restricted during ' MODES 1. 2. and 3 for ALARA reasons. Therefore, the probability of misalignment of these PCIVs. Once they have been verified to be in their proper position. is low. A second Note has been included to cicrify that PCIVs that are open under administrative controls are not required to meet the SR during the time that the PCIVs are open. SR 3.6.1.3.4 . 1 The traversing incore probe (TIP) shear isolation valves are actuated by explosive charges. Surveillance of explosive charge continuity provides assurance that TIP valves will actuate when required. Other administrative controls, such as those that limit the shelf life of the explosive charges.

                          -    must be followed. The 31 day Frequency is based on operating experience that has demonstrated the reliability of the explosive charge continuity.

l r , l FERMI UNIT 2 B 3.6.1.3.- 12 Revision SE. 05/10/99

l l PCIVs B 3.6.1.3 l BASES I SURVEILLANCE REQUIREMENTS (continued) l SR 3.6.1.3.5 h; Verifying the isolation time of each power operated automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV l full closure isolation time is demonstrated by SR 3.6.1.3.7. l I 1 The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the i i safety analyses. The isolation time and Frequency of this l SR are in accordance with the requirements of the Inservice l Testing Program. i SR 3.6.1.3.6 i I For primary containment purge valves with resilient seals (6 inch, 10 inch, 20 inch. and 24 inch), additional leakage rate testing beyond the test requirements of 10 CFR 50. Appendix J. Option B (Ref. 3). is required to ensure oar, OPERABILITY. This will ensure

                                                 . Operating     that leakage experience       is s 0.05 L,d has demonstrate when    tested at that this type o  P'f seal  has  the potential to degrade   in a shorter time period than do other seal types. Based on this i                             observation and the importance of maintaining this penetration leak tight (due to the direct path between primary containment and the environment). a Frequency of 184 days was established.

1 Additionally. this SR must be performed once within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened. ! The primary containment purge valves are only required to meet leakage rate testing requirements in H00ES 1. 2. and 3. ' (i.e. no isolation instrumentation functions of LC0 3.3.6.1 are required to be OPERABLE for purge system isolation

                         - outside of H0 DES 1. 2. and 3).         If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria, i

l? , l FERMI UNIT 2 B 3.6.1.3 - 13 Revision 5'a. 05/10/99 l 9

1 PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.6.1.3.7 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. This ensures that the calculated radiological consequences of these events remain within 1 10 CFR 100 limits. The minimum stroke time ensures'that isolation does not result in a pressure spike more rapid than assumed in the transient analyses. The Frequency of this SR is in accordance with the requirements of the ! Inservice Testing Program. SR 3.6.1.3.8 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM OAl FUNCTIONAL TEST in SR 3.3.6.1.5 overlaps this SR to provide complete testing of the safety function. The 18 month Frequency was developed considering it is prudent that this Surveillance be performed only during a unit outage since isolation of penetrations would eliminate cooling water flow and disrupt the normal operation of many critical components. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.6.1.3.9 This SR requires a demnnstration that each reactor instrumentation line excess flow check valve (EFCV) is OPERABLE by verifying that the valve restricts flow on a simulated instrument line break. This SR provides assurance that the instrumentation line EFCVs will perform so that

                   - predicted radiological consequences will not be exceeded during the postulated instrument line break event evaluated in Reference 5. The 18 month Frequency is based on the typical performance of this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating              -

g l FERMI UNIT 2 B 3.6.1.3 - 14 Revision Sa',' 05/10/99 9

PCIVs , E 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued) experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore. the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.6.1.3.10 The TIP shear isolation valves are actuated by explosive charges. An in place functional test is not possible with this design. The explosive squib is removed and tested to provide assurance that the valves will actuate when required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of the batch successfully fired. No squib will remain in service beyond the expiration of its shelf life or its operating life. The Frequency of 18 months on a STAGGERED TEST BASIS is considered adequate given the administrative controls on replacement charges and the frequent checks of circuit continuity (SR 3.6.1.3.4). SR 3.6.1.3.11 This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of Reference 1 are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leakage (leakage trough the worse of the two isolation valves) unless the penetration is isolated by use of one closed and de activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation device. If both isolation valves in the penetration are closed, the y actual leakage rate is the lesser leakage rate of the two i valves. The frequency is required by the Primary g Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. Additionally, some

                        - secondary containment bypass paths (refer to UFSAR 6.2.1.2.2.3) use non PCIVs and therefore are not addressed by the testing Frequency of 10 CFR 50. Appendix J.' testing.

To address the testing for these valves, the Frequency also includes a requirement to be in accordance with the Inservice Testing Program.

 ?        ,

l FERMI UNIT 2 B 3.6.1.3 - 15 Revision 5$. 05/10/99 a

PCIVs B 3.6.1.3 BASES

          -SURVEILLANCE REQUIREMENTS (continued)-

Secondary containment bypass leakage is also considered part of L,. Therefore. Note 1 assures that any secondary ; containment bypass leakage is appropriately evaluated against the criteria for overall containment leakage. SR 3.6.1.3.12 The analyses in References 1 and 4 are based on leakage that is less than the specified leakage rate. Leakage through all four main steam lines must be s 100 scfh when tested at a Pi (25 psig). This ensures that MSIV leakage is properly ' accounted for to assure safety analysis assumptions. regarding the MSIV LCS ability to provide a positive pressure seal between MSIVs. remain valid. This leakage test is performed in lieu of 10 CFR 50. Appendix J. Type C l I test requirements, based on an exemption to 10 CFR 50. Appendix J. As such, this leakage is not combined with the Type B and C leakage rate totals. The Frequency is required by the Primary Containment Leakage Rate Testing Program. SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides , assurance that the calculation assumptions of Reference 2 y are met. The acceptance criteria for the combined leakage s - of all hydrostatically tested lines is 1 gpx times the g number of valves per penetration, not to exceed 3 gpm, when (= 62.2 psig). Additionally, a combined w g tested leakageatrate 1.1lim P,it of s 5 gpm when tested at 1.1 P, (= 62.2 psig) is applied for all hydrostatically tested

    $                            PCIVs that penetrate containment. The combined leakage rates must be demonstrated in accordance with the leakage rate test Frequency required by Primary Containment Leakage Rate Testing Program.

This SR has been modified by a Note that states that these valves are only required to meet the combined leakage rate in MODES 1. 2. and 3. since this is when the Reactor Coolant System is pressurized and primary containment is required.

                           - In some instances the valves are required to be capable of
                               - automatically closing during MODES other than MODE,5 1, 2.

and 3. However specific leakage limits are not applicable

                              ~ in these other MODES or conditions.

J l FERMI UNIT 2 B 3.6.1.3 -16 Revision 5[ 05/10/99 5 o'

i PCIVs B 3.6.1.3 l 1 BASES REFERENCES 1. UFSAR. Chapter 15.

2. UFSAR. Table 6.2-2.

3. 10 CFR 50. Appendix J. Option B.

4. UFSAR. Section 6.2.

5. UFSAR. Section 15.6.2.

i l i 1 r .,a_ l FERMI UNIT 2 B 3.6'.1.3 - 17 ' Revision Sa'. 05/10/99

Drywell Air Temperature B 3.6.1.5 BASES SURVEILLANCE SR 3.6.1.5.1 REQUIREMENTS Verifying that the drywell average air temperature is within the LCO limit ensures that operation remains within the temperature limits for the primary containment. Drywell air temperature is monitored in all zones and at various elevations. Due to the shape of the drywell, a volumetric average is used to determine an accurate representation of the actual average temperature. This is accomplished by averaging at least one reading at each of the following elevations:

     !                     a. 590 ft. O inches (azimuth 90*. 135* 270*. or 316*)

4l!' b. 597 ft. O inches (azimuth 35* 75*. 93*. 135*. 175*. 200*. 246*. 272*, 306*. or 345*)

c. 621 ft. 8 inches (azimuth 0*. 90*. 180*. 270*)

d 648 ft. 6 inchec (azimuth 45*. 135*. 225*. 315*)

e. 662 ft. O inches (azimuth 0* 90*. 180*. 285*)

f. 685 ft. 6 inches (azimuth 0* or 180*)

The 24 hour Frequency of the SR was developed based on operating experience related to drywell average air temperature variations and temperature instrument drift during the applicable MODES and the low probability of a DBA occurring between surveillances. Furthermore. the 24 hour Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal drywell air temperature condition. REFERENCES 1. UFSAR. Section 6.2.

2. UFSAR. Table 6.2-1.

                                                                                            . ,.e-3
                         +'*.

l FERMI UNIT 2 B 3.6.1.5 - 3 Revision Sa',' 05/10/99

p Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES BACKGROUND (continued) The process gas circulating through the heater, the reaction chamber, and the cooler is manually regulated to 150 scfm. l 4 The process gas is heated to 1300*F. The hydrogen and oxygen gases are recombined into water vapor which is then condensed in the water spray gas cooler by the associated residual heat removal subsystem and discharged with some of the effluent process gas to the suppression chamber. The majority of the cooled. effluent process gas is mixed with the incoming process gas to dilute the incoming gas prior to the mixture entering the heater section. , The primary containment hydrogen recombiner provides gT5l APPLICABLE SAFETY ANALYSES the capability of controlling the bulk hydrogen concentration in primary containment to less than the lower Q flammable concentration of 6.0 v/o following a DBA. This

    &v      l control would prevent a primary containment wide hydrogen burn, thus ensuring that pressure and temperature conditions assumed in the. analysis are not exceeded. The limiting DBA relative to hydrogen generation is a LOCA.

r Hydrogen may accumulate in primary containment following a LOCA as a result of:

a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant; or

b. Hydrogen contained in the water in the Reactor Coolant System from radiolytic decomposition and the hydrogen water chemistry control program.

y To evaluate the potential for hydrogen accumulation in primary containment following a LOCA, the hydrogen generation is calculated as a function of time following the initiation of the accident. Assumptions recommended by Reference 3 are used to maximize the amount of hydrogen calculated. The calculation (Ref. 4) confirms that hydrogen and oxygen can be safely and effectively controlled to the limits of Table 1 of Reference 5. UNIT 2 B 3.6.3.1-2 Revision 58', 05/10/99

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