ML20209D400

Rev 9 to Fermi 2 ITS Submittal Dtd 980403,providing Update for Sections 3.0,4.0 & 5.0

ML20209D400
Person / Time
Site:	Fermi
Issue date:	07/07/1999
From:	DETROIT EDISON CO.
To:
Shared Package
ML20209D385	List: ML20209D400 NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions
References
NUDOCS 9907130128
Download: ML20209D400 (62)

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{{#Wiki_filter:INSERT THIS PAGE IN FRONT OF VOLUME 2 Volume 2.SECTION 1.0,2.0 & 3.0 Remove Replace B 3.0ITS pg B 3.0-5 Rav 0 B 3.0 ITS pg B 3.0-5 Rev 9 3.0 CTS M/U 3/4 0-1 (2) pg 3 of 12 Rev 0 3.0 CTS M/U 3/4 0-1 (2) pg 3 of 12 Rev 9 B 3.0 NUREG M/U pg]) 3.0-4 B 3.0 NUREG M/U pg B 3.0-4 Rev 9 B 3.0 NUREG M/D pg 1l 3.0-5 B 3.0 NUREG M/U pg B 3.0-5 Rev 9 l 9907130128 990707 PDR ADOCK 05000341 Rev 9 07/07/99 P PDR

LC0 Applicability B 3.0 BASES LCO 3.0.3 (continued) ACTIONS of individual Specifications sufficiently define the remedial measures to be taken, j Exceptions to LCO 3.0.3 are provided in. instances where requiring a unit shutdown, in accordance.with LC0 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An e tam)le of this is in 'p l LCO 3.7.7, " Spent Fuel Storage Pool Wat fr _evel," LC0 3.7.7 has an Applicability of "During movemet.t Of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this @ -l LCO can be applicable in any or all MODES. If the LC0 and t/ j the Required Actions of LC0 3.7.7 are not met while in [ MODE 1, 2 or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required /l Action of LCO 3.7.7 of " Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LC0 3.0.3. These exceptions are addressed in the individual Specifications. LC0_3.0.4 LC0 3.0.4 establishes limitations on changes in MODES or other specified conditions in the A>plicability when an LCO is not met. It precludes placing t1e unit in a MODE or other.specified condition stated in that Applicability (e.g., Applicability desired to be entered) when the following exist: a. Unit conditions are such that the requirements of the LC0 would not be met in the Applicability desired to be entered: and b. Continued noncompliance with the LC0 requirements, if the A)plicability were entered, would result in the . unit >eing required to exit the Applicability desired to be entered to comply with the Required Actions. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time' in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made l FERMI - UNIT'2 B 3.0-5 Revision 9, 07/07/99

I 1 Specification 3.0 l INSERT 3.0 4 l When an LC0 is not met, entry inta a MODE or other specified l condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation 'n the MODE or other specified condition in the i Applicability for an unlimited period of time. This i Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. Exceptions to this Specification are stated in the individual 7 lk Specifications. i l LC0 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. l l INSERT 3.0 5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other l equipment. This is an exception to LC0 3.0.2 for the system i returned to service under administrative control to perform l the testing required to demonstrate OPERABILITY. l' l l l l FERMI - UNIT 2 07/07/99l Page 3/4 01 (2) 3 0F. REVfION 9. PAGE .t

l i e LCO Applicability B 3.0 BASES v LCO 3.0.3 A unit shutdown required in accordance ~with LCO 3.0.3 may be (continued) terminated and LCO 3.0.'3 exited if any of the following occurs: a. The LC0 is now met. b. A Condition exists for which the Required Actions have now been per*ormed, c. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the ti LCO 3.0.3 is exited. s.c o The time limits of Lxift.; tin 3.0.3 allow 37 hours for IQ the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of 1 operation when a shutdown is required, the time limit for reaching the next lower MODE applies. If a ower MODE is reached in less time than allowed, 5:xr )the total lf-8 allowable time to reach MODE 4. or other a,pplicable MODE, is not reduced. For example, if MODE 2 is reached in 2 hours, then the time allowed for reaching MODE 3 is the next j 11 hours, because the total time for reaching MODE 3 is not i reduced from the allowable limit of 13 hours. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed. t' In MODES 1, 2, and 3, LC0 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LC0 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most rer.trictive Condition required by LCO 3.0.3. The requirements of LC0 3.0.3 do not apply in other zTacified conditions of the i Applicability Cunless in MODE 1, If, or 3) because the ACTIONS of ind9vioual Specificati;ns sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances'where requiring a unit shutdown, in accordance with LC0 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in h LCO 3.M,* " Spent Fuel Storage Pool Water Level." LCO 3.7. has an%pplicability of 'During movement of irradiated fuel G (continued) "./' n! B 3.0-4 5 " 1, ^'/07/95 Rd9 4

l ' ~ l LCO Applicability i B 3.0 BASES LCO 3.0.3 assemblies in the spent fuel storage pool." Therefere, this (continued) LCO can be applicable in any or all MODES. If the LCO and the Reovired Actions of LCO 3.7.gare not met while la l MODE 1, 2, or.s, mere is no sarety benefit to be gained by r7 placing the unit in a shutdown condition. The Required i Action of LCO 3.7gof " Suspend movement of irradiated fusi l assemBTTas m sne spent fuel storage pooT" is the appropriate Required Action to complete in lieu of the actions of LCD 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 LC0 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It precludes placing the unit in a MODE or other specified conditilon stated in that Applicability (e.g., Applicability destred to be entered) when the following exist: a. Unit conditions are such that the requirements of the LCO would not be met in the Applicability desired to be entered; and b. Continued noncompliance with the LCO requirements, if the Applicability were entered, would result in the unit being required to exit the Applicability desired ( to be entered to comply with the Required Actions. Compliance with Required Actions that per, sit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provider an acceptable level of safety for continued operation. This is without regard to the status of the unit before or,after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability (continued) ?*!^ "E B 3'.0-5 k:,c^jCin ~

INSERT THIS PAGE IN FRONT OF VOLUME 10 h . Volume 10 SECTION 3.9,3.10,4.0 & 5.0 - Remove Replace 4.0 NUREG M/U pg 4.0-1 4.0 NUREG M/U pg 4.01 Rev 9 4.0 NUREG M/U pg 4.0-2 4.0 NUREG M/U pg 4.0-2 Rev 9 4.0 JFD's pg 1 Rev 0 4.0 JFD's pg i Rev 9 5.2 DOCS pg i Rev 0 5.2 DOCS pg i Rev 9 l 5.4 ITS pg 5.0-6 Rev 0 5.4 ITS pg 5.0-6 Rev 9 5.4 DOCS pg 2 Rev 0 5.4 DOCS pg 2 Rev 9 5.4 DOCS pg 3 Rev 0 5.4 DOCS pg 3 Rev 9 5.4 NUREG M/U pg 5.0-6 5.4 NUREG M/U pg 5.0-6 Rev 9 5.5 ITS pg 5.0-11 Rev 0 5.5 ITS pg 5.0-11 Rev 9 5.5 ITS pg 5.0-13 Rev 0 5.5 ITS pg 5.0-13 Rev 9 5.5 ITS pg 5.014 Rev 0 5.5 ITS pg 5.0-14 Rev 9 5.5 ITS pg 5.0-15 Rev 0 5.5 ITS pg 5.0-15 Rev 9 5.5 ITS pg 5.0-I8 Rev 0 5.5 ITS pg 5.0-18 Rev 9 5.5 ITS pg 5.0-19 Rev 2 5.5 ITS pg 5.0-19 Rev 9 5.5 ITS pg 5.0-19(i) Rev 2 5.5 CTS M/U (1-4) pg i of 24 5.5 CTS M/U (1-4) pg i of 24 Rev 9 5.5 CTS M/U (3/4 0-2) pg 2 of 24 5.5 CTS M/U (3/4 0-2) pg 2 of 24 Rev 9 5.5 CTS M/U (3/4 6-55) pg 10 of 24 ' 5.5 CTS M/U (3/4 6-55) pg 10 of 24 Rev 9 I 5.5 CTS M/U (3/4 7-3) pg 12 of 24 5.5 CTS M/U (3/4 7-3) pg !? of 24 Rev 9 l 5.5 CTS M/U (6-16b) pg 23 of 24 5.5 CTS M/U (6-16b) pg 23 of 24 Rev 9 5.5 CTS M/U (6-16c) pg 23a of 24 5.5 CTS M/U (6-16c) pg 23a of 24 Rev 9 5.5 CTS M/U (6-24) pg 24 of 24 5.5 CTS M/U (6-24) pg 24 of '4 Rev 9 5.5 DOCS pg i Rev 0 5.5 DOCS pg i Rev 9 5.5 DOCS pg 3 Rev 2 5.5 DOCS pg 3 Rev 9 ) 5.5 DOCS pg 3(i) Rev 2 5.5 DOC's pg 3(ii) Rev 2 5.5 DOCS pg 4 Rev 0 5.5 DOCS pg 4 Rev 9 5.5 DOCS pg 5 Rev 0 5.5 DOCS pg 5 Rev 9 5.5 DOCS pg 6 Rev 0 5.5 DOCS pg 6 Rev 9 I Rev9 07/07/99

1 l

Volume 10 ' SECTION 3.9,3.10,4.0 & 5.0 (cont'd).

Remove Replace 5.5 DOCS pg 7 Rev 0 5.5 DOCS pg 7 Rev 9 5.5 DOCS pg 8 Rev 9 5.5 NUREG M/U pg 5.0-11 5.5 NUREG M/U pg 5.0-11 Rev 9 5.5 NUREG M/U pg 5.0-12 5.5 NUREG M/U pg 5.0-12 Rev 9 5.5 NUREG M/U pg 5.0-13 5.5 NUREG M/U pg 5.0-13 Rev 9 5.5 NUREG M/U pg 5.0-13 (Insert) 5.5 NUREG M/U pg 5.0-13 (Insert) Rev 9 - 5.5 NUREG M/U pg 5.0-17 ~ 5.5 NUREG M/U pg 5.0-17 Rev 9 5.5 NUREG M/U pg 5.0-17(3)(Insert) 5.5 NUREG M/U pg 5.0-17(3)(Insert) Rev 9 5.5 JFD's pg i Rev 0 5.5 JFD's pg 1 Rev 9 5.6 DOCS pg 2 Rev 0 5.6 DOCS pg 2 Rev 9 l l i l Rev 9 07/07/99 Mm .m

1 i Design Features 4.0 4.0 DESIGN FEATURES < c7.r> 4.1 Site Location [ Text descrii, tier, er ;it; lecet'=.] ggf.,g g, g _ / (g, f y 4.2 Reactor Core 4.2.1 Fuel Assemblies 7g4-(S. 3. I) 1 The reactor shall contain,4460? fuel assemblies. Each assembly shall consist of a matrix of (Eircalloy ~"": fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0,) as fuel materialsk and water rodstf Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. 4.2.2 Control Rod Assemblies /96 l The reactor core shall contain-EM7-] ll begboron carbide, hafniu cruciform shaped control rod assemblies. The control material sha r j meta 1AasapprovedbytheNRC. ~ \\ l 4.3 Fuel Storage g Criticality l4--- J 4.3.1.1 The spent fuel storage racks are designed and shall be [5.(,/) maintained with: a. Fuel assemblies having a maximums-infinity of 11.31 gin the normal reactor core configcration at n "*m "*W%* = = b. k s 0.95 if fully flooded with unborated water, x wNch includes an allowance for uncertainties as h describedinfSection9.1ofthe/SAR;and 1 l (continued)

• 1"'/4 STS 4.0-1

- L... v= h l I 8Ei/ i 1 I

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued) 6,22 ND> A nominal f4,6} inch center to center distance [56./.6 ) c. betwee fuel assemblies placed in thy torace .\\ rac T (hopf n'enisty) .3.1.2 The new fuel storage racks are 'esignea una snaii ne, 1 }, maint ned with: O givf a naminal a. Fuel assemblies havi a maximum [k-infinity of .31% in the normal actor core configuration t /49 Y 6 6 s.ac4 @ldconditions7[ co erage-U-235 enrichment-of craffe /s cenfer [4.5] weight perc ); 8 " "' ' b. h/ch include s 0.95 if 11y flooded with unborated ater, fuel attemd/s'es an allowance for uncertai es as 1 ( g/oce/ in fAc describedinjSection9.1ofthedFSARl; { I-dord$C '9 C bJ, kg,ludes c. s 0. if moderated by aqueous f , which h inc n allowa~nce for uncertai es as t W - descri in [Section 9.1 of-the ]; and ('. An .en fuel!as}semblies placnel-{440 -inch center t center distance instorageracks.) . bet 4.3.2 Drainane The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation-[40 ft]q Of[.//,F/nc/c 4.3.3 Canacity The spent fuel storage pool is designed and shall be maintai*ned with a storage capacity limited to no more than 6,0;] fuel 0=/: :T! 4.0-2 as 2, 04/07/;; pe. f

l ) i JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: CHAPTER 4.0 - DESIGN FEATURES L NON BRACKETED PLANT SPECIFIC CHANGES l P.1 These changes are made to NUREG-1433 to reflect Fermi 2 current licensing basis: including design features, existing license I requirements and commitments. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. I P.2 Not used. ) P.3 Not used. Y l4 P.4 Not used. ' FERMI - UNIT 2 1 REVISION 9. 07/07/99l l

7.-.-- / I 1 l DISCUSSION OF CHANGES ITS: SECTION 5.2 - ORGANIZATION l ADMINISTRATIVE l . A.1 In the conversion of the Fermi 2 current Technical. Specifications l (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 The STA requirements of CTS 6.2.4.1 are modified to reference the Commission Policy Statement on Engineering Expertise on Shift in l ITS 5.2. Since the policy statement encompasses the current -requirements,~ this change is administrative with no impact on . safety. A.3 CTS 6.2.2.c footnote has been modified in a Note to ITS 5.0 which clarifies.the wording and intent of this CTS footnote. Since this is a clarification of intent which is consistent with current Technical Specifications, this change is administrative and will not impact safety. Also, for consistency, CTS 6.2.1.c and 6.8.6 [ references to " health physics" are revised to " radiation g protection." TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES LESS RESTRICTIVE " Generic" l LA.1 CTS 6.2.2 specifies the un'it staff requirements and CTS Table 6.2.2-1, specifically defines the number of licensed operators required for each position and limitation on absences. These details are also defined in UFSAR Section 13.1.2.5. Changes to the UFSAR are controlled in accordance with 10 CFR 50.59. The minimum shift crew requirements for licensed operators and senior reactor operators are contained in 10 CFR 50.54 (k), (1), and (m) and do not need to be repeated in the ITS. The minimum shift crew l requirements for non-licensed plant equipment operators (i.e., Nuclear Power Plant Operators or Nuclear Assistant Power Plant FERMI - UNIT 2 1 REVISION 9. 07/07/99l

P k l Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS '5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and ' maintained covering the following activities: l a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2. Appendix A. February 1978: 4* b. The emergency operating procedures required to implement the i l requirements of NUREG-0737 and to NUREG 0737. Supplement 1 as stated in Generic Letter 82-33: i c. Quality assurance for effluent and environmental monitoring: d. Fire Protection Program implementation: and e. All programs specified in Specification 5.5. i i l FERMI - UNIT 2 5.0-6 Revision 9, 07/07/99

r F DISCUSSION OF CHANGES ITS: SECTION 5.4 PROCEDURES TECHNICAL CHANGES - LESS RESTRICTIVE " Generic" LA.1 CTS 6.8.1.j details the specific guidance documents requiring written procedures for the Quality Assurance Program for effluent and environmental monitoring..ITS 5.5.1.d requires that, " Written procedures shall be established, implemented.'and maintained covering Quality assurance for effluent and environmental monitoring," but does not provide specific details on the guidance documents for these quality assurance activities. Defining these guidance documents in ITS is not necessary to ensure a successful T O Quality Assurance Program for effluent and environmental lg 0 monitoring. Therefore, these details will be relocated to the QA Program. This change is consistent with NUREG 1433. The information moved to the QA Program requires changes to be controlled in accordance with 10CFR50.54(a). This relocation continues to provide adequate protection of the public health and safety since the requirement that written procedures shall be established, implemented, and maintained covering quality assurance for effluent and environmental monitoring continues to be required by tne Technical Specifications. LA.2 CTS 6.8.1.b requires procedures to implement commitments made in response to NUREG 0737. ITS 5.4.1.b requires only procedures to cover the emergency operating procedures that are required to meet NUREG 0737 (a reference to NUREG 0737 Supplement 1 and Generic Letter 82 33 is added for clarity and completeness: this reflects an administrative change discussed here for completeness). Commitments for other-procedures recommended in NUREG-0737 are k being relocated to UFSAR Section 13.5. Prescribing these commitments within the ITS is not necessary to provide adequate protection of the public health and safety since the requirement that written procedures shall be established, implemented, and maintained covering the remainder of the NUREG 0737 commitments can be adequately controlled by 10CFR50.59. This change is consistent with NUREG-1433. FERMI - UNIT 2 2 REVISION 9, 07/07/99l

l DISCUSSION OF CHANGES ITS: SECTION 5.4 PROCEDURES LA.3 CTS 6.8.1.h required procedures to cover the Process Control Program (PCP) implementation. ITS does not retain this I requirement. Commitments for PCP implemeritation procedures are 9 0lg relocated to the UFSAR. Prescribing these commitments within the ITS is not necessary to provide adequate protection of the public health and safety since the requirement that written procedures shall be established, implemented, and maintained commitments can be adequately controlled by 10CFR50.59. This change is consistent with NUREG 1433. TECHNICAL CHANGES - LESS RESTRICTIVE " Specific" None RELOCATED SPECIFICATIONS None i FERMI.- UNIT 2 3 REVISION 9. 07/07/99l

l Procedures 5.4 5.0 ADNINISTRATIVE CONTROLS 5.4 Procedures b.8) 5.4.1 Written procedures shall be established, implemented, and (d. 8. I maintained covering the following activities: a. The applicable procedures recommended in Regulatory (d. 8. l. Q, Guide 1.33, Revision 2, Appendix A, February 1978; b. The emergency operating procedures required to implement the /g'g,g' requirements of NUREG-0737 and to NUREG-0737, Supplement 3,. \\ as-statedin4GenericLetter82-33g i Quality assurance for effluent and environmental monitoring; fg,$/.J) c. d. Fire Protection Program implementation; and (6. 6. l.9) e. All programs specified in Specification 5.5. D g g,j) 1 (

".?"/' Li5 5.0-6 R.,

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T Programs and Manuals 1 5.5 5.5' Programs and Manuals (continued) 5.5.5 Comoonent Cyclic or Transient Limit This program provides controls to track the UFSAR Section 5.2.1.2 cyclic and transient occurrences to ensure that components are maintained within the design limits. 5.5.6 Inservice Testina and Insoection Proaram These programs provide controls for inservice testing and @l inspection of ASME Code Class 1. 2. and 3 components. The program shall include the following: a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda are as follows: ASME Boiler and Pressure Vessel Code and applicable Addenda Required Frequencies terminology for for performing inservice inservice testing and testing and inspection insoection activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days ) Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days b. The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing and inspection activities: c. The provisions of SR 3.0.3 are applicable to inservice testing and inspection activities: and d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any TS. (continued) l FERMI - UNIT 2 5.0 11 Revision 9. 07/07/99 )

n I ProgramsandMandals 5.5 5.5 Programs and Manuals-L ,5.5.7-Ventilation Filter Testina Prooram (VFTP)- (continued) Demonstrate for~each of the ESF systems that an inplace test-i of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52. Revision 2, and ASME N510-1980 at the system' flowrate specified below

• 10%.

Penetration and .ESF Ventilation System Flowrate (cfm) System Bvoass Standby Gas Treatment 3800 0.05% Control Room Emergency 1800 (makeup filter) 1.0% Filtration 3000 (recirculation filter) c. The following tests shall be performed: 1. Once per 18 months: - hl. 2. After 720 hours of system operation: 3. After any structural maintenance on the HEPA filter or charcoal adsorber housing; and 4. Following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation. Demonstrate for each of the ESF systems that a laboratory test of a sam)1e of the charcoal adsorber, when obtained as described in tegulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with AS1N D38031989 at a I temperature of 30'C and at the relative humidity specified below. ESF Ventilation System Penetration 88 Standby Gas Treatment 0.100* 70% Control Room Emergency 1.0t 70% Filtration 1 i (continued) j.' FERMI.. UNIT 2 5.0 13 Revision 9. 07/07/99

q l Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued) l d. The following tests shall be performed once per 18 months. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters (CREF only), and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52. Revision 2. and ASME N510-1980 at the system flowrate specified as follows

• 101:

Delta P Flowrate ESF Ventilation System (inches water aauae) (cfm) Standby Gas Treatment 11.0 3800 Control Room Emergency 6.0 (makeup train) 1800 l Filtration (CREF) 8.0 (recirculation 3000 train) e. The following tests shall be performed once per 18 months. Demonstrate that the heaters for each of the ESF system dissipate the value specified below when tested in accordance with ASME N510 1980: ESF Ventilation System WattaQe (kW) Standby Gas Treatment = 24 Control Room Emergency 12.0 i 2.0 Makeup Inlet Air The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies. (continued) l FERMI - UNIT 2 5.0-14 Revision 9. 07/07/99

P.' Programs and Manuals 5.5 i i 5.5 Programs and Manuals (continued) 5.5.8 ExDlosive Gas and Storace Tank Radioactivity Monitorino Prooram This program provides controls for potentially explosive gas M mixtures contained in the Main Condenser offgas treatment system. Url and the quantity of radioactivity contained in temporary outdoor storage tanks. The program shall include: a. A limit of s 4% by volume for concentration of hydrogen in j the main condenser offgas treatment system and a surveillance program to ensure the limit is maintained. b. A surveillance program to ensure that the quantity of radioactivity contained in any outdoor liquid radwaste tank that is not surrounded by liners, dikes, or walls, capable of holding the tank's contents and that does not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is s 10 curies, excluding tritium and dissolved or entrained noble gases. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies. 5.5.9 Emeroency Diesel Generator Fuel Oil Testino Prggrg An emergency diesel generator fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following: a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has: 1. an API gravity or an absolute specific gravity within

limits, 2.

a flash point and kinematic viscosity within limits for ASTM 20 fuel oil, and 3. a clear and bright appearance with proper color: (continued) l FERMI - UNIT 2 5.0 15 Revision 9, 07/07/99

o Programs and Manuals 5.5 l 5.5 Programs and Manuals 1 5.5.11 Safety Function Determination Prooram (SFDPI (continued) The SFDP identifies where a loss of safety function exists..If a loss of safety function is determined to exist by this >rogram, the appropriate Conditions and Required Actions of the _C0 in which the loss of safety function exists are required to be . entered. 5.5.12 Primary Containment Leakaoe Rate Testina Proaram a. A program shall be established to implement the leakage rate testing of the primary containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J. Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163. " Performance Based Containment Leak-Test Program," dated September, 1995, with the exception of approved exemptions to 10 CFR 50, Appendix J. b. The peak calculated containment internal pressure for the design basis loss of coolant accident, P,, is 56.5 psig. c. The maximum allowable containment leakage rate L, at P., shall be 0.5% of containment air weight per day. d. Leakage Rate acceptance criteria are: 1. Containment leakage rate acceptance criterion is s 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage [ rate acceptance criteria are s 0.60 L-for the required Type B and C tests and s 0.7$ L, for Type A tests. 2. Air lock testing acceptance' criteria are: 1) Overall air lock leakage rate is s 0.05 L, when tested at = P,. ii) For each door, leakage rate is s 5 scf per hour when the gap between the door seals is pressurized to a P,. e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Primary Containment Leakage Rate Testing Program. (continued) l l- .ll FERMI UNIT 2 5.0 18 Revision 9, 07/07/99

i i Programs and Manuals 5.5 1 5.5 Programs and Mariuals 1 5.5.12 Primary Containment Leakaoe Rate Testino Prooram (continued) l f. The provisions of SR 3.0.3 are applicable to the Primary l Containment Leakage Rate Testing Program. I 5.5.13 Hioh Density Soent Fuel Racks A program shall be provided which will assure that any } unanticipated degradation of the high density spent fuel racks will be detected and will not compromise the integrity of the sh racks. l @l l w l l I l l i l l l 1 l i I l FERMI - UNIT 2~ -5.0 19 Revision 9, 07/07/99 i j

$Pw..Nckg& g.c;- b h4 Su Spm$ cab L0) DEFINITIONS IMINIMUMCRITICALPOWERRATIO 1.22 The MINIMUM CRITICAL POWER RATIO (MCPR) shall be the smallest CPR which exists in the core. 0FF-GAS lREATMENT SYSTEM i.+.,F 1.23 An 0FF-GAS TREATMENT SYSTEM is any system designed and installed to reduce i I Mse # radioactive gaseous effluents by collecting reactor coolant cystem l offgases from the reactor coolant and providing for delay or holdup for \\ k environment. the purpose of reducing the total radioactivity prior to release to the j OFFSITE DOSF CAlt0LATION MANUAL N'I*Gy' The OFFSITE DOSE CALCULATION MANUAL (00CM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from [ 65;l.41 radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alare/ Trip Setpoints, and in the conduct of the Radiological Environmental Monitoring Program. The ODC*i shall also contain (1) the Radioactive Effluent Controls required by Section 6.8.5 and Radiological Environmental Monitoring Programs and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.g.1.7 and 6.g.1.8. ME - OPERABILITY 1.25 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform I its function (s) are also capable of performing their related support function (s). 4 OPERATIONAL CONDITION. CONDITION 1.26 An OPERATIONAL CONDITION, i.e., CONDITION, shall be any one inclusive combination of mode switch position and average reactor coolant g temperature as specified in Table 1.2. L PHYSICS TESTS S \\p 1.27 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and (1) described in Chapter 14 of the FSAR, (2) authorized under the provisions of 30 CFR 50.5g, or (3) otherwise approved by the Commission. PRESSURE B00NDARY LEAKAGE 3.28 PRESSURE BOUNDARY LEAKAGE shall be leakage through a nonisolable fault in a reactor coolant system component body, pipe wall, or vessel wall. PRIMARY _ CONTAINMENT INTEGRITY .29 PRIMARY CONTAINMENT INTEGRITY shall exist when: a. All primary containment penetrations required to be closed during accident conditions are either: 1. Capable of being closed by an OPERABLE primary containment automatic isolation system, or FERMI - UNIT 2 1-4 Agnt No. N. PAGEJ OF 24 gy9

./ TPEDF1carich) 5.$ MW0 0' 'O SURVEILLANCE RE001REMENTS (CO.I' Surveillance Requirements shall be met during the OPERATIONAL ' CONDITIONS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Each Sury'elllance Requirement.shall be performed within the specified 4.0.2 surveillance' interval with a maximum allowable extension not to exceed 25 ' percent of the specified surveillance interval. For the purpose of the sixth j \\' refueling outage, those Surveillance Requirements listed on Table 4.r.2-1 and 4.0.2-2 are extended to the data specified in the table. 4 Failure to perform a Surveillance Requirement within the allowed Q ql/ su.0.3 rveillance interval, defined by Specificatior. 4.0.2, shall constitute I noncompliance with the OPERABILITY requirenants for a Limiting Condition for Operation. The time limits of the ACTION requiremer.ts are applictble at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours to permit the completion of the surveillance when the allowable outage time lin'its of the ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on inoperable equipment. 4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unleu the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified. This provisior, shall not prevent passage through or to OPERATIONAL CONDITIONS as required to a h d h ACTION requirements. tt:9 Surveillance Requirements for inservice inspection and testing of AS I Code Class 1, 2, & 3 components shall be applicable as follows: 44,l y In w11we mapecuan or asrit ode class I, z, a a components ano inservi testing of ASME de Class I, 2, and pumps'and valves shall performed in ace dence with Sectio I of the ASME Bo11e and Pressure Ves Code and applica e Addenda as requ ed by 1 CFR 50, Section 55a(g),except re specific writt rel ef has been gran d by the commissi pursuant to 10 CF 50, iSe tion 50.55a(g)(6) 11. $,3,6,a g Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications: 4 i PAGE c2 0F 24 FERMI'- UNIT 2 3/4 0 2 Amendment No. JJ, 55, JJJ,124 reb

9PECIF(CAT 10Al 65 3 b 0'" 9' M C" A 3 3 d c mIallagwT systems (Mso Cu SpeclRcakm %4 5) SURVEf tt ANCE Rf0UIRFMFNTS (Continued) b. At least once per 18 months cr (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or j (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem by: 5 6.7.a E Verifying that the subsystem satisfies the in place penetration and bypass leakage testing acceptance criteria 5 6 '7. b of less than 0.055 and uses the test procedure guidance in ' ? Regulatory / L4,3 7 St-;

==- - "- r -r. ; - ' f ~ Guide 1.52, Revision 2. March 1978, and the system flow rate is 3800 cfm a 105. f.5/7. c A' VerifyingI.40.1., n t ) after removal that a laboratory analysis of a representative carbon sample obtained in =.-->---- m - 3 7 _ -:--;". - Regulatory P LA 3 tuide 1.52, Revision 2, March 1978, shows a methyl iodide penetration of less then 0.1005 when tested at a temperature of 30'C and at a relative humidity of 705 in accordanc+ with ASTM 03803-1989 =+ah-*4-4aeh-hneh and f.f.7. a E Verifying a subsystem flow rate of 3800 cfm a 105 during system operation when tested in accordance with ANSI N510 1980. O g'7 0 a After every 720 hours of charcoal adsorber operation by verifying riiM-M tu after removal t'nat a laboratory analysis of a M j representative carbon sample obtained ia=eceerdenes=w$4tr -_,_M.,- : =*--

• El d "egulatory Guide 1.52,. Revision 2, n

o March 1978, shows a methyl iodide per.etration of less than 0.1005 when tested at a temperature of 30'C and at a relative humidity of 705 in accordance with ASTM D3803 1989 =M * '-A N l ,K At least once per 18 months by: gg,7,f A'. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 11.0 inches water gauge while operating the filter train at a flow rate of 3800 cfm a 101. Soc hm !l Verifying that the filter train starts and isolation dampers 3.(,.y.3 open on jeach of the following} test signals: _ $ ) Manualinitiationfromthecontrolroom,and] g l {} Simulated automatic initiation signal. 33.4'1 ,M Verifying that the heaters dissipate at least 24 kW when 6'S'7,g tested in accordance with ANSI N510-1980. Verifying that the filter cooling bypass dampers can be Su S p ficekat remote manually opened and the fan can be remote manually 5.t,43 s_ tarted. 47 4 \\ppo : SR 3.o.2 h seao.s arf A/PutnacE l FERMI - UNIT 2 3/4 6 55 Amendment No.110 PAGE /0 0F 24 gg9 9

$ (/A fI CR Ti & S $ I5o $~ Q uj 8c4///71 8 F. / PLANT SYSTEMS EMERGENCY EDUfPMENT COOLING WATER SYSTEM [ A b o m p i ca h.T.'7,i ) tIMITING CONDITION FOR OPERATION 3.7.1.2 Two tideoendent emergency equipment cooling water (EECW) system subsystems shall be OPERABLE with each subsystem comprised of: N a. One OPERABLE EECW pump, and i t40M5#w An OPERxBLE flow path capable of removing heat from the associated t b. g safety-related equipment. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, 4, and 5. ACTl0N: in OPERATIONAL CONDITION 1, 2 or 3, with one EECW system subsystem a. inoperable: / N' ~ F. Within'2 1 a) Verify that all required systems, subsystems, trains l components and devices that depend upon the remaining OPERABLE EECW system subsystem are also OPERABLE, and g44. f -ll b) Verify that the AOS* is OPERABLE. Otherwise",beinatleastHOTSHUTDOW!iwithinthenext12hourg and in COLD SHUTDOWN within the following 24 hours. f Declaie the associated safety-related equipment inoperable and ( Z. take the ACTIONS required by the applicable Specifications. Sa g/ggb j 3. Restore tha inoperable EECW system subsystem to OPERABLE status within 72 hours or be in at least HOT SHUTDOWN within 3* U the next 12 hours and in COLD SHUTDOWN within the following 24

hours, b.

In OPERATIONAL CONDITION 4 or 5, determine the OPERABILITY of the safety-related equipment associated with an inoperable EECW system subsystem and take any ACTIONS required by the applicable g cations. 5 M. F' g g f A

• ADS is not required to be OPERABLE when reactor steam dome pressure is less [4,Y than or equal to 150 PSIG.

g,g 4

• Except for an inoperable Drywell Cooling Unit, required by Specification 1'

3.7.11 or an inoperable primary containment oxygen monitoring instrumentation channel, required by Specification 3.3.7.5, that depends on the remaining OPERABLE EECW system subsystem. In these cases, take the ACTION required by Specification 3.7.11 for the inoperability of both required Drywell Cooling UnitsorSpecification3.3.7.5fortheinoperabilityofbothrequiredprimaryj Leontainment oxygen monitoring instrumentation channels f l FERMI UNIT 2 3/4 7 3 Amendment No. JJ, Jp,132 PAGE

• OF 24 Rev 9

T' l $PEctFl&TtoO 0'T ADMINISTRATIVE CONTROLS j PROCEDURES AND PROGRAMS (Co 19ued) -f. DELETG [ i g,g-yi Primary Containment Leakage Rate Testing Program g, g,4 A program shall be established to implement the leakage' rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based containment Leak-Test Program," dated September 1995. 5.5,lt b The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 56.5 psig. 3,s.n..CL The maximum allowable primary containment leakage rate, L., shall be 0.5% of primary containment air weight per day at P.. 5,5 17 6 The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. 654 f The provisions of Specification 4.0.3 are applicable to the Primary Containment Leakage Rate Testing Program. t-confiourationMisk Manaaement Proar,jtrn The Confi ration Risk Management Program RMP) provides a Q procedur ized risk informed assessment o manage the risk associ ed with equipment inoperabili The program applies to g tech cal specification structures, ystems, or components for whi, a risk-informed-allowed-out e-tirne has been granted d Sr cification3.8.1.1.b.2). T program shall include the / T ilowing elements: ~ {-L Provisions for contr and implementation of a level 1 at I power, internal ev nts PRA-informed methodologyj Th assessment shall _e capable of evaluating the appl able plant configur ion. .2 - Provisions r performing an Lssessment prior o entering the100A IOR. STATEMENT for preplanned acti ties.-. 4r- ,Provisi ns,for performing.an'~ assessment a# er entering the .LCO.-A _-ION. STATEMENT for unplanned entry ,nto, the LCO ACTION STAT ENT. -t-- Pr visions for a:,sessir.g t'he need fo additional actions ter the discovery of adtir,al e ipment out of servi onditions while in the LCO-Adi0 STATEMENT. i ~ FERMI - UNIT 2 6-16b Amendment No. EJ, JpE, JJJ,119 PAGE 13 0F 24 O7

l SPEcsvntmed S S Mso su y#et i Frah%s&a% S 2 Afsb set OG ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) -5; Prov sions for considerin other applicable ris ignificant co ributions such as L el 2 PRA issues and e ernal h ents, qualitatively, or quantitativelyf f.8.6 Administrative controls shall be developed and implemented.to limit the 6 working hours of personnel who perform safety-related functions (e.g., senior reactor operators, reactor operators, auxiliary operators, health physicists, land key maintenance personnel). The controls shall include guidelines on / g kworking hours that ensure that adequate shift coverage is maintaine / gt routine heavy use of overtime for individuals. \\@ Any deviation from the working hour guidelines shall be authorized in advance by the Plant Manager or his designee, in accordance with approved administrative procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation. Controls shall be included in the procedures such that individual overtime shall be reviewed monthl/ by the Plant Manager or his designee to ensure that excessive hours have not been assigned. Routine deviation from the above guidelines shall not be authorized. I 6.9 R(PORTING RE0VIREMENTS ROUTINE REPORTS 6.9.1 In addition to the app'icable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Regional Office of the NRC unless otherwise i no,t ed. g STARTUP REPORT h'*b y6.9.1.1 A summary report of plant startup and power escalation testing shall I be submitted following (1) receipt of an Operating License, (2) amendment to the license involving a planned increase in power level, (3) installation of \\ fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit. 6.9.1.2 The startup report shall address each of the tests identified in Subsection 14.1.4.8 of the Final Safety Analysis Report and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions were required to FERMI - UNIT 2 6-16c Amendment No. JpE/U,119 PAGE 23a OF 24 Rev7

96C(F(c&T70A/ 6,f ADMINISTRATIVE CONTROLS I L14 0FFSfTE DOSE CALCUtATION MANUAL f0DCM) 1M: " - 5 M i ?' h _,,.____ i; i H -----;- ; ici

r S.r.I.6 5'**

Chan9es to the 00CM: 5.0/.6.I 4. Shall be documented and records of reviews performed shall be retained. This documentation shall contain: p ,5 M Sufficient information to support the change together with the appropriate analyses or evaluations. justifying the changes (s) and ,ji 2) A determination that the change will maintain the level of radioactive effluent control required by 30 CFR 20.1302, 40 CFR Part 190, 30 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations. 4

65. I,b.2. k.

Shall become effective after approval of the Plant Manager. l g *7* g *g'3m Shall be submitted to the Cosnission in the form of a complete. legible copy of the entire ODCM as part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented. i f Adb iTS 6 5. /I, sa fe ly beclim befemurakn Arvfran1 5m to, Baus MUmamh& '. /g i l FERMI - WIT 2 6-24 AmendmentNo.JJ,7J,7J.7J 113 PAGE d)U OF 24 ga 9

L l / DISCUSSION OF CHANGES ITS: SECTION 5.5 - PROGRAMS AND MANUALS 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 preferen.es 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 Not used. l A.3 CTS 4.0.5.d states that the performance of inservice testing and . inspection activities shall be in addition to other surveillance requiremer.ts. This CTS statement prevents the misinterpretation j that the CTS 4.0.5 requirements were in place of other 1 surveillances. The structure and application of ITS does not require this statement. It is clear from the Use and Application section of ITS that these activities do not replace other SR's, j Therefore, this is an administrative change with no impact on 4 safety. l A.4 CTS 4.0.5.b and ITS 5.5.6.a contain a table translating the calendar terms of the ASME Code to a frequency given in terms of j days. The ITS table includes a translation for the Code term i " Biennially or every 2 years." The CTS does not include this translation. The ITS translation of " Biennially or every 2 years" to be equivalent to 731 days is consistent with standard industry practice and NUREG 1433. Revision 1. 731 days also corresponds to the maximum number of days two consecutive years may contain, given only one can be a leap year. Therefore, this is an administrative change with no impact on safety. FERMI UNIT 2 1 REVISION 9. 07/07/99l

i DISCUSSION OF CHANGES ITS: SECTION 5.5 PROGRAMS AND MANUALS l A.9 ITS 5.5.11, Safety Function Determination Program provides guidance regarding the appropriate Actions to be taken when an inoperability (i.e., a support system) also results in the inoperability of one or more related systems (i.e., supported system (s)) and the actions of the supported system are not taken, as allowed by ITS LC0 3.0.6. The ITS 5.5.11 program, along with ITS LC0 3.0.6, is intended to resolve inconsistencies and ambiguities associated with inoperabilities in support / supported systems. Refer to discussions in Section 1.0 regarding incorporation of ITS LC0 3.0.6 for additional details. The BWR STS, NUREG-1433. Rev. 1, was developed, with the Industry input and approval of the NRC, to include LC0 3.0.6, and a new program, Specification 5.5.11 Safety Function Determination Program to resolve the application of LCOs to support and supported systems. Since the function of ITS 5.5.11 and LC0 3.0.6 is to clarify existing ambiguities and to maintain actions r4 l (4 consistent with previous interpretations, this is an administrative change with no impact on safety. A.10 CTS Bases for Specification 3.11.1.4 provide a detailed description of outside temporary tank." ITS 5.5.8.b includes these details within the body of the Specification. This change does not result in any technical changes (either actual or interpretational), and is therefore considered an editorial presentation preference. Therefore this change is an administrative change with no impact on safety. A.11 CTS 6.8.5 contains a list of functional systems that could have primary coolant sources outside of containment. This list contains generic system names that are being replaced with more specific Fermi-2 nomenclature. The system names provided in ITS 5.5.2 are those used in the procedures that implement this CTS requirement. Therefore, this change is administrative only. be A.12 Not used. N 4 FERMI - UNIT 2 3 REVISION 9. 07/07/99l

i DISCUSSION OF CHANGES ITS: SECTION 5.5 PROGRAMS AND MANUALS TECHNICAL CHNWiES - MORE RESTRICTIVE i M.1 ITS 5.5.10 TS Bases Control Program, is provided to specifically delineate the appropriate methods and reviews necessary for a i change to the Technical Specification Bases. The method of control of the CTS Bases is undefined. Therefore, the addition of this program represents a more restrictive change with no impact on safety. TECHNICAL CHANGES - LESS RESTRICT M Generic" ] LA.1 CTS 4.0.5.a provides references to specific 10 CFR 50 and ASME Code requirements governing performance of the Inservice Inspection (ISI) Program. The references are duplicated in 10 CFR 50.55a, which requires the implementation of ASME, Section XI and applicable addenda, for inservice inspection of ASME Code Class 1, b

2. and 3 components. These specific references are relocated from 6

the CTS and are maintained in the ISI Program. As stated above, these requirements are specified in 10 CFR 50.55a, and therefore. Q l cannot be changed by Detroit Edison, without prior approval from the NRC. This provides an equivalent level of regulatory control. Therefore, this change is a less restrictive administrative change, which has no impact on safety. LA.2 CTS 4.0.5.f includes requirements for an inservice inspection program for piping identified in Generic Letter 88 01. "NRC Position On IGSCC in BWR Austenitic Stainless Steel Piping." CTS 4.0.5 requires that this program be in accordance with the NRC staff positions on schedule, methods, personnel, and sample l expansion. Fermi 2 has committed to the NRC to implement the l requirements of Generic Letter 88 01. This program is included in the ISI NDE Program required by 10 CFR 50.55a and performed in accordance with ASME Section XI. Therefore. the inservice l inspection program for piping in CTS 4.0.5.f is in the plant l controlled ISI-NDE Program and is not repeated in the ITS. This is a less restrictive administrative change but it is acceptable because the regulations and fermi 2 commitments to the NRC contain all necessary programmatic requirements for the ISI-NDE without repeating them in the ITS. Changes to the ISI NDE Program are controlled in accordance with 10 CFR 50.55a. This relocation continues to provide adequate protection of the public health and safety because the ISI NDE program of Generic Letter 88 01 will I continue to be required by the ISI-NDE program. l l FERMI UNIT 2 4 REVISION 9, 07/07/99l

T' DISCUSSION OF CHANGES ITS: SECTION 5.5 PROGRAMS AND MANUALS l LA.3 CTS 4.6.5.3 and CTS 4.7.2.1 require surveillance tests to be l performed and also detail the methods for implementing ventilation filter testing requirements for the Standby Gas Treatment (SGT) System and Control Room Emergency Filtration (CREF) System. ) ITS 5.5.7 require surveillance test to be performed. but do not detail the methods for performing the test. This is acceptable 7 because the CTS details do not impact the requirement to perform o the surveillance test. Therefore, these details will be l *, adequately controlled in the UFSAR. which requires revisions to be g controlled by 10 CFR 50.59. This relocation continues to provide adequate protection of the public health and safety since there is no change in the requirement to perform the surveillance tests. LA.4 CTS 3.7.1.? Action a.) requires confirmatory actions to be completed within 2 hours if a single Emergency Equipment Cooling Water (EECW) subsystem is inoperable. This confirmatory action is related to determining that equipment on the opposite division of the division affected by the loss of EECW is Operable. If an opposite division component is inoperable then a prompt shutdown is required since a loss of a safety function is likely to have occurred. These actions are not explicitly required in the ITS. c> but are conceptually relocated to ITS LC0 3.0.6 and the Safety l6 Function Determination Program required by ITS 5.5.11, which are E provided to determine if a loss of a safety function has occurred W and to require the correct action to take in this event. The level of safety of facility operation is unaffected by the change and this relocation continues to provide adequate protection of the public health and safety since the requirement to determine if loss of a safety function has occurred and take appropriate action continues to be required by the Technical Specifications. LA.5 CTS 4.8.1.1.2.c and CTS 4.8.1.1.2.d require surveillance tests to be perfor.ned and also detail the standards and methods for implementing diesel fuel oil testing requirements. ITS 5.5.9 require the tests to be performed, but do not detail the specific standards and methods for performing the tests beyond the general statement of the use of ASTM standards and the use of ASTM type 2D fuel oil. These details are relocated to the Bases. This is l g-l acceptable because relocation of the details to the Bases for ITS o SR 3.8.3.3 do not impact the requirement to perform the o lg surveillance test or the appropriate acceptance criteria. [ Therefore, these details will be adequately controlled by the ITS l Bases. which require change control in accordance with ITS 5.5.10 Bases Control Program. This relocation continues to provide FERMI UNIT 2 5 REVISION 9 07/07/99l

DISCUSSION OF CHANGES ITS: SECTION 5.5 PROGRAMS AND MANUALS adequate protection of the public health and safety since there is no change in the required frequency or acceptance criteria of these tests. LA.6 CTS 3/4.11.1.4 requires maintaining the quantity of radioactive material contained in any outside temporary tanks within limits and provides specific Actions and Surveillance Requirements for maintaining this limit. ITS 5.5.8 requires the quantity to be maintained within limits, and requires an appropriate surveillance program to ensure the limits are maintained, but relocates the specific Actions and Surveillance Requirements. These requirements are relocated to the Technical Requirements Manual, which requires changes to be controlled by the provisions of 10 CFR 50.59. This is a more appropriate level of regulatory control. This relocation continues to provide adequate protection of the public health and safety since there is no change in the requirement to maintain the quantity of radioactive material within the required limits and the requirements for appropriate surveillances and actions. LA.7 CTS 3.11.2.6 establishes a maximum limit of 4% by volume for the hydrogen concentration in the main condenser offgas treatment system with actions to be taken if the limit is exceeded. In addition, CTS 4.11.2.6 establishes a requirement for the continuous monitoring of the hydrogen concentration in the main condenser offgas treatment system to ensure that the specified limit is maintained. ITS 5.5.8.a requires the 4% limit and that a surveillance program be established to ensure that the limit is maintained. The action requirements for exceeding the limit for the hydrogen concentration and the specifics of the surveillance program for ensuring the limit is maintained are relocated to the Technical Requirements Manual, which requires changes to be controlled by the provisions of 10 CFR 50.59. This is a more appropriate level of regulatory control. This relocation continues to provide adequate protection of the public health and safety since there is no change in the requirement to maintain hyorogen concentration within the required limit and the requirements for appropriate surveillances and actions. FERMI UNIT 2 6 REVISION 9. 07/07/99l

i l DISCUSSION OF CHANGES ITS: SECTION 5.5 - Pk3 GRAMS AND MANUALS 1 LA.8 CTS 5.7.1 requires components to be maintained within the cyclic or transient limits defined in CTS Table 5.7.11. ITS 5.5.5 requires that the components be maintained within the cyclic or transient limits, but does not define the specific limits or the specific components. This is acceptable because these design T details do not impact the ITS requirement to maintain the components within their limits. Therefore, these design details will be relocated to the UFSAR which requires change control in l accordance with 10 CFR 50.59. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. This relocation continues to provide adequate protection of the public health and safety since there is no change in the requirement'to maintain the components within their cyclic or transient limits. 4 LA.9 Not used. k k LA.10 CTS 6.8.5.g requires the Configuration Risk Management Program j (CRMP). This Program is relocated to the Technical Requirements b i Manual (TRM), which requires changes to be controlled by the provisions of 10 CFR 50.59. NRC SERs issuing risk informed ( l Completion Times will continue to require assessments in g accordance with the CRMP, and Technical Specifications will l continue to prescribe the necessary required actions for discovered inoperabilities. This relocation continues to provide adequate protection of the public health and safety since there is no change in the requirement to perform assessments in accordance with the CRMP. and the requirements for appropriate actions remain in the Technical Specifications. FERMI - UNIT 2 7 REVISION 9, 07/07/99l

l / 1 DISCUSSION OF CHANGES ITSi SECTION 5.5 PROGRAMS AND MANUALS LR.1 CTS 4.6.1.1.a. 3.6.1.2.b 3.6.1.2 Action b, 3.6.1.2 footnotes

• and **, 4.6.1.3.a. 4.6.1.3.b, 4.6.1.3.c.1 and 2, 4.6.1.5.1, and h

4.6.1.5.2 provide details of containment leak rate testing V./ frequencies, exceptions and exemptions, inspections. These / details are adequately addressed within ITS 5.5.12, " Containment Leakage Rate Testing Program," which requires compliance with 10 CFR 50, Appendix J Option B, as modified by approved exemptions, and which requires compliance with the guidelines of Regulatory Guide 1.163, " Performance Based Containment Leak Test Program." Any revisions to these requirements requires change I control in accordance with 10 CFR 50.92 or in accordance with the Q requirements of 10 CFR 50, Appendix J, Option B. Furthermore, d reporting details are removed from Technical Specifications since the' reporting requirements of 10 CFR 50.73 are adequate to assure the proper and prompt reporting. Therefore, since there is no change in the technical requirements, ano future revisions must also be made by Technical Specification amendment request or exengtion to the regulations, the removal of these details continues to provide adequate protection of the public health and safety. TECHNICAL CHANGES - LESS RESTRICTIE " Specific" None RELOCATED SPECIFICATIONS None FERMI - UNIT 2 8 REVISION 9 07/07/99l 1

i l l Programs and Manuals 5.5 b 5.5 Programs and Maauals (continued) 5.5. h Inservice Testino gt/,qQ Class 1, 2, and 3 co/ controls for inservice testinWof ASME Codeh Th rogra rovide program shall include the foll[owing: mponents d cl=;.; :;;: m 5"aaaS The c.3 a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda are d.0.%62-as follows: ASME Boiler and Pressure Vessel Code and applicable Addenda t u inology for Required Frequencies insarvice testing e for performing inservice activities I testinadactivities p,\\ Weekly .At least once per 7 days -T Monthly At least once per 31 days Md inSpcoktw Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every N 2 years .At least once per 731 days \\.. I b. The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing 5 Y O'S'D activities; j Th gsting activities; andisions of SR 3.0.3 are applicable to inservl L c. te A'3 { Nothing in the ASME Boder and Pressure Vessel Code shall beg.0( d. j construed to supersede the requirements of any TS. 5.5. Ventilation Filter Testino Prooran (VFTP) {testinprogranjhall be establishTd to impi dfie f;ollowing regurred l er Engineered,S(fety Feature e filter ventila n j sys at the fre ncies specifi f n [ Regulatory Gu ], e n accordane ith[RegulatoffGuide1.52,Revi n2,ApME 0-1989, and 1]. Er1SerY F, $ ' 7 } l (continued) .s BWR/4 STS 5.0-11' Rev 1, 04/07/95 Rey 9 i j

Programs and Manuals 5.5 5) 5.5 Programs and Manuals 5.5.k7 Ventilation Filter Testina Proaram (VFTP) (continued) hsed SS ~LD Demonstrate for each of the ESF systems that an inplace test of the ;".PA filters shows a penetration and system bypass

9

06}% when tested in accordance withy { Regulatory uude 1.52, Revision 2, and ASME N510-1989(~ at the system Sjoece*[/cd floitrate specified below *+ 10%}f o

d.&.S /5.b.17 pf,g t.v.s.r.3.h.3 7 ESFWetP:ti. Syn Th=ts y y,g,y,3, p y ~ ~ ~ ~ y 3 (4 7. 2. l.c,17 Im(l-f5-3 Q><* PC CH.7.1 <! c.b 7 ,e-c L 4 Y,7. 2.1, f 7 J [h5d('f' 6'I"7'b Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < J.D.05 Y when tested in accordance withe { Regulatory Spec 6/e/ Guide 1.52, Revision 2, and ASME N510-1989)"'at the system 6,/as flowrate specified below.ft 10%K O gg,g,g.5.b,f) ESF-V diiation system T h.d r<4*4 S e p

g L~insch 65 4 Q-

c. ( Demond rate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described ine j

methyl iodide [ Regulatory Guide 1.52, Revision 2}f shows the a i penetration less than the.value specified F below when tes in accordance with.fASTM D3803-1989t'"at a l temperatur f30 *07 and /07ene. 1;..r. -. muu.i m the i r(1ative umid< y specified W low. g y, c. v.3. b.2'/ ESF Mtihtis,.. S ns Pc tistivu N 4Lt s 5<3,c ) l i d,7.2./. c :2/ l yC p*) ~

>y<>C" i

(,q.7.2.1.d) l a ,l Se f A (continued) f ) BWR/4 STS 5.0-12 Rev 1, 04/07/95 h

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5 Ventilation Filter Testino Procram (VFTP) (continued) wer's Note: Allowable penetration - (100% - methyl dw offic r charcoal credited in staff sa y-ey a on]/ (safety fac Safety fac or systems w 7 for systems without hea e Demonstrate for och of the ESF systems t.. t..p)TC#p;-;fessu d. j I drop across the combined HEPA filters, the prefilters L/AS*d 6'E'j the charcoal adsorbers is less than the value specified i below when tested in accordance with'(Regulatory Guide 1.52 Revision 2, and ASME N510-198 at the system flowrate specified as follows>ft 10% K ,4,y -ESF h d 11.t 6.. Sy a - DeMa-P-r, m:t. __ ) 6/.7,2./.e,// r Zrtste4 w 5, T - 5 { h R y V h lnsed A.r-2c; Demonstrate that the heaters for each of the ESF system dissipate the value specified below [i la"]-when tested in accordancewith>(ASMEN510-198g: 7C .Eer Y =t h ti = Sg t r M tt:; - M Ys 't j < v.4 (,j! d. 57 ?f Qu) g,'7-(v ^ c"zpf,7,2.I, c,Q yc:- V ^ 5 j The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies. (DDC A.% 5.5 Exolosive Gas and Storace Tank Radioactivity Monitorino Prooram J.fl J.6 > This program provides cont'ols for potentially explosive g g '. mixtures contained in thef; te Gas H @ STstemT, [L " quant y of /ad Wactivity contained gas stor e tan V or fed-to th IdC4Se f fgas tfe'a w d system, and the quanIny of rauicactivity 4, 3, sf. /.@ contained 1 r;.tect" outdoor.14<pttd-storage tanks 3f p \\ te;+porary (continued) BWR/4 STS 5.0-13 Rev 1, 04/07/95 Rev%

Programs and Manuals 5.5 l' Insert 5.5 2C The following tests shall be performed once per 18 months. Insert 5.5 5 ESF Ventilation System Delta P (inches water cauce) Flowrate (cfm) l Standby Gas Treatment 11.0 3800 Control Room Emergency 6.0 (makeup train) 1800 Filtration (CREF) 8.0 (recirculation train) 3000 Insert 5.5 6 ESF Ventilation System Wattaae (kW) Standby Gas Treatment 2 24 Control Room Emergency Makeup 12.0

• 2.0 Inlet Air i

i FERMI - UNIT 2 Page 5.0-13 (Insert) REVISION 9. 07/07/99l l

Programs and Aanuals 5.5 b 5.5 Programs and Manuals 5.5.)t II Safety' Function Determination Proaram (SFDP) (continued) DOCAe9 2.Ar" A required system redundant to system (s) in turn supported by the inoperable supported system is also inoperable; or 3r A required system redundant to support system (s) for the supported systems (a) and (b) above is also inoperable. The SFDP identifies where a loss of safety function exists. If a loss of safety function is detemined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. h.\\ rise rf Sr [ ~~ ] g Insert fr5 -/o) O'8'E O l T m ~d i k BWR/4 STS 5.0-17 Rev 1, 04/07/95 gEy 9

1 ) / Programs and Manu'als 5.5 Insert 5.5 11 g ~ Ge << Removed in Rev 8 >> j i FERMI - UNIT 2 Page 5.0-17(3) (Insert) REVISION 9. 07/07/99l

] n: 1 JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 l ITS: SECTION 5.5 PROGRAMS AND MANUALS l NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NlREG 1433 to reflect Fermi 2 current l l licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. Refer to CTS Discussion Of Changes to the related requirement for_ a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. P.2 Not used. P.3 Not used. P.4 Vent lation Filter Testing Program, is modified to include a det' d description of the required SR Frequencies to improve cla. ,y and to facilitate use by the plant staff. This change pr< des additional detail and is intended to improve clarity and ensu,e the requirement is fully understood and consistently applied. There are no technical changes to requirements as specified in NUREG 1433. Revision 1: therefore, this change is not a significant or generic deviation from NUREG-1433. i P.5 Change made for editorial preference or clarity. For example, j Fermi 2 CTS addresses only single unit reporting requirements. Therefore the NUREG 1433 wording applicable to dual unit sites is eliminated. i GEEERIC_CilEiES C.1 TSTF-106: NRC approved change to NUREG 1433. C.2-TSTF-118: NRC approved change to NUREG 1433. C.3 TSTF 279: NRC approved change to NUREG 1433. C/ l FERMI - UNIT 2 1 REVISION 9, 07/07/99l

F DISCUSSION OF CHANGES L' ITS: SECTION 5.6 - REPORTING REQUIREMENTS l' l ' TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES - LESS RESTRICTIVE- Generic" LA.1 CTS 6.9.1.1. 6.9.1'.2 and 6.9.1.3 detail specific reporting l requirements for the Startup Report. This requirement is being relocated to the TRM which requires revisions to be controlled by l 10 CFR 50.59. The startup report provides the NRC a means to review the appropriateness of licensee activities after the fact. l but provides no regulatory authority or approval. This detail is 1 not required by 10 CFR 50.36 for inclusion into the Administrative Controls section of the TS. Since the report performs no compensatory or mitigative functions the Technical Specification requirement for its submittal is not required to ensure adequate protection of the public health'and safety. The relocation of this information maintains the consistency with NUREG 1433. LR.1 CTS 6.9.1.5.c and 6.9.1.5.d require submission of reports covering ECCS o' tage data and results of primary coolant specific activity u analyses when it has exceed its limit. ITS does not contain this requirement. The requirements for submission of these reports are removed from Technical Specifications. These reports involve no -regulatory authority or approval. This Technical Specification detail is not required by 10 CFR 50.36 for inclusion into the Administrative Controls Section. Regulatory control of changes to these requirements (e.g., Technical Specification amendment or 10 ' CFR 50.59) is not necessary to provide adequate protection of the public health and safety since the reports perform no compensatory or mitigative functions and are not required to ensure adequate protection of the public health and safety. For fuel cladding failures that exceed the reporting guidelines of 10 CFR 50.73. appropriate reporting.is required. The removal of this i informution maintains the consistency with NUREG 1433. k FERMI . UNIT 2 2 REVISION 9. 07/07/99l ~ l 1

l INSERT THIS PAGE IN FRONT OF VOLUME 11

Volume 11i CTS MARKUP.COMPILATIONi 4

Remove Replace 1-4 (5.5 CTS M/U) pg 1 of 24 14 (5.5 CTS M/U) pg i of 24 Rev 9 3/4 0-1 (2)(3.0 CTS M/U) pg 3 of 12 Rev 0 3/4 0-1 (2)(3.0 CTS M/U) pg 3 of 12 Rev 9 3/4 0-2 (5.5 CTS M/U) pg 2 of 24 3/4 0-2 (5.5 CTS M/U) pg 2 of 24 Rev 9 3/4 6-55 (5.5 CTS M/U) pg 10 of 24 3/4 6-55 (5.5 CTS M/U) pg 10 of 24 Rev 9 3/4 7-3 (5.5 CTS M/U) pg 12 of 24 3/4 7-3 (5.5 CTS M/U) pg 12 of 24 Rev 9 6-16b (5.5 CTS M/U) pg 23 of 24 6-16b (5.5 CTS M/U) pg 23 of 24 Rev 9 6-16c (5.5 CTS M/U) pg 23a of 24 6-16e (5.5 CTS M/U) pg 23a of 24 Rev 9 6-24 (5.5 CTS M/U) pg 24 of 24 6-24 (5.5 CTS M/U) pg 24 of 24 Rev 9 l Rev9 07/07/99 i

0 $ pea Fuaw S.cr S C#$ cab Ed 5 P DEF1NfT10NS MINIMUM CRITICAL POWER RATIO 1.22 1he MINIMUM CRITICAL POWER RATIO (MCPR) shall be the smallest CPR which exists in the core. j OFF-CAS TREATMENT SYSTEM lg.cpFI1.23 6 An OFF-GAS TREATMENT SYSTEM is any system designed and installed to reduce i radioactive gaseous effluents by collecting reactor coolant system 5' 10 offgases from the reactor coolant and providing for delay or holdup for \\ ( environment. the purpose of reducing the total radioactivity prior to release to the OFFSITE DDSE CALCULATION MANUAL W' y -The OFFSITE DOSE CALCULATION MANUAL (DDCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from 6 5 l AL radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring AlarWTrip Setpoint;, and in the conduct of the Radiological Environmental Monitoring Program. The ODCM shall also contain (1) the Radioactive E? fluent Controis required by Section 6.8.5 l and Radiological Environmental Monitoring Programs and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.9.1.7 and 6.9.1.8. OPERABLE - OPERABILTTY 1.25 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystes, train, component or device to perform its function (s) are also capable of performing their related support function (s). OPERATIONAL CONDITION - CONDIT10N 1.26 An OPERATIONAL CONDITION, i.e., CONDITION, shall be any one inclusive combination of mode switch position and average reactor coolant p temperature as specified in Table 1.2. + L PHYSICS TESTS c[\\p 1.27 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and (1) described in Chapter 14 of the FSAR, (2) authorized under the provisions of 10 CFR 50.59, or (3) otherwise approved by the Cosnission, j PRESSURE BOUNDARY LEAKAGE 1.28 PRESSURE BOUNDARY LEAKAGE shall be leakage through a nonisolable fault in a reactor coolant system component body, pipe wall, or vessel wall. PRIMARLCORIAINMENLINIEGRITY 1.29 PRIMARY CONTAINMENT INTEGRITY shall exist when: a. All primary containment penetrations required to be closed during accident conditions are either: 1. Capable of being closed by an OPERABLE primary containment automatic isolation system, or FERMI - UNIT 2 1-4 Amendment No. A!, 113 PAGE_ l OF M y

Specification 3.0 l INSERT 3.0 4 When an LC0 is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. Exceptions to this Specification are stated in the individual 7 Specifications. lg i LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2. and 3. INSERT 3.0 5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LC0 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. FERMI UNIT 2 Page 3/4 (2) RV ION 9. 07/07/99 l L

) / TPET.lF10ry0s) 5 T 0 M S"f SURVEftLANCE REOUTREMENTS /CD.I' Surysillance Requirements shall be met during the OPERATIONAL CONDITIONS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. 4.0.2 Each surveillance Requirement -shall be performed within the specified surveillance' interval with a maximum allowable extension not to exceed 25 percent of the specificd surveillance interval. For the purpose of the sixth j l \\' refueling outage, those Surveillance Requirements listed on Table 4.0.2-1 and i t[ 4.0.2-2 are extended to the date specified in the table. /su.0.3 Failure to perform a Surveillance Requirement within the allowed 4 9i rveillance interval, defined by Specification 4.0.2, shall constitute ' noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours to permis the completion of the surveillance when the allowable outage time lin'its of the i ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on inoperable equipment. 4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified. This provision bshall not prevent passage through or to OPERATIONAL CONDITIONS as required to a=alv H th ACTION requirements. +:t':S Surveillance Requirements for inservice inspection and testing of AS I Code Class 1, 2, & 3 components shall be applicable as follows: L A,l [ $um vice maprLL1Dn of MMt'. ode Class 1, Z, a J component.s anu I inservi testing of ASME de Class I, 2, and pumps and valves shall perfomed in ace dance with Sectio I of the ASME Bolle and Pressure Ves 1 Code and applica e Addenda as requ ed by I CFR 50, Section .55a(g),except re specific writt rel ef hss been gran d by the Commissi pursuant to 10 CF 50, i'Se tion 50.55a(g)(6) 1). / 5gG,a,M Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications: PAGE c2 0F 24 FERMI - UNIT 2 3/4 0-2 Amendment No. JJ, S. JN.124 PJNk

l 9PectFicAT70Al E.5 3' CONTAll#1ENT SYSTEMS hiso GL %ifiMhh %4 5 b SURVEILLANCE REQUIREMENTS (Continued) b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the subsystem by: 5 5.7.a E Verifying that the subsystem satisfies the in-place penetration and bypass leakage testing acceptance criteria 6'6,7 b of less than 0.055 and uses the test procedure guidance in ~ ' ? Regulatory / LS,3 "-- S t_.. ". m = f "_e. f " :. Guide 1.52. Revision 2, March 1978, and the system flow rate is 3800 cfm a 105. f.5,7. c <C VerifyingI.m.;. M 4.) after removal that a laboratory I analysis of a representative carbon sample obtained in tc ' -- 'th ":; i ":-j " -U- - ~l - f Regulatory p LA 3 Guide 1.52, Revision 2. March 1978, shows a methyl iodide 1 penetration of less then 0.100% when tested at a temperature of 30'C and at a relative humidity of 705 in accordance with ASTM D3803-1989 wMh-*4-4neh-tmh and i i f,f,7. a A Verifying a subsystem flow rate of 3800 cfm : 105 during system operation when tested in accordance with ANSI N510-1980. After every 720 hours of charcoal adsorber operation by verifying 6 'g *7 C.,e W after removal that a laboratory analysis of a I O'3 representative carbon sample obtained ia=ecoordenes=estter " ; M^n "="'- * ' t s' ":;:latory Guide 1.52,. Revision 2, h . March.1978, shows a methyl iodide penetration of less than 0.1005 when tested at a temperature of 30'C and at a relative humidity of 70E in accordance with ASTM 03803-1989 - t j ,K At least once per 18 months by: g,y,gJ .4. Verifying that the pressure drop across the combined HEPA filters and charcoal adserber banks is less than 11.0 inches water gauge while operating the filter train at a flow rate of 3800 cfm a 101. !lf. Verifying that the filter train starts and isolation dampers S&ct hm open on pach of the following} test signals: 3.c.y.3 pec;Oca hm - ~ [) Su Manual initiation from the control room, and] i{} Simulated automatic initiation signal. 33 M 2 verirrin9 that the heaters dissio te at 1==st 25 kw whea ?"*g*7.e tested in accordance with ANSI H510-1980. Verifying that the filter cooling bypass dampers can be Su S pcAReak.n remote manually opened and the fan can be remete manually 3.c.+3 started. A.7 / Sg 3.o.2 kse1o.3Aa6NPiaws 4 \\g pg. 3/4 6 55 Amendment No.110 FERMI - UNIT 2 PAGE /0 0F 24 ggy 9

r l SPFMicamu 55 M5o Sepec/8ca/-/m.f f. /) PLANT SYSTEMS l EMEpGENCY EOUTPMENT C00tlNG WATtR SYSTEM [ kl50 h S/dcJded Nex.3'7. 1IMITING CONDITION FOR OPERATION Two independent emergency equipment cooling water (EECW) system 3.7.1.2 subsystems shall be OPERABLE with each subsystem comprised of: M a. One OPERABLE EECW pump, and Qechcahrw An OPERABLE flow path capable of removing heat from the associated j b. g.7~ 7 safety related equipment. ADPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, 4, and 5. ACIl0N: In OPE 2ATIONAL CONDITION 1, 2 or 3, with one EECW system subsystem a. inoperable: y l ~ M F. Within 2 i a) Verify that all required systems, subsystems, trains components and devices that depend upon the remaining i OPERABLE EECW system subsystem are also OPERABLE, and pg g'" -f b) Verify that the ADS

• is OPERABLE.

Otherwise", be in at least HOT SHUTDOWii within the next 12 hours,j i Qnd in COLD SHUTDOWN within the following 24 hours. f Declare the associated safety related equipment inoperable and f z. } take the ACTIONS required by the applicable Specifications. 5a Restore the inoperable EECW system subsystem to OPERABLE g/g;gh ) 3. status within 72 hours or be in at least HOT SHUTOOWN within 30'1 the next 12 hours and in COLD SHUTDOWN within the following 24

hours, b.

In OPERATIONAL CONDITION 4 or 5, determine the OPERABILITY of the safety-related equipment associated with an inoperable EECW system subsystem and take any ACTIONS required by the applicable g ications, s o. r g gd Q

• ADS is not required to be OPERABLE when reactor steam dome pressure is less [4, Y than or equal to 150 PSIG.

g,g

• • Except for an inoperable Drywell Cooling Unit, required by Specification 1

8 3.7.11 or an inoperable primary containment oxygen monitoring instrumentation channel, required by Specification 3.3.7.5, that depends on the remaining OPERABLE EECW system suesystem. In these cases, take the ACTION required by Specification 3.7.11 for the inoperability of both required Drywell Cooling (Units or Specification 3.3.7.5 for the inoperability of both required [ containment oxygen monitoring instrumentation channels f - FERMI - UNIT 2 3/4 7-3 Amendment No. JJ, Ep.132 PAGE

• OF 24 Rev9

$PEc.tVICkTlod 05 ADMINISTRATIVE CONTROLS I PROCEDURES AND PROGRAMS (Co nued) f. cELET= 4,/ g,7, g Primary Containment Leakage Rate Testing Program p,g,g,4 A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 f CFR 50, Appendix J, Option B as modified by approved exemptions. This program shall be in accordance with the guidelines contained { in Regulatory Guide 1.163, ' Performance-Based containment Leak-Test Program," dated September 1995. 6.5.q,, b The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 56.5 psig. g

,s, n., c.

The maximum allowable primary containment leakage rate, L., shall be 0.5% of primary containment air weight per day at P., S.L G d The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program. - 6 5.G. f The provisions of Specification 4.0.3 are applicable to the Primary Containment Leakage Rate Testing Program. LonfiourationMisk ManEG;;; At-Procram The Conf ( ration Risk Management Program RMP) provides a Q I procedur ized risk informed assessment o manage the risk associ ed with equipment inoperabili The program applies to g tech cal specification structures, ystems, or components for whi a risk-informed allowed-out e-time has been granted 4 (S cification 3.8.1.1.b.2). T program shall include the / E f Ilowing elements: L Provisions for contr and implementation of a level 1 at power, internal ev nts PRA-informed methodologyj Th a.ssessment shall. e capable of evaluating the appli able plant configur ion. 2_ Provisions r performing an assessment prior.o entering the.T.C0 A 10tL STATEMENT for preplanned acti ties. 2. ,Provisi ns.for performing an assessment af er entering the . LCO-A ION STATEMENT for unplanned entry nto the LC0 ACTION STAT ENT. t Pr visions for assessing,the need for additional actions ter the discovery of additional e ipment out of servi onditions while in the LCO ACTION STATEMENT. i ~ FERMI - UNIT 2 6-16b Amendment No. E2, JpS, JJJ,119 PAGE 23 0F 24 O7

$f6 C LT'K/ mod be I Mso ses 56h S 2-ADMINISTRATIVE CONTROLS 4f6D 64 p2ce.J - a#su EG PROCEDURES AND PROGRAMS (Continued) (-5. Prov sions for considerin other applicable ris ignificant co ributions such as L el 2 PRA issues and ernal h ents, qualitatively, or quantitativelyf j l /.8.6 Administrative controls shall be developed and implemented to limit the 6 working hours of personnel who perform safety-related functions (e.g., senior reactor operators, reactor operators, auxiliary operators, health physicists, and key maintenance personnel). The controls shall include gu!delines on / tf- \\w rking hours that ensure that adequate shift coverage is maintained without 5 / pk routine heavy use of overtime for individuals. 51 Any deviation from the working hour guidelines shall be authori7ed in advance by the Plant Manager or his designee, in accordance with approvo' administrative procedures, or by higher levels of manag~ement, in accordance with established procedures and with documentation of the basis for grp.nting the deviation. Controls shall be included in the procedures such that-individual overtime shall be reviewed monthly by the Plant Manager or his designee to ensure that excessive hours have not been assigned. Routine deviation from the above guidelines shall not be authorized. '69 REPORTING RE0VIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Regional Office of the NRC unless otherwise noted. STARTUP REPORT b \\ 6.9.1.1 A summary report of plant startup and power escalation testing shall 5h be submitted following (1) receipt of an Operating License, (2) amendment to the license involving a planned increase in power level, (3) installation of \\ fuel that has a different design or has been manufectured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydrculic performance of the unit. 6.9.1.2 The startup report shall addre:s each of the tests identified in Subsection 14.1.4.8 of the final Safety Analysis Report and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions were required to FERMI - UNIT 2 6-16c Amendment No. JpM13,119 PAGE 23a 0F 2h Rev7

l SPECIF(C&Ttobl 5 5 ADMINISTRATIVE CONTPOL5 l 6.14 0FFSITE DOSE CALCULATION MANUAL (ODCtil 2M' "- 99 " t" h 1;;. _ _ __ by i' ^ = : -/ ici f.T./.6 6d+.+ Changes to the ODCH: 5.r./.6./4. - thall be documented and records of reviews performed shall be [ retained. This documentation shall contain: / ,M~ Sufficient information to support the change together with the appropriate analyses or evaluations justifying the changes (s) and M 4) A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.10?, 40 4 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of eff' vent, dose, or setpoint esiculations. 4 O. l. b.2. &. Shall become effective after approval of the Plant Manager. l g *g. g 'g,3.e. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as part of or concurrent with the Annual Radio:ctive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was taplemented. Add-lTS 6 5./l, sa4/y Gelie befaminah 9 Program fk.k'./7T 5.5.l0, Bam M Us7so?" h & \\ FERMI - UNIT 2 6-24 Amendment No. JJ, JJ M, N 113 PAGE d)O OF 24 ggy cf

E t I / INSERT TIIIS PAGE IN FRONT OF VOLUME 12 i 1

Volume 12: IMPROVED TECHNICAL SPECIFICATIONS.

Remove Replace 5.4 ITS p[5.0-6 Rev 0 5.4 ITS pg 5.0-6 Rev 9 5.5 ITS pg 5.0-11 Rev 0 5.5 ITS pg 5.0-11 Rev 9 5.5 frS pg 5.0-13 Rev 0 5.5 ITS pg 5.0-13 Rev 9 5.5 TTS pg 5.0-14 Rev 0 5.5 ITS pg 5.0-14 Rev 9 5.5 ITS pg 5.0-15 Rev 0 5.5 ITS pg 5.0-15 Rev 9 5.5 ITS pg 5.0-18 Rev 0 5.5 ITS pg 5.0-18 Rev 9 5.5 ITS pg 5.0-19 Rev 2 5.5 ITS pg 5.0-19 Rev 9 l i Rev 9 07/07/99 i

g 1 i Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities: a. The applicable procedures recommended in Regulatory Guide 1.33. Revision 2, Appendix A, February 1978: 3* b. The emergency operating procedures required to implement the requirements of NUREG 0737 and to NUREG 0737. Supplement 1. I as stated in Generic Letter 82 33: c. Quality assurance for effluent and environmental monitoring: d. Fire Protection Program implementation; and e. All programs specified in Specification 5.5. I l FERMI UNIT 2 5.-06 Revision 9 07/07/99-l l

( r l Programs and Manuals 5.5 l 5.5 Programs and Manuals (continued) 5.5.5 Comoonent Cyclic or Transient Lin., l This program provides controls to track the UFSAR Section 5.2.1.2 cyclic and transient occurrences to ensure that components are maintained within the design limits. 5.5.6 Inservice Testino and Insoection Proaram These programs provide controls for inservice testing and fj inspection of ASME Code Class 1. 2. and 3 components. The program shall include the following: a. Testing frequencies specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda are as follows: ASME Boiler and Pressure i Vessel Code and applicable Addenda Required Frequencies terminology for for performing inservice inservice testing and testing and inspection insoection activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 morths At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days b. The provisions of SR 3.0.2 are applicable to the above required Frequencies for performing inservice testing and inspection activities: c. The provisions of SR 3.0.3 are applicable to inservice testing and inspection activities; and d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any TS. (continued) l FERMI UNIT 2 5.0 11 Revision 9. 07/07/99 i

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Progi ams and Manuals 5.5 1 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testina Procram (VFTP) (continued) Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < specified below when tested in accordance with Regulatory Guide 1.52. Revision 2, and ASME N510 1980 at the system flowrate specified below i 10%. Penetration and ESF Ventilation System Flowrate (cfm) System Byoass Standby Gas Treatment 3800 0.05t Control Room Emergency 1800 (makeup filter) 1.0% Filtration 3000 (recirculation filter) c. The following tests shall be performed: 1. Once per 18 months: .Bl C 2. ^rter 72o hours or srste oper t4oa: 3. After any structural maintenance on the HEPA filter or charcoal adsorber housing; and 4. Following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52 Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30*C and at the relative humidity specified below. ESF Ventilation System Penetration R_H Standby Gas Treatment 0.100t 70t i Control Room Emergency 1.0% 70% Filtration (continued) ! FERMI - UNIT 2 5.0 13 Revision 9. 07/07/99

i Programs and Manuals l 5.5 l l 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued) i d. The following tests shall be performed once per 18 months. 0A l oemonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters (CREF only), and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52. Revision 2 and ASME N5101980 at the system l flowrate specified as follows i 10%: Delta P Flowrate ESF Ventilation System (inches water cauael (cfm) l Standby Gas Treatment 11.0 3800 Control Room Emergency 6.0 (makeup train) 1800 l Filtration (CREF) 8.0 (recirculation 3000 train) I e. The following tests shall be performed once per 18 months. Demonstrate that the heaters for each of the ESF system dissipate the value specified below when tested in L accordance with ASME N510 1980: j ESF Ventilation System Wattaae (kW) Standby Gas Treatment a 24 Control Room Emergency 12.0 i 2.0 Makeup Inlet Air The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies. l (continted) l FERMI UNIT-2 5.0-14 Revision 9. 07/07/99

1 l Programs and Manuals l 5.5 5.E' Programs and Manuals (continued) 5.5.8 Exolosive Gas and Storaae Tank Radioactivity Monitorina Procram This program provides controls for potentially explosive gas l mixtures contained in the Main Condenser offgas treatment system, and the quantity of radioactivity contained in temporary outdoor storage tanks. The program shall include: a. A limit of 5 4% by volume for concentration of hydrogen in l' the main condenser offgas treatment system and a surveillance program to ensure the limit is maintained, b. A surveillance program to ensure that the quantity of radioactivity contained in any outdoor liquid radwaste tank that is not surrounded by liners, dikes, or walls. capable of holding the tank's contents and that does not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is s 10 curies, excluding tritium and dissolved or entrained noble gases. The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies. 5.5.9-Emeroency Diesel Generator Fuel Oil Testina Proaram An emergency diesel generator fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASIN Standards. The purpose of the program is to estaulish the following: a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has: 1. an API gravity or an absolute specific gravity within

limits, j

2. a flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and 3. a clear and bright appearance with proper color: (continued) l FERMI - UNIT 2 5.0 15 Revision 9. 07/07/99 i I

l / 1 Programs and Manuals l c-5.5 u 5.5 Programs and Manuals 5.5.11 Safety Function Determination Proaram (SFDP) (continued) The SFDP identifies where a loss of safety function exists. If a j loss of safety function is determined to exist by this program. the appropriate Conditions and Required Actions of the LC0 in which the loss of safety function exists are required to be entered. l 5.5.12 Primary Containment Leakaae Rate Testina Prcqritm a. A program shall be established to implement the leakage rate testing of the primary containment as required by 10 CFR ' 50.54(o) and 10 CFR 50. Appendix J. Option B. as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163. " Performance Based Containment Leak Test Program." dated September 1995, with the exception of approved exemptions to 10 CFR 50. Appendix J. b. The peak calculated containment internal pressure for the design basis loss of coolant accident. P,. is 56.5 psig. c. The maximum allowable containment leakage rate L, at P,. shall be 0.5% of containment air weight per day d. Leakage Rate acceptance criteria are: '1. Containment leakage rate acceptance criterion is s 1.0 L,. During the first unit startup following l testing in accordance with this program, the leakage j rate acceptance criteria are 5 0.60 L for the required Type B and C tests and s 0.7$ L, for Type A tests. 2. Air lock testing acceptance criteria are: i) Overall air lock leakage rate is s 0.05 L, when tested at a P,. ii) For each door, leakage rate is s 5 scf per hour when the gap between the door seals is-pressurized to a P,. e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Primary Containment Leakage Rate Testing Program. (continued) i FERMI UNIT 2. 5.0 18 Revision 9. 07/07/99-t

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakaae Rate Testina Proaram (continued) f. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program. 5.5.13 Hiah Density Scent Fuel Racks A program shall be provided which will assure that any } unanticipated degradation of the high density spent fuel racks will be detected and will not compromise the integrity of the -D racks. $l e4 l [ FERMI - UNIT 2 5.0 19 Revision 9. 07/07/99 i I L

I l l l INSERT THIS PAGE IN FRONT OF VOLUME 13 ' Volume 13: IMPROVED TECHNICAL SPECIFICATIONS BASES Remove Replace B 3.0 ITS pg B 3.0-5 Rev 0 B 3.0ITS pg B 3.0-5 Rev 9 l Rev 9 07/07/99

LC0 Applicability B 3.0 BASES LCO 3.0.3 (continued) ACTIONS of individal Specifications sufficiently define the remedial measures to be taken. l Exceptions to LC0 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3. would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in /yl LC0 3.7.7. " Spent Fuel Storage Pool Water Level." LC0 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LC0 can be applicable in any or all MODES. If the LC0 and the Required Actions of LC0 3.7.7 are not met while in [j MODE 1, 2. or 3. there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required /l Action of LC0 3.7.7 of " Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the j actions of LC0 3.0.3. These exceptions are addressed in the individual Specifications. LC0 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or I other specified conditions in the A>plicability when an LC0 is not met. It precludes placing t1e unit in a MODE or other specified condition stated in that Applicability (e.g., Applicability desired to be entered) when the following exist: a. Unit conditions are such that the renuirements of the LC0 would not be met in the Applicab desired to be et#tered; and 1 ? b. Continued noncompliance with the LC0 requirements, if the Applicability were entered, would result in the unit being required to exit the Applicability desired to be entered to comply with the Required Actions. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to tne status of the unit before or after the MODE change. Therefore, in such cases. entry into a MODE or other specified condition in the Applicability may be made l FERMI - UNIT 2 B -3.0 - 5 Revision 9. 07/07/99}}