ML20212H504
| ML20212H504 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/02/1999 |
| From: | DETROIT EDISON CO. |
| To: | |
| Shared Package | |
| ML20195G136 | List: |
| References | |
| NUDOCS 9906150242 | |
| Download: ML20212H504 (250) | |
Text
{{#Wiki_filter:. l 1 l l l ATTACHMENT 3 TO NRC-99-0046 INSERT AND REMOVAL SHEETS 9906150242 990602 PDR ADOCK 05000341 P PDR ,,.
i INSERT THIS PAGE IN FRONT OF VOLUME 2 l 1 1 Volume 2: SECTION 1.0 Remove Replace 1.1 ITS pg 1.1-1 Rev 0 1.1 ITS pg 1.1-1 Rev 6 1.1 ITS pg 1.1-2 Rev 0 1.1 ITS pg 1.1-2 Rev 6 1.1 ITS pg 1.1-4 Rev 0 1.1 ITS pg 1.1-4 Rev 6 1.1 ITS pg 1.1-5 Rev 0 1.1 ITS pg 1.1-5 Rev 6 1.0 CTS M/U (3/41-1) pg 1 of 14 1.0 CTS M/U (3/41-1) pg 1 of 14 Rev 6 1.0 CTS M/U (3/41-2a) pg 4 of 14 1.0 CTS M/U (3/41-2a) pg 4 of 14 Rev 6 1.0 CTS M/U (3/41-3) pg , of 14 1.0 CTS M/U (3/41-3) pg 5 of 14 Rev 6 1.0 CTS M/U (3/41-4) pg 6 of 14 1.0 CTS M/U (3/41-4) pg 6 of 14 R.-v 6 1 1.0 CTS M/U (3/41-5) pg 7 of 14 1.0 CTS M/U (3/41-5) pg 7 of 14 Rev 6 l 1.0 DOCS pg i Rev 0 1.0 DOCS pg i Rev 6 I 1.0 DOCS pg 2 Rev 0 - 1.0 DOCS pg 2 Rev 6 I l 1.0 DOCS pg 3 Rev 0 1.0 DOCS pg 3 Rev 6 1.0 DOCS pg 4 Rev 0 1.0 DOCS pg 4 Rev 6 1.0 DOCS pg 5 Rev 0 1.0 DOCS pg 5 Rev 6 , 1.0 DOCS pg 6 Rev 0 1.0 DOCS pg 6 Rev 6 1 1.0 DOCS pg 7 Rev 0 1.0 DOCS pg 7 Rev 6 1.0 DOCS pg 8 Rev 0 1.0 DOCS pg 8 Rev 0 l 1.0 DOCS pg 9 Rev 0 1.0 DOCS pg 9 Rev 0 l.0 DOCS pg 10 Rev 0 1.0 DOCS pg 10 Rev 0 1.0 DOCS pg i l' Rev 0 't.0 DOCS pg ii Rev 0 1.1 NUREG M/U pg 1.1-1 1.1 NUREG M/U pg 1.1-1 Rev 6 l 1.1 NUREG M/U pg 1.1-2 1.1 NUREG M/U pg 1.1-2 1.1 NUREG M/U pg 1.1-5 1.1.NUREG M/U pg 1.1-5 1.0 JFD's pg i Rev 0 1.0 JFD's pg 1 Rev 6 l l l l l Rev 6 05/28/99
1 l Definitions I 1.1 1.0 USE AND APPLICATION 1.1 Definitions
.....................................N0TE --- --- - --- ---------- ----- l The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
Term Definition ACTIONS ACTIONS shall be that part of a Specification that I prescribes Required Actions to be taken under designated Conditions within specified Completion Times. AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a .mecific HEAT GENERATION RATE planar height and is equal to the surn of the (APLHGR) LHGRs for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height. CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the )arameter that the channel monitors. A CHANNEL CA.IBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. A CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total pl channel steps. l (continited) l FERMI - UNIT 2 1.1 1 Revision 6 05/28/99
Definitions 1.1 1.1 ~ Definitions (continued) CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter. J CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify , OPERABILITY of all devices in the channel required for channel OPERABILITY. A CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so j
)
{ that the entire channel is tested. j 1 CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, j sources, or reactivity control components, within the reactor vessel with the vessel head < removed and fuel in the vessel. The following l exceptions are not considered to be CORE ALTERATIONS:
- a. Movement (including replacement) of source range monitors, local power range monitors.
l intermediate range monitors, traversing incore probes, or special movable detectors: and
- b. Control rod movement provided there are no fuel assemblies in the associated core cell.
Suspension of CORE ALTERATIONS shall not preclude i completion of movement of a component.to a safe l position. 1 (continued) l FERMI - UNIT 2 '1.1 2 Revision 6. 05/28/99
Definitions 1.1 1.1 Definitions (continued) LEAKAGE LEAKAGE shall be:
- a. Identified LEAKAGE
- 1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank: or
- 2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE:
- b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE:
- c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE:
- d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.
LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per RATE (LHGR) unit length of fuel rod. It is the integral of the heat flux over the heat transfer area
- associated with the unit length.
LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test [l TEST _of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including. the actuated device, to verify 0PERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested. 1
) (continued) ;
I FERMI UNIT 2 1.1 4 Revision 6. 05/28/99
Definitions 1.1 1.1 Definitions (continued) > Oj{ j MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each type of fuel. The CPR is that power in the assembly that is calculated by application of the a)propriate correlation (s) to cause some point in tie assembly to experience boiling transition, divided by the actual assembly operating power. MODE A MODE shall correspond to any one inclusive j combination of mode switch position, average j reactor coolant temperature, and reactor vessel i head closure bolt tensioning specified in ' Table 1.1 1 with fuel in the reactor vessel. OPERABLE - 0PERABILITY' A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of Jerforming its specified safety function (s) and w1en all necessary attendant instrumentation, controls, nornial or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or devige to perform its specified safety function (s) are also capable of performing their.related support function (s). PHYSICS TESTS PHYSICS TESTS shall be those tests performed to
- measure the fundamental nuclear characteristics of the reactor cor~e and related instrumentatinn.
These tests are:
- a. Described in Chapter 14. Initial Test Program of the UFSAR:
- b. Authorized under the provisions of 10 CFR 50.59; or
- c. Otherwise approved by the Nuclear Regulatory Commission.
(continued) l FERMI UNIT 2 1.1 5 Revision 6. 05/28/99 i
1 Sgtc\4 ec, w :.o 0 pj
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A.I e I. I Me (%-,p w ud,n -- 4 + DEFINITIONS
# 1 a.p .tetion vi dese The-fel h ing te m: :r: d: fined se ih.i un'Te m ir.
g :!::ti::: ny 5: ::ht:::d. Thedefinedteradappearincaitaizedtyeand se-i ll t; applicable throughout these Technical Specifications p- d -Ba A , are < L8eyu g etm65g l ACTION prescribes remed4M
-W ACTI shall be that part of a Spec ication
-::: r:: r:;;! rad under_designa_ted nditionsfa:L ~
s e -lo (jgiMin spec;hed L U P AVERAGE PLAf4AR EXPOS 1AE - ~ [,7 I shall pplicable a speciff lana eight 1.2 T W AVERAGE MAR EXPO to the of the e sure of a e fuel r in fandise e fue 1 CLH6R v AVERAGE ptANAR LINEAR HEAT GENERAT:ON
;[N; RATION RATE APLHGRy s RATE '(APL H M The AVE" ACE "LA.NA" L:"EA'1 :::A to a specific planar height and is equal to the sum of the L:#:AR ;; CAT alt hvices k uc sENERATION RATES for all the fuel rods in the specified bundle at the C O U T* M specified height divided by the number of fuel g,.in the fuel bundle.
0 45
# CHANNEL CALIBRATION-
# 4,4- A CHANNEL CAllBRATION shall be the adjustment, as necessary, of the channel output such that it responds with he necessary range and accuracy to known values of the parameter- the channel monitors. The CHANNEL CALIBRATION shalt encompass :nt'r: th: n 'n:hdi,,, o. .....m , ,d ;.h m :nd/ _
tr'; f.,~t i;::,/* ;h:c.d a.;; ... h.I.:'the CHANNEL FUNCTIONAL TheTEST CHANNEL frM M c[ CAllBRATIONmaybeperformedbyYanyseriesofsequential,(o poing or
- t'r: ;h;c. .;l i; .? !Lr;t:dAalierano l
@ total channel steos c:5 th:t th:of instrument channels.with resistance temperature detect
-[, , ' ' ' - thermocouple sensors sh;?' :ensi;; ef veri :tien of eper:bi'ity of the sens4n9-Hement end adjudwiii -s a m : n.,goi tha *==>4ninn adiustabl
/- - - -
devices in the channel. f
-_ cosas t of a n inPLQce f LUbO8HC
#Tb my8,//@Sfn*[MAISC2' P l CHANNEL CHECK
-l + A CHANNEL CHECK shall be the qualitative assessmen of channel behavior g' l during operation,bj et;; recti:n This determinat n shall include, where l possible, comparison of the channel indication fut status-wMigother indications andfor status derived from independ nt in trument channels O
measuring the same parameter. 6 tf o}6 3 _wserv 6o rp ' CHANNEL FUNCTIONAL TEST
-h 6- ANNEL FUNCTIONAL TEST shall beh a 04 att devices A.3 J L "k"l m&cc6xl Mn:h; :h:nneh Cthe injection of a simulate signal into the channel )
as close to the sensor as practicable to verify OPERABILIT.]::hding
~
l ngu'ind fe NI;-- 2nd/;r '"" 9""* ^"" '"4 *- 21 nih IM P3 - chul otd48MTY
- b. "!!! bh th:meh - tM inject he of : ti cht d eignal /IWtn lento 6 te_ver"v OPERro!L!" Schdin; 21ere and/or tvip funct4cm g; The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlappin or total channel step that the ntire channel is tested. )
' 4322S of 11 endment No. 41 i FERMI - UNIT 2- I PAGE : _. OF 14 he-l l
$P Ol5 Cat STil I* D A.I DEFINITIONS EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME [gy[df"o?;
-4rH The EMC^,^. se, seai ;00u;; ^?";;;; ECC5fRESPONSETIMEshallbethattime interval from when the monitored parameter exceeds its ECCS "W setpoint at the channel sensor untti the ECCS equipment is capable of performingitssafetyfunction(1.e.,thevalvestraveltotheirrequired positions, pump discharge pressures reach their required values, etc.)
Times shall include diesel generator starting and sequence loading delays 3 f- - where applicable. The response time may be measured byaany series of (med f?.S of sequential, overlappingg^ r total steps that the entTPF'7ETponse time is measured. s C ^^f.:T:^^: 07 m ;^:TI;; 70.,2R L:N-~~ tftP&) shall be the LHGR existing 4,4eatThejFRACTION OF LIMITING 4 given location divided by the spec POWER DENSITY)ified LHGR limit for that bundle type. _ j (FRACTIONOFAATEDTHERMALPOWER \ T RACT OF RAT ( A 0WER fisided by the RATED THE. RHAL P0 TP)sht L POWER._f the mez TH RMA A, $ l e l FERMI - tlNIT 2 1-2a Amendment No. 64 l PAGE 9 0F 14 Avle -
Spe m e m ou 0 A./
/,/ nrrtMfYtnNC NOTATION spe eillanc 5 The FREQUE
"^^"i":-- .. p" I P 0:-=^*= y *adfortheppmitruanceofagTahla the inta daff=ad 4 1 _ _
41DENTIFIED} LEAKAGE -- l 1.15 IDENTIFIED LEAXAGE shall be: dq q M Ob Lggs into@__lh:th . .,;t ; . such as pump saadar valve packing ( p. Lea a sump orto11ecting tank, lea 3, that is capture duct or r1
- 2. V. Lea e into the --"- -- mosph sources that are both sp c fically located and known either not to interfere witi the -
operation of the leakage detection systems or not to beLPRESSUREL - veuunuAltv41 m aar s
> Go ktsghichG i s oC.Jed' fled oA uk[ Red Lth&
150lATIUM SThlEM E E TIME C&Qlfrom tetfr' The ISOLATION SYSTEM RESPONSE TIME shall be that time , when the monitored parameter exceeds its isolation ::Ojinterva ttie setpoint ) at the channel sensor until the isolation valves travel to their required positions. Times shall include diesel generator starting (8tMs d- and secuence loading delays where applicable. The response time any l
~ be measured bykany series of sequential, overlapping or total steps I that the entire response time is measured.
x 1.17 A LIMITING CONT . R00 PAU LRN shall the core bein on a thermal hydra limit, e a patisii.e.. n =Mshoper s-^- onM 'Ite M s2b pA l I limitiner va a far AptW.D 1WCD e WDR./ LINEAR HEAT' GENERATION RATE K, 1.1^ U";AR ::: AT GO;;;AT;;%;. ""T. 4LHGR) shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over ye re w the heat transfer area associated with the unit length. SYSTEM FUNCTIONAL TEST h"hfW M Pradicd{t A3 I
-M9- A LOGIC SYSTEM FUNCTIONAL 1EST(shall be a test of all logic ",
;Mp [,t/
componentsph p *,. ia m ei---*. ., :!' "- ::hp r.: ::- ::::. :::of a logic circuit, ensor from\ue44e, thaeugh., seHd s
- e=d including the actuated device, to verify OPERABILITY. The LOGIC. 'S M?b N N ' SYSTEM FUNCTIONAL TEST may be performed by an) series of sequential, overlapping or total system steps that the entire logic _3ystem is tested. Sc, ru6s of]
X (MA11MUMFRACT10$OFLIM1"INGPOWERD(NSITY 1.20 q TM "'2!unu "iM: t value ofreag"3e the ELP r [;- hich ;;;;;G exists POWER-DENSIT%MFLPD) in t f corey shallgj l C "';l~?, ^' 'ME puBL.K .
).21 MEMBER (S) THE iubU6 snaii ~ s an inuiviousi in . .II.J U
( UNRESTR ED AREA. However an individual is not a [ien ER OF TH 1 PUBL1 uring any period which the individual prelves an
'%nr.g__ tional dose.f FERMI - U IT 2 1-3 Amendment No. 93 k+1-PAGE I 0F 14 Re4
Spec nmcAnorJ /.0 (M:.o su Spct ficc<km 5 5 ') t FINITIONS MINIMUM
-hN- The iii-i-EMCRITICAL 91 mr ?= POWER
~._.
hNb RATIO"(mIpe]!SgCPR) shall be the s exists in the coreg .fgr each +ype of fueQ 5'M m b d C [0FF-GAS TREAMIENT SYSTEM 1 _. (4T& An FF-GAS TREATMENT YSTEM is any system des ned and installpt to reduce r dioactive gaseous ffluents by collecting eactor coolant fstem ffgases from the eactor coolant and prov ing for delay holdup for the purpose of ducing the total radio ivity prior to elease to the g*g b utennennt. , [0FFSITEDOSECALCULATIONMANUAL
- p. The OFFSITE DOSE CALCULATION MANUAL (00CM) shall contain the methodology
, and parameters used in the calculation of offsite doses resulting from i
radioactive gaseous and liquid effluents, in the calculation of gaseous M J and liquid effluent monitoring Alars/ Trip Setpoints, and in the conduct of i I
, T the Radiological Environmental Monitoring Program. The ODCM shall also gudkati contain (1) the Radioactive Effluent Controls required by Section 6.8.5 l 6,5 and Radiological Environmental Monitoring Programs and (2) descriptions of I the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports re utred by Specifications 6.9.1.7 and 6.9. - - - -
OPERABLE - OPERABILITY dM5l#H e F i A system, subsystem, t..$ omponent or device shall Al . OPERABILITY when it is capabl of performing its spect e4PERABLE d function (s) and or have O when all_ necessary attendant instrumentation controls, electrical power, 4- cooitng-4r-seal water, lubrication required for the system, sobsystem,pr otheromponent uxiliary equipment or device tothat are perform PM; its4 function (s) are also capable of raing their related support M function (s). 006 ^ nore n;; L c6HDITiGW - cudo;;;0" 4,36-
.' .- ^"EDAT 'OZi. COCITIGH , i . . . . ""!T!_..,
hfIs shall Wany one inclusive combinatidh of mode switch positio 3 ' ad-av ane resctor coolant 4.10 temperatur as specified in Table ..
%d rtou.WVessef hea
- l. - g W f u l m W e a cl e te ]
PHYSICS TESTS eloswe boff- fms;d A.tD 4,W- PHYSICS TESTS shall be those tests per o to measure the fundamental ore and related instrumentation Mhe nuclear . . described in Chapter 1 ofofththe characteristics reacto SAR, authorized under the KS provisions of 10 CFR 50.59 or et rwise ved by thegoinnission. 4,44-LEMAGE GlnusalThf r. G @Tu @pl@ /N PRESSURE BOUNDARY L'EAKACET.' h a nonisolable fault in body, pipe wa h Mh;;; throu$1, or vessel wall. afeactor/colantgyste
* '"""'. CGnTAInNEni unui h Rcs nent f
/,J . l j PRIMARY C AINMENT INTEGRHT s siexistwhen.Q g
- a. Al primary containment enetrations requ d to be close during cident conditions ar either:
d q
- 1.
- Capable of bei closed by an 0 RABLE primary ontainment automatic iso tion system, or ,
FERMI - UNIT 2 1-4 Amendment No. E ,
'PAGE lo 0F 14 gav(,
l Sporpro kn m I.O
),I DErlNITIONS 2.
Closed by at least one sensal valve M nt n ange, or deact vated a omatic v ve secur d in i s closed except for v ves that re open as reitt by Specif cation 3 .3.er a inistrati sition. contrei
}M 4.l -
4
- b. 11 pri ry cent inment e ipment i ches a closed a sealed. j '
- c. Each leary ontainee air 1 k is
/
a campi 'nce wit . the ix ( requi nts if specif ation 3. 1.3. j 9 [. The priser contal nt leak rate are with 'n the 11 its of 5 ificat on 3.6.1 .
.l2
- e. T supp ession amber i in camp lance wit the reg roment of cift tion 3. 2.1.
- f. he : ling chanism ssocist with es primar containment penat ation. .g., wel s, bell , er 0 ri s, is O AABLE.
- g. The suppression chamber to re ter buildt g vacu compliance with Specification 3.6.4.2. breakers are in 1 E
offSS CONTROL PROGRAM A -
- 3. The OCESS ROL OGRAM ) sh contain curre formulas, sa ling, nalyse , test, dete nations be made
.M.2 oces g and ckagin f soli dioacti wastes ba ensur hat proc ing o actual on de trat simul d wet so wastes w be acto is j su a wa s to a ure c ance wi 10 CFR Pa 20,61 nd 71 ate the drs)oosal ogulat tns, bu require al gronts, and o er requirements g rningj solid radioactiv waste. - kR8f-PURGING
/1.31 PU/ /
or PUR* G is t contr ed proc V6f disc 3
,a onfine ing al gas f a t to in rature ressur umidit cent on r oth operat con on, in such a mann hat rep 1 ment -or gas) is r utred t urify e confine' ment.f-RATED THERMAL POWER y . . . . . . . . - . . ' (
^ ^ ~ - - shall be a total reactor core heat transfer rate to the reactor coolant :f 3430 MWT.
RTP FERMI - UNil 2 15 Amendment No. 72, SJ. 57 102 PAGE 7 0F 14 Rev& I
l t l l DISCUSSION OF CHANGES ITS: SECTION 1.0 USE AND APPLICATION I ADMINISTRATIVE f A.1 In the conversion of the Fermi 2 current Technical Specifications 3 (CTS) to the proposed plant specific Improved Technical l Specifications (ITS) certain wording preferences or conventions { are adopted which result in no 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 Selected definitions are deleted because the CTS that uses these definitions are not retained in the ITS, or the ITS will not use the defined term. Discussions of the technical aspects of these changes are addressed in the discussions of change for the specifications where the phrase is used in the ITS. The removal of. a definition that is not used in the ITS is an administrative change because it has no impact on the implementation of any existing requirement not addressed in the ITS conversion and will have no impact on safety. A.3 The CTS definitions of Channel Calibration, Channel Functional Test and LSFT include, example lists potential components. The actual channel or logic may include other components, however, all of the devices included in the channel may not be " required" to establish Operability of the channel. For example, some channels may have a " required" display function while others do not. Therefore, the example list is eliminated and replaced with a more generic "all devices" or "all logic components" along with the h addition of the phrase " required for OPERABILITY." This is consistent with the intent of the CTS wording, and therefore, the revised wording more accurately reflects this intent. Furthermore, the concluding phrase in the Channel Calibration and Channel Functional Test definitions ("such that the entire channel is tested") is redundant to the other statements in the definition and is therefore editorially deleted. Since the list of equipment functions in the definition of Channel Functional Test is simplified to eliminate examples of components / functions, the revised wording can be applied to both analog and bistable channels in the definition of Channel ig Functional Test. The separate CTS definitions / requirements for analog and bistable channels can be combined into one common ITS definition. FERMI - UNIT 2 1 REVISION 6. 05/28/99l !
[ DISCUSSION OF CHANGES ITS: SECTION 1.0 USE AND APPLICATION l The phrase "or actual" is added to the definitions of Channel Functional Test and Logic System Functional Test as an option to l the currently required simulated signal. Some tests are performed l by insertion of an actual signal into the logic (e.g.. rod block interlocks') . For others where a simulated signal is typically used for testing. there is no reason why an actual signal would prevent satisfactory performance of the test. Use of an actual signal instead of a " simulated" signal will not affect the performance of the channel. Operability can be adequately demonstrated in either case since the channel itself cannot discriminate between an " actual" or " simulated" signal. Various interpretations of the CTS requirements could lead to a conclusion _that these changes introduce some degree of flexibility and/or restriction. However, these changes reflect the intent of the CTS requirements and are, therefore, administrative changes with no impact en safety. , A.4 The definition of Critical Power Ratio has been incorporated into - the definition of Minimum Critical Power Ratio. The term CPR is not used in the ITS. The removal of a definition that is not used in the ITS is an administrative change because it has no impact on the implementation of any existing requirement not specifically addressed in the ITS conversion and will have no impact on safety. A.5 The definition for Frequency Notation was deleted because the abbreviations in CTS Table 1.1 are no longer used. All Surveillance Requirement Frequencies in the ITS are specifically stated with the associated requirement. Therefore, this is an administrative change with no impact on safety. A.6 The definitions for Identified Leakage. Pressure Boundary Leakage ' and Unidentified Leakage have been combined into the defined term Leakage. The ITS definitions of each of the subcategories of Leakage are consistent with the CTS definitions. The CTS description of identified leakage as the " leakage into ' collection systems" is intended to include only the leakage into those collection systems in the drywell space and the term leakage is considered to mean leakage into the drywell. Therefore the ITS uses the term " leakage into the drywell." instead of " leakage into cqllection systems." to more accurately reflect the intent. The definition continues to refer to Identified Leakage as also being " captured and conducted to a sump or collecting tank." FERMI UNIT 2 - 2 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION The BWR STS, NUREG 1433, definition for " Total Leakage" has been included for clarity and completeness. These changes are administrative with no impact on safety. I A.7 The CTS definition of Channel Calibration has been revised to add J more specific requirements for thermocouples and RTDs. The intent j of a Channel Calibration is to adjust the channel output so that l the channel responds with known range and accuracy. Most instrument channels contain an adjustable transmitter (sensor) l which is also subject to drift. Thus, for most channels, a l Channel Calibration includes adjustments to the sensor to re establish proper input / output relationships. Certain types of sensing elements, by their design, construction, and application have an inherent resistance to drift. They are designed such that they have a fixed input / output response which cannot be adjusted or changed once installed. When a credible mechanism that can cause change or drift in this fixed response does not exist, it is unnecessary (and in many cases not possible) to test them in the same manner as the other remaining devices in the channel to i demonstrate proper operation. RTDs and thermocouples are sensing elements that fall into such a category. Thus, for these sensors, the appropriate calibration at the Frequencies specified in the Technical Specifications would consist of a verification of Operability of the sensing element and a calibration of the remaining adjustable devices in the channel. Calibration of the adjustable devices in the channel is performed by applying the sensing elements' (RTDs or thermocouples) fixed input / output relationships to the remainder of the channel and making the necessary adjustments to ensure range and accuracy. l l This ITS provi.sions for RTDs and thermocouples are considered to be a clarification of the currently accepted method for j calibration of these instruments. As such, this change is , l considered to be administrative. l c 4
+
i FERMI - UNIT 2 3 REVISION 6 05/28/99l
i DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION A.8- The definition of Logic System Functional Test (LSFT) has been modified to exclude the actuated device. The actuated device will be tested as part of a system functional test and is specified in the Specification for each system. Deleting the actuated device from the definition of LSFT eliminates the confusion as to whether a previously performed LSFT is rendered invalid if the final actuated device is discovered to be inoperable as a consequence of another Surveillance (e.g.. valve cycling). In instances where the CTS does not contain a corresponding " system functional test" that tests the actuated device, one is added in the ITS. Therefore, this change in conjunction with other proposed changes that move or establish requirements in other Specifications, maintains the same technical requirements and is, therefore, an administrative change. This change is consistent with BWR STS. NUREG 1433. Rev 1. i l A.9 The ITS Core Alterations definition deletes reference to the word l
" conservative" with regard to "... movement of a component to a I safe conservative position." When Core Alterations are required !
to be suspended. it is known that a specific movement may have to ' be completed. Completing the movement that was in progress at the ! time of the requirement to suspend is required to establish a l
" safe" configuration (e.g., no fuel bundle suspended from the fuel mast). The requirement to establish a " safe" position is deemed proper and sufficient. Eliminating the requirement to also be in a " conservative" position avoids potential confusion and perhaps overly restrictive interpretation. Since there is no reference on which to base the conservative evaluation (i.e., conservative with respect to what?). it is assumed that " conservative" is intended to reflect the same context as " safe." That is, if it is " safe" it is also " conservative." Given this understanding, the wording '
change is editorial. This is acceptable since " safe" adequately , controls the allowance to complete the move. A.10 The CTS defined term Operational Condition Condition is replaced by the ITS defined term Mode. This terminology is used so that ITS will be consistent with BWR STS. NUREG 1433. Rev 1. Since the terms 'are defined and the change is made consistently throughout the ITS this change is editorial. The definition has been revised to indicate that Modes defined in ITS Table 1.11, are applicable only when fuel is in the reactor vessel and that the Mode may be affected by the status of the reactor vessel head closure bolt tensioning. These changes are administrative because FERMI UNIT 2 4 REVISION 6 05/28/99lh
1 DISCUSSION OF CHANGES ITS: SECTION 1.0 USE AND APPLICATION they are consistent with a footnote to CTS Table 1.2. This administrative change has no impact on safety. A.11 The CTS definition for Operable-Operability is being modified to i improve clarity. The CTS definition requires the availability of l "all necessary attendant... electrical power" and is interpreted ' as a requirement for the availability of only one source of power for Operability. However, this definition has a history of requiring both " normal and emergency power" in Technical Specifications for plants licensed before 1980. To prevent confusion, the requirement is more explicitly stated in the ITS as "all necessary attendant... normal or emergency electrical power." The CTS definition's stipulation "to perform its specified function (s)" is intended to address only safety function (s) and not to encompass any non safety functions a system may also perform. This intent is clarified by use of the phrase "specified safety function (s)" in the ITS version of the defir11 tion. These changes are consistent with BWR STS. NUREG 1433. Rev. 1. and are administrative changes because there is no change to the intent or implementation of the CTS and therefore, no impact on safety. A.12 The CTS definitions for Primary Containment Integrity and Secondary Containment Integrity are deleted because these definitions duplicate requirements that are appropriately contained in Specifications. Some of the details of these definitions are relocated to various Section 3.6 Bases: refer to 1.0 00C LA.1 for this discussion. The change is administrative because all the requirements in the definitions are addressed in b ITS Limiting Conditions for Operation (LCOs) and/or Surveillance n Requirements (SRs) for other Specifications and therefore, this 2 change has no impact on safety. Specifically: 4
. CTS 1.29.a.1. and 2: adequately addressed by ITS LC0 3.6.1.3 ,3 '
and associated SRs 3.6.1.3.2. 3. and 8. t<il
. CTS 1.29.b and f: sealing" requirements are adequately specified by the Primary Leakage Rate Testing Requirements of ITS SR 3.6.1.1.1 Type A leakage test. }
g
. CTS 1.29.c: addressed by ITS LC0 3.6.1.2. <
. CTS 1.29.d: addressed by ITS LC0 3.6.1.1 and SRs 3.6.1.3.12 and #
3.6.1.3.13. Y
. CTS'1.29.e: addressed by ITS LCOs 3.6.1.1. 3.6.2.1, and 3.6.2.2.
FERMI UNIT 2 5 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 1.0 USE AND APPLICATION
. CTS 1.29.g: addressed by ITS LC0 3.6.1.7.
CTS 1.36.a.1. and 2: adequately addressed by ITS LC0 3.6.4.2 h Q and associated SRs 3.6.4.2.1 and 3. M
. CTS 1.36.b and e: " sealing" requirements for blowout panels and sealing mechanisms are adequately specified by the leakage 3 .
testing requirements of ITS SR 3.6.4.1.5. D
. CTS 1.36.b: closed hatches and blowout panels requirements are m specified by ITS SRs 3.6.4.1.2 and 3.6.4.1.4. 3
. CTS 1.36.c: addressed by ITS LC0 3.6.4.3. E l
. CTS 1.36.d: addressed by SR 3.6.4.1.3. $ l
. CTS 1.36.f: addressed by ITS SR 3.6.4.1.1.
. CTS 1.36.g: addressed by ITS SR 3.6.4.1.2.
v A.13 <Not usedi. A.14 The CTS definition of Shutdown Margin is modified to address stuck control rods. This is consistent with the current CTS requirement in Surveillance 4.1.1.c to account for the worth of a stuck control rod. The movement of this requirement to the SDM definition is an administrative change with no impact on safety. A.15 The CTS definition of Staggered Test Basis is reworded to improve clarity and to establish an approach consistent with BWR STS. NUREG-1433. Rev 1. The requirements for the frequency of testing components on a Staggered Test Basis is not changed. The revised definition is designed so that the minimum Surveillance interval ' for the applicable subsystem is specified as the Surveillance Requirements' Frequency and is independent of the number of subsystems. The impact of the change in the definition will be evaluated for each application of the definition, and therefore, this is an administrative change with no impact on safety. A.16 The stipulation in footnotes to CTS Table 1.2 that the Mode definition applies only when fuel is in the reactor vessel has been moved to the definition of Mode. The stipulation in footnotes to CTS Table 1.2 that a certain Mode definition applies "with the head removed" was eliminated because it is redundant to the condition when " head closure bolts are less than fully tensioned." ITS footnote (a) is added to the definitions to clarify that Modes 2. 3 and 4 only exist when the reactor head bolts are fully tensioned. These are administrative changes becaus'e there is no change to the existing requirements and therefore, have no impact on safety. FERMI - UNIT 2 6 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION A.17 The footnotes to CTS Table 1.2 referencing Special Test Exceptions l 3.10.1, 3.10.3, and 3.10.7 have been deleted. These footnotes are cross references and are not needed in ITS. Therefore, this is an i administrative change with no impact on safety. This is l consistent with the BWR STS. NUREG 1433. Rev 1. A.18 The following sections are added: Section 1.2 - Logical , Connectors: Section 1.3 - Completion Times: and Section 1.4 - Frequency. These additions aid in the understanding and use of the ITS format and presentation style. The reason for these additional sections is that some conventions in the application of Technical Specifications to unusual situations have been the subject of debate and different interpretations between the ' licensees and the NRC Staff. Because the guidance in these proposed sections establishes positions not previously formalized, the guidance is considered administrative. These sections are I consistent with the BWR STS, NUREG-1433. Rev 1. The new sections I are as follows: ! Section 1.2 - Logical Connectors l Section 1.2 provides specific examples of the logical { connectors "A_N]" and "M " and the numbering sequence associated with their use. Section 1.3 Completion Times Section 1.3 provides direction for the proper use and interpretation of Completion Times. The Section also provides specific examples that aid the user in understanding Completion Times. Section 1.4 - Frequency Section 1.4 provides direction for the proper use and interpretation of the Surveillance Frequency. The Section also provides specific examples that aid the user in understanding Surveillance Frequency. FERMI UNIT 2 7 REVISION 6 05/28/99
l DISCUSSION OF CHANGES ITS: SECTION 1.0 USE AND APPLICATION TECHNICAL CHANGES MORE RESTRICTIVE M.1 The CTS Table 1.2 Operational Condition definitions present a potential to interpret certain plant conditions such that no Mode, or a less restrictive Mode would exist. To minimize this , potential, certain clarifications are added. The addition of head I closure status (as ITS footnote (a)). mode switch position to the
-definition of Startup and extending the range of coolant temperatures for the Refueling definition is intended to address plant conditions in ITS.that are not currently defined as a Mode or can be defined as more than one Mode. The intent of these ITS changes is to provide clarity and completeness and avoid potential misinterpretation. Since the changes eliminate the potential to interpret certain plant conditions such that no Mode, or a less restrictive Mode would exist this change is discussed and justified as a "more restrictive" change. Specifically:
Startup Mode will now include the mode switch position of
" Refuel" when the head bolts are fully tensioned (footnote
"(a)"). This is currently a plant condition which has no i corresponding Mode and could therefore be incorrectly interpreted as not requiring the application of the majority of Technical Specifications. By defining this plant condition as Startup Mode, sufficiently conservative restrictions will be applied by the applicable LCOs.
Clarifying the shutdown Modes is a new footnote stating "all reactor vessel head bolts fully tensioned" which eliminates the overlap in defined Modes when the mode switch is in " Shutdown" position. For example, with the vessel head detensioned, both the definition of Refuel as well as Cold Shutdown could apply. It is not the intent of the Technical Specification to allow an option of whether to apply Refuel applicable LCOs or to apply Cold Shutdown applicable LCOs. This change precludes an unacceptable interpretation. The CTS definition of Refuel does not apply when average coolant temperature exceeded 140 F. With the mode switch in " Refuel" a plant condition which has no corresponding ! Mode could therefore exist. This could be incorrectly I interpreted as not requiring the application of the majority of Technical Specifications. By defining the Refuel Mode to include plant conditions with no specific ' FERMI UNIT 2 8 REVISION 6. 05/28/99lh
DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION coolant temperature range. sufficiently conservative restrictions will be applied by the applicable LCOs during all fueled conditions with the vessel head bolts detensioned. These more restrictive changes provide clarification to the Specifications and will reduce potential misinterpretations and result in consistent application of the requirements. Therefore, this change will have no negative impact on safety. TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic"
~
LA.1 The CTS definitions for Primary Containment Integrity and Secondary Containment Integrity are deleted because these definitions duplicate requirements that are appropr.iately A contained in other Specifications (refer to 1.0 DOC A.12 for q detailed discussion). However. CTS definition 1.29.a. b and c are y relocated to ITS 3.6.1.1 Bases, stating the necessity for these requirements as they relate to maintaining a leak-tight containment barrier. These details'can be adequately defined and h controlled in the Bases which require change control in accordance $ with ITS 5.5.10. Bases Control Program. Since these details do 9 not impact the requirements to maintain the primary containment i (including associated support systems and components) operable. l this change continues to provide adequate protection of the public Y ' health and safety. TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" L.1 The CTS definition of Channel Functional Test for bistable channels requires the test signal to be injected "into the ; sensor." The ITS allows the signal to be injected "as close to i the sensor as practicable." Injecting a signal at the sensor increases the probability of actuating related circuits that are not being tested in those cases where several logic channels are associated with one sensor. Therefore. performing the test by injecting a signal at the sensor may require jumpering associated logic channels to prevent their initiation during the test, or increasing the scope of the test to include other logic channels. Either approach increases the difficulty of performing the FERMI UNIT 2 9 REVISION 6 05/28/99l l
DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION surveillance. Allowing initiation of the signal close to the sensor provides a complete test of the channel function while reducing the probability of an undesired initiation. Therefore, this change will have a negligible impact on safety. This change is consistent with BWR STS. NUREG 1433, Rev 1. i l L.2 The CTS Core Alterations definition is revised to delete reference j to the word " normal" and include LPRMs in the list of instruments i that can be moved. The CTS makes no delineation of what is and is not considered " normal" movement. This has lead to some confusion l and perhaps overly restrictive interpretation. The change l maintains Core Alterations as movement of only that which can l affect core reactivity. The basis for this is evident in that the Specificat. ions applicable during Core Alterations are those that protect from or mitigate a reactivity excursion event. In keeping with this, the ITS provides that any movement (including undervessel replacement) of SRMs. IRMs LPRMs, TIPS or special movable detectors (i.e., incore instruments) is not considered a Core Alteration. The ITS focuses the definition on activities that can affect the core reactivity. Since incore instruments have negligible (if any) affect on core reactivity, any movement of incore instruments has essentially no impact on core reactivity. Therefore, revising the definition to delete the word
" normal" places no restrictions on incore instrument movement:
" normal" or otherwise, including under vessel replacement. This change is consistent with BWR STS NUREG-1433.
L.3 The ITS Core Alterations definition is revised to allow control rod movement in a defueled cell to not be considered a Core Alteration. With the cell defueled, the negative reactivity inserted by removing the adjacent four fuel assemblies is significantly more than any positive reactivity inserted during control rod movement (including complete removal). Appropriate Technical Specifications controls are applied during the fuel movements (i.e., they are Core Alterations) preceding the control rod movement to protect from or mitigate a reactivity excursion event. After the fuel has been removed, sufficient margin and administrative controls are in place to allow removing the Technical Specification controls applicable during Core Alterations. Therefore, revising the definition to allow control rod movement in a defueled cell to not be considered a Core Alteration focuses the definition on activities that can affect ~ the core reactivity. Maintaining Core Alterations as movement of only that which can affect core reactivity is consistent with its FERMI UNIT 2 10 REVISION 6 05/28/99lh
DISCUSSION OF CHANGES ITS: SECTION 1.0 - USE AND APPLICATION application in the Specifications. Core Alterations Applicabilities involve Specifications that protect from or mitigate a reactivity excursion event. This change is consistent with BWR STS, NUREG - 1433. L.4 The CTS definition of LSFT requires inclusion of the channel sensor in the LSFT. The ITS Definition of LSFT allows the signal to be injected "as close to the sensor as practicable" in lieu of "from sensor." Injecting a signal at the sensor increases the probability of actuating related circuits that are not being tested in those cases where several logic channels are associated with one sensor. Therefore, performing the test by injecting a signal at the sensor may require jumpering associated logic channels to prevent their initiation during the test, or increasing the scope of the test to include other logic channels. Either approach increases the difficulty of performing the ! surveillance. Allowing initiation of the signal cl,ose to the l sensor provides a complete test of the logic channel while reducing the probability of an undesired initiation. Furthermore, the sensor is adequately tested by the Channel Calibration to assure complete channel Operability. Therefore, this change will have a negligible impact on safety. This change is consistent with BWR STS, NUREG 1433. Rev 1. REl,.0CATED SPECIFICATIONS None l l l l FERMI - UNIT 2 11 REVISION 6, 05/28/99l
Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions
------------------------------------NOTE- =-------- --------------------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases. . It.tm Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times. AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific HEAT GENERATION RATE planar height and is equal to the sum of the (APLHGR) XLHGRsV{Ht ;= tien rete y;, unit k;;;th ;f feel . W) for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle pt the heightk CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it I responds within the necessary range and accuracy to known values of the parameter that the channel , monitors. The CHANNEL CALIBRATION shall encompass C.I dildd sCe51M -bh;;. th rtire c6 red (<fuW A '" ylden;.el,
=i, andincludir.;
ir ip iundthe required suna. and A,il eenoep fv Cha( the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature 0%ftpr6ftRYoM detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total g
~
cha nel steps - t tne uni;.- J.-..n i Q Cil - -- CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or (continued) j 1
- "a/t :T: 1.1-1 ":v 1, Ot/C7/;;
i
l l Definitions 1.1 1.1 Definitions l CHANNEL CHECK status derived from independent instrument (continued) channels measuring the same parameter. CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify r4 aB devic 43 in 4k OPERABILITYpel dinv mir.J dar=, interk d , cWel re v;nd .fw- spleyf - ~ tri;; '"reti:= , r.d d-.....I Te .1 - - M^'( p trip v The CHANNEL FUNCTIONAL TEST may be
# l*/ performed by means of any series of sequential,
- overlapping, or total channel steps :: th:t the-C./ Iet525==1is:nW -
CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. The following exceptions are not considered to be CORE i ALTERATIONS:
- a. Novement of source range monitors, local power range monitors, intermediate. range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);
and
- b. Control rod movement, provided there are no fuel assemblies in the associated core cell.
Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position. CORE OPERATING LINITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications. DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/ gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132 I-133 I-134, and 1-135 actually present. The thyroid dose (continued)
~O/; od- 1.1-2 W1. "'/^710'
i Definitions 1.1 1.1 Definitions (continued) LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all teev+ red-logic components M .:.. d ' I r auir d --'--- - > --+--+- *l-"- e d- 0 Ttjm W b
. i
~
tate h;EAE. DAM.fof a Sogic' circuit, DW'L8 &/ from as.close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested. MAXIMUM FRA ON N'he MFLPD shall the largest valu of the F LIMITING 1 action of limiti power density 1 the core. ER DENSITY LPD) Th fraction of lie ing power density hall be A' the HGR existing at tven location d ided by s _,, the s cified LHGR limi or that bundle . MINIMUM CRITICAL POWER The MCPR shall be the snailest critical power RATIO (MCPR ratio (CPR)thatexistsinthecoreTforeach
- 1p 7 a4ees of fue1 . The CPR is that power in the assambly that{is calculated by application of the appropriate correlation (s) to cause,some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel. OPERABLE-OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function (s) and when all necessary attendant - instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function (s) are also capable of perfoming their related support function (s). PHYSICS TESTS PHYSILS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. I (continued)
?"El0 L 1.1-5 M r; 1, O'.l0?l0;
~
Y JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: CHAPTER 1.0 - USE AND APPLICATION NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG-1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Some of these changes are specifically discussed below:
- a. NUREG Definition END 0F CYCLE RECIRCULATION PUMP TRIP (E0C-RPT)" is not retained in the Fermi 2 ITS to be consistent with the current Fermi 2 design and licensing basis, which does not include this trip function.
- b. NUREG Definition " PRESSURE Al0 TEMPERATURE LIMITS REPORT (PTLR)"
reflects adoption of generic NRC accepted methods of determining P/T limits. Since Fermi-2 does not have methods that are generically reviewed and approved by the NPC for future use, this option, and therefore this Definition, are not incorporated in ITS.
- c. The ITS TURBINE BYPASS SYSTEM RESPONSE TIME Definition reflects CTS wording, which in turn, reflects Fermi 2 specific analytical methodologies. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions.
P.2 Not used. - P.3 Not used. P.4 Relocation of the Definition of L, from 1.0, Definitions, to the Primary Containment Leak Rate Testing Program in ITS Section 5, is a presentation preference consistent with unapproved Generic Change TSTF 52. While relocation of the Definition was not specifically included in the initial TSTF 52 proposal (oversight), it is consistent with the intent of TSTF-52, since the Section 5 l l Program contains the Definition. The removal of the Definition from Section 1 is addressed in a revision to TSTF 52. l l GENERIC CHANGES ! C.1 TSTF 205: NRC approved change to NUREG 1433. FERMI UNIT 2 1 REVISION 6. 05/28/99l
l INSERT THIS PAGE IN FRONT OF VOLUME 4 Volume 4: SECTION 3.3.1.1-3.3.4.1 Remove Replace 3.3.1.1 ITS pg 3.3-5 Rev 0 3.3.1.1 ITS pg 3.3-5 Rev 6 3.3.1.1 ITS pg 3.3-8 Rev 0 3.3.1.1 ITS pg 3.3-8 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-18 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-18 Rev 6 l B 3.3.1.1 ITS pg B 3.3.1.1-27 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-27 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-28 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-28 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-29 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-29 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-30 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1 30 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.131 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-31 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-32 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.132 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.133 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-33 Rev 6 B 3.3.1.1 ITS pg B 3.3.1.1-34 Rev 0 B 3.3.1.1 ITS pg B 3.3.1.1-34 Rev 6 l - B 3.3.1.1 ITS pg B 3.3.1.135 Rev 6 3.3.1.1 CTS M/U (3/4 3 1) pg 4 of 11 3.3.1.1 CTS M/U (3/4 3-1) pg 4 of 1I Rev 6 l 3.3.1.1 CTS M/U (3/4 3-8) pg 11 of i1 3.3.1.1 CTS M/U (3/4 3-8) pg 11 of 11 Rev 6 3.3.1.1 DOCS pg i Rev 0 3.3.1.1 DOCS pg i Rev 6 3.3.1.1 DOCS pg 3 Rev 0 3.3.1.1 DOCS pg 3 Rev 6
- 3.3.1.1 DOCS pg 4 Rev 0 3.3.1.1 DOCS pg 4 Rev 6 3.3.1.1 DOCS pg 6 Rev 0 3.3.1.1 DOCS pg 6 Rev 6 3.3.1.1 DOCS pg 7 Rev 0 3.3.1.1 DOCS pg 7 Rev 6 ,,
3.3.1.1 DOCS pg 8 Rev 0 5.3.1.1 DOCS pg 8 Rev 6 j 3.3.1.1 DOCS pg 9 Rev 0 3.3.1.1 DOCS pg 9 Rev 6 3.3.1.1 DOCS pg 9i Rev 0 3.3.1.1 DOCS pg 9i Rev 6 3.3.1.1 DOCS pg 10 Rev 0 3.3.1.1 DOCS pg 10 Rev 6 3.3.1.1 DOCS pg i1 Rev 0 3.3.1.1 DOCS pg 1i Rev 6 3.3.1.1 DOCS pg 12 Rev 0 '3.3.1.1 DOCS pg 12 Rev 6 3.3.1.1 DOCS pg 14 Rev 0 3.3.1.1 DOCS pg 14 Rev 6 3.3.1.1 NUREG M/U pg 3.3-1 3.3.1.! NUREG M/U pg 3.3-1 Rev 6 3.3.1.1 NUREG M/U pg 3.3-4 3.3.1.1 NUREG M/U pg 3.3-4 Rev 6 3.3.1.1 NUREG M/U pg 3.3-7 ? 1.1.1 NUREG M/U pg 3.3-7 Rev 6 B 3.3.1.1 NUREG M/U pg B 3.3-19 (Insert) Rev 0 B 3.3.1.1 NUREG M/U pg B 3.3-19 unsert) Rev 6 B 3.3.1.1 NUREG M/U pg B 3.3-27 B 3.3.1.1 NUREG M/U pg B 3.3 27 Rev 6 B 3.3.1.1 NUREG M/d pg B 3.3-27 (Insert) Rev 0 B 3.3.1.1 NUREG M/U pg B 3.3-27 (Insert) Rev 6 B 3.3.i.; NUREG W ' pe B 3.3-28 B 3.3.1.1 NUREG M/U pg B 3.3-28 Rev 6 Rev 6 05/28/99 f t
Volume 4: SECTION 3.3.1.1-3.3.4.1 (cont'd) Remove Replace B 3.3.1.1 NUREG M/U pg B 3.3-29 B 3.3.1.1 NUREG M/U pg B 3.3-29 Rev 6 B 3.3.1.1 NUREG M/U pg B 3.3-29 (Insert) Rev 0 B 3.3.1.1 NCREG M/U pg B 3.3-29 (Insert) Rev 6 B 3.3.1.1 NUREG M/U pg B 3.3-30 B 3.3.1.1 NUREG M/U pg B 3.3 30 Rev 6 B 3.3.1.1 NUREG M/U pg B 3.3-30 (Insert) Rev 0 B 3.3.1.1 NUREG M/U pg B 3.3-30 (Insert) Rev 6 3.3.1.1 JFD's pg i Rev 0 3.3.1.1 JFD's pg 1 Rev 6 3.3.1.1 JFD's pg 2 Rev 0 3.3.1.1 JFD's pg 2 Rev 6 B 3.3.1.2 ITS pg 3.3.1.2-7 Rev 0 B 3.3.1.2 ITS pg 3.3.1.2-7 Rev 6 B 3.3.1.2 ITS pg 3.3.1.2-8 Rev 0 B 3.3.1.2 ITS pg 3.3.1.2-8 Rev 6 B 3.3.1.2 ITS pg 3.3.1.2-9 Rev 0 B 3.3.1.2 ITS pg 3.3.1.2-9 Rev 6 3.3.1.2 DOCS pg 4 Rev 0 3.3.1.2 DOCS pg 4 Rev 6 3.3.1.2 DOCS pg 5 Rev 0 3.3.1.2 DOCS pg 5 Rev 6 3.3.1.2 DOCS pg 6 Rev 0 ._ 3.3.1.2 DOCS pg 6 Rev 6 3.3.1.2 DOCS pg 7 Rev 0 3.3.1.2 DOCS pg 7 Rev 6 3.3.1.2 DOCS pg 8 Rev 6 B 3.3.1.2 NUREG M/U pg B 3.3-41 B 3.3.1.2 NUREG M/U pg Il 3.3-4i Rev 6 B 3.3.1.2 NUREG M/U pg B 3.3-41 (Insert) Rev 0 B 3.3.1.2 NUREG M/U pg B 3.3-41 (Insert) Rev 6 B 3.3.1.2 NUREG M/U pg B 3.3-42 B 3.3.1.2 NUREG M/U pg B 3.3-42 Rev 6 B 3.3.1.2 NUREG M/U pg B 3.3-43 B 3.3.1.2 NUREG M/U pg B 3.3-43 Rev 6 3.3.1.2 JFD's pg 2 Rev 0 3.3.1.2 JFD's pg 2 Rev 6 3.3.2.1 ITS pg 3.3-18 Rev 0 3.3.2.1 ITS pg 3.3-18 Rev 6 3.3.2.1 ITS pg 3.3 19 Rev 0 3.3.2.1 ITS pg 3.3-19 Rev 6 3.3.2.1 ITS pg 3.3-20 Rev 0 3.3.2.1 ITS pg 3.3-20 Rev 6 3.3.2.1 ITS pg 3.3-21 Rev 0 3.3.2.1 ITS pg 3.3-21 Rev 6 B 3.3.2.1 ITS pg B 3.3.2.1-7 Rev 0 B 3.3.2.1 ITS pg B 3.3.2.1-7 Rev 6 B 3.3 ?.1 ITS pg B 3.3.2.1-8 Rev 0 B 3.3.2.1 ITS pg B 3.3.2.1-8 Rev 6 B 3.3.2. I ITS pg B 3.3.2.1-9 Rev 0 .B 3.3.2.1 ITS pg B 3.3.2.1-9 Rev 6 B 3.3.2.I ITS pg B 3.3.2.1-10 Rev 0 B 3.3.2.1 ITS pg B 3.3.2.1-10 Rev 6 B 3.3.2.1 ITS pg B 3.3.2.1-11 Rev 0 B 3.3.2.1 ITS pg B 3.3.2.1-11 Rev 6 l B 3.3.2.1 ITS pg B 3.3.2.1-12 Rev 6 3 3.2.1 CTS M/U (3/41-16) pg i of 9 1.3.2.1 CTS M/U (3/41-16) pg 1 of 9 Rev 6 1 3.3.2.1 CTS M/U (3/4 3-43) pg 5 of 9 3.3.2.1 CTS M/U (3/4 3-43) pg 5 of 9 Rev 6 l 3.3.2.1 CTS M/U (3/4 3-44) pg 6 of 9 3.3.2.1 CTS M/U (3/4 3-44) pg 6 of 9 Rev 6 l 3.3.2.1 DOCS pg i Rev0 3.3.2.1 DOCS pg i Rev 6 i 3.3.2.1 DOCS pg 2 Rev 0 3.3.2.1 DOCS pg 2 Rev 6 Rev 6 05/28/99 ) I l
Volurne 4: SECTION 3.3.1.1-3.3.4.1 (cont'd) . 1 Remove Replace 3.3.2.1 DOCS pg 3 Rev 0 3.3.2.1 DOCS pg 3 Rev 6 3.3.2.1 DOCS pg 4 Rev 0 3.3.2.1 DOCS pg 4 Rev 6 3.3.2.1 DOCS pg 5 Rev 0 3.3.2.1 DOCS pg 5 Rev 6 3.3.2.1 DOCS pg 6 Rev 0 3.3.2.1 DOCS pg 6 Rev 6 3.3.2.1 DOCS pg 7 Rev 0 3.3.2.1 DOCS pg 7 Rev 6 3.3.2.1 DOCS pg 8 Rev 0 3.3.2.1 DOCS pg 8 Rev 6 3.3.2.1 DOCS pg 9 Rev 0 3.3.2.1 DOCS pg 9 Rev 6 3.3.2.1 DOCS pg 1I Rev 0 3.3.2.1 DOCS pg i1 Rev 6 3.3.2.1 NUREG M/U pg 3.316 3.3.2.1 NUREG M/U pg 3.3-16 Rev 6 l 3.3.2.1 NUREG M/U pg 3.3-17 3.3.2.1 NUREG M/U pg 3.317 Rev 6 ) 3.3.2.1 NUREG M/U pg 3.3-20 3.3.2.1 NUREG M/U pg 3.3-20 Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-50 B 3.3.2.1 NUREG M/U pg B 3.3-50 Rev 6
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B 3.3.2.1 NUREG M/U pg B 3.3-51 B 3.3.2.1 NUREG M/U pg B 3.3-5i Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-51 (Insert) Rev 0 B 3.3.2.1 NUREG M/U pg B 3.3-51 (Insert) Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-52 B 3.3.2.1 NUREG M/U pg B 3.3-52 Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-52 (Insert) Rev 0 B 3.3.2.1 NUREG M/U pg B 3.3-52 (Insert) Rev 6 j B 3.3.2.1 NUREG M/U pg B 3.3 54 l B 3.3.2.1 NUREG M/U pg B 3.3-54 Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-54 (Insert) Rev 0 B 3.3.2.1 NUREG M/U pg B 3.3-54 (Insert) Rev 6 B 3.3.2.1 NUREG M/U pg B 3.3-55 B 3.3.2.1 NUREG M/U pg B 3.3-55 Rev 6 . l B 3.3.2.1 NUREG M/U pg B 3.3-55 (Insert) Rev 0 B 3.3.2.1 NUREG M/U pg B 3.3-55 (Insert) Rev 6 3.3.2.1 JFD's pg i Rev 0 3.3.2.1 JFD's pg i Rev 6 3.3.2.1 NSHC pg 2 Rev 6 3.3.2.1 NSHC pg 7 Rev 6
-- 3.3.2.1 NSHC pg 8 Rev 6 B 3.3.2.2 ITS pg B 3.3.2.2-6 Rev 0 B 3.3.2.2 ITS pg B 3.3.2.2-6 Rev 6 B 3.3.2.2 ITS pg B 3.3.2.2-7 Rev 0 B 3.3.2.2 ITS pg B 3.3.2.2 7 Rev 6 3.3.2.2 DOCS pg 2 Rev 0 3.3.2.2 DOCS pg 2 Rev 6 3.3.2.2 DOCS pg 3 Rev 0 3.3.2.2 DOCS pg 3 Rev 6 3.3.2.2 DOCS pg 4 Rev 0 3.3.2.2 DOCS pg 4 Rev 6 B 3.3.2.2 NUREG M/U pg B 3.3-61 B 3.3.2.2 NUREG M/U pg B 3.3-61 Rev 6 B 3.3.2.2 NUREG M/U pg B 3.3-61 (Insert) Rev 0 B 3.3.2.2 NUREG M/U pg B 3.3 61 (Insert) Rev 6 3.3.2.2 JFD's pg i Rev 0- 3.3.2.2 JFD's pg i Rev 6 B 3.3.3.1 ITS pg B 3;3.3.1-6 Rev 0 B 3.3.3.1 ITS pg B 3.3.3.1-6 Rev 6 3.3.3.1 DOCS pg 2 Rev 0 3.3.3.1 DOCS pg 2 Rev 6 t
i Rev 6 05/28/99
Volume 4: SECTION 3.3.1.1-3.3.4.1 (cont'd) Remove Replace 3.3.3.1 DOCS pg 3 Rev 0 3.3.3.1 DOCS pg 3 Rev 6 3.3.3.1 DOCS pg 4 Rev 0 3.3.3.1 DOCS pg 4 Rev 6
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3.3.3.1 DOCS pg 5 Rev 0 3.3.3.1 DOCS pg 5 Rev 6 3.3.3.1 DOCS pg 7 Rev 0 3.3.3.1 DOCS pg 7 Rev 6 B 3.3.3.1 NUREG M/U pg B 3.3-67 B 3.3.3.1 NUREG M/U pg B 3.3-67 Rev 6 3.3.3.1 NSHC pg 3 Rev 0 3.3.3.1 NSHC pg 3 Rev 6 3.3.3.1 NSHC pg 4 Rev 0 3.3.3.1 NSHC pg 4 Rev 6 3.3.3.2 CTS M/U (3/4 3-57) pg i of 3 3.3.3.2 CTS M/U (3/4 3-57) pg 1 of 3 Rev 6 3.3.4.1 ITS pg 3.3-33 Rev 0 3.3.4.1 ITS pg 3.3-33 Rev 6 B 3.3.4.1 ITS pg B 3.3.4.1-8 Rev 0 B 3.3.4.1 ITS pg B 3.3.4.1-8 Rev 6 B 3.3.4.1 ITS pg B 3.3.4.1-9 Rev 0 B 3.3.4.1 ITS pg B 3.3.4.1-9 Rev 6 3.3.4.1 CTS M/U (3/4 3-32) Pg 1 of 4 3.3.4.1 CTS M/U (3/4 3-32) Pg 1 of 4 Rev 6 3.3.4.1 DOCS pg 1 Rev 0 3.3.4.1 DOCS pg 1 Rev 6 3.3.4.1 DOCS pg 2 Rev 0 3.3.4.1 DOCS pg 2 Rev 6 3.3.4.1 DOCS pg 3 Rev 0 3.3.4.1 DOCS pg 3 Rev 6 3.3.4.1 DOCS pg 4 Rev 0 3.3.4.1 DOCS pg 4 Rev 6 3.3.4.1 NUREG M/U pg 3.3-33 3.3.4.1 NUREG M/U pg 3.3-33 Rev 6 . l 3.3.4.1 NUREG M/U pg 3.3-35 3.3.4.1 NUREG M/U pg 3.3-35 Rev 6 B 3.3.4.1 NUREG M/U pg 3.3-91 B 3.3.4.1 NUREG M/U pg b 3.3-91 Rev 6 l B 3.3.4.1 NUREG M/U pg 3.3-98 B 3.3.4.1 NUREG M/U pg B 3.3-98 Rev 6 l 3.3.4.1 NUREG M/U pg 3.3-98 (Insert) Rev 0 3.3.4.1 NUREG M/U pg 3.3-98 (Insert) Rev 6 3.3.4.1 NUREG M/U pg 3.3-99 3.3.4.1 NUREG M/U pg 3.3-99 Rev 6 3.3.4.1 NUREG M/U pg 3.3-99 (Insert) Rev 0 3.3.4.1 NUREG M/U pg 3.3-99 (Insert) Rev 6 l 3.3.4.1 JFD's pg i Rev 0 3.3.4.1 JFD's pg i Rev 6 l 3.3.4.1 NSHC pg 3 Rev 0 3.3.4.1 NSHC pg 3 Rev 6 l Rev 6 05/28/99 u
p l l l RPS Instrumentation 3.3.1.1 i 1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY ! SR 3.3.1.1.4 -- -
---- NOTE - - -- -
Not re uired to be performed when enteri g MODE 2 from H0DE 1 until 12 hours after entering MODE 2. Perform CHANNEL FUNCTIONAL TEST. 7 days SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST. 7 days SR 3.3.1.1.6 Verify the source range monitor (SRM) and Prior to fully intermediate range monitor (IRM) channels withdrawing l overlap. SRMs from the l core l SR 3.3.1.1.7 ---
-- --- NOTE- --- - - - --
Only required to be met during entry into MODE 2 from MODE 1.
~ '
Verify the IRM and APRM channels overlap. 7 days 1 to
,L l SR 3.3.1.1.8 Calibrate the local power range monitors. 1000 MWD /T i
gg average core exposure SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. 92 days (continued) l l FERMI UNIT 2 3.3 5 Revision 6, 05/28/99
i RPS Instrumentation 3.3.1.1 Table 3.3.1.1 1 (page 1 of 3) Reactor Protection System Instrumentation APPLICABLE CONDITIONS H0 DES OR REQUIRED REFERENCED OT)ER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SlRVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE
- 1. Intermediate Range Monitors
- a. Neutron Flux-High 2. 3 G SR 3.3.1.1.1 s 122/125 SR 3.3.1.1.4 divisions of SR 3.3.1.1.6 full scale SR 3.3.1.1.7 SR 3.3.1.1.11 SR 3.3.1.1.15 5(a) 3 I SR 3.3.1.1.1 s 122/125 SR 3.3.1.1.5 divisions of
. SR 3.3.1.1.11 full scale SR 3.3.1.1.15
- b. Inop 2 3 G SR 3.3.1.1,4 NA ,
SR 3.3.1.1.15 n 5(a) 3 I SR 3.3.1.1.5 NA l SR 3.3.1.1.15
- 2. Average Power Range Monitors
- a. Neutron Flux- Upscale 2' 3(c) G SR 3.3.1.1.2 s 20t RTP
^ (Setdown) SR 3.3.1.1.7 '
SR 3.3.1.1.8 I SR 3.3.1.1.12
, SR 3.3.1.1.18
' b. Simulated Thermal 1 3(C) F SR 3.3.1.1.2 s 0.63 (W aW)
% Power - Upscale SR 3.3.1.1.3 + 64.3% RTP SR 3.3.1.1.8 and s SR 3.3.1.1.12 RTP(b)115.51 SR 3.3.1.1.18 i (continued)
(a) With any control rod withdrawn from a core cell containing one or more fuel assenblies. (b) 4W = 81 when reset for single loop operation per LC0 3.4.1 " Recirculation Loops Operating." Otherwise i/ *W = Ot. (c) Each APRM channel provides inputs to bnth trip systems. l FERMI UNIT 2 3.3 8 Revision 6, 05/28/99 I
I l RPS Instrumentation : B 3.3.1.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) l The Turbine Stop Valve-Closure Allowable Value is selected I to be high enough to detect imminent TSV closure. thereby l reducing the severity of the subsequent pressure transient. ! Eight channels of Turbine Stop Valve-Closure Function, with four channels in each trip system, are required to be OPERABLE to ensure that no single instrument failure will preclude a scram from this Function if any three TSVs should close. This Function is required, consistent with analysis i assumptions, whenever THERMAL POWER is a 30% RTP. This e Function is not required when THERMAL POWER is < 30t RTP W since the Reactor Vessel Steam Dome Pressure-High and the 31 Average Power Range Monitor Neutron Flux-Upscale Functions i e are adequate to maintain the necessary safety margins. I
- 10. Turbine Control Valve Fast Closure Fast closure of the TCVs results in the loss of a heat sink I that produces reactor pressure, neutron flux, and heat flux l transients that must be limited. Therefore, a reactor scram is initiated on TCV fast closure in anticipation of the transients that would result from the closure of these valves. The Turbine Control Valve Fast Closure Function is the primary scr.am signal for the generator load rejection event analyzed in Reference 7. For this event, the reactor scram reduces the amount of energy required to be absorbed and ensures that the MCPR SL is not exceeded.
Turbine Control Valve Fast Closure signals are initiated by the de-energization of the solenoid dump valve at each control valve. Redundant relay signals are provided to each RPS logic channel such that fast closure of one control valve in each RPS trip system will initiate a scram. This ) Function must be enabled at THERMAL POLTR a 30t RTP. This !' is normally accomplished automaticall' by pressure transmitters sensing turbine first stage pressure of a 161.9 psig; therefore, to consider this Function OPERABLE, the turbine bypass valves must remain shut at THERMAL POWER :
= 30% RTP.
There is no Allowable Value for the Turbine Control Valve Fast Closure Function since the channels are actuated solely l on de energization of the solenoid dump valve. 1 FEPJiI UNIT 2 B 3.3.1.1 - 18 Revision 6, 05/28/99
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR -3.3.1.1.4 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all f of the other required contacts of the relay are verified by other Technical-Specifications and non Technical Specifications tests at least once per refueling interval with, applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. . 7 As noted, SR 3.3.1.1.4 is not required to be performed when g entering MODE 2 from MODE 1. since testing of the M0DE 2 g required IRM Functions cannot be performed in MODE 1 without bl - utilizing jumpers, lifted leads, or movable links. This allows entry into MODE 2 if the 7 day Frequency is not met per SR 3.0.2. In this event., the SR must be performed within 12 hours after entering MODE 2 from MODE 1. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR. A Frequency of 7 days provides an acceptable level of system average unavailability over the Frequency interval and is , based on reliability analysis (Ref. 9). SR 3.3.1.1.5 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change'of state of a single contact of the relay. 'This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all h of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. In accordance with Reference 9. the scram contactors must be tested as part of the Manual
'l FERMI - UNIT 2. B 3.3.1.1 - 27 Revision 6, 05/28/99
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued) l Scram Function. A Frequency of 7 days provides an acceptable level of system average availability over the Frequency and is based on References 9 and 10. (The Manual Scram Function's CHANNEL FUNCTIONAL TEST Frequency was credited in the Reference 9 analysis to extend many automatic scram Functions' Frequencies.) SR 3.3.1.1.6 and SR 3.3.1.1.7 These Surveillances are established to ensure that no gaps in neutron flux indication exist from subcritical to power operation for monitoring core reactivity status. The~ overlap between SRMs and IRMs is required to be demonstrated to ensure that reactor power will not be increased into a neutror, flux region without adequate indication. This is required prior to fully withdrawing SRMs from the core since indication is being transitioned from the SRMs to the IRMs. The overlap between IRMs and APRMs is of concern when reducing power into the IRM range. On power increases. the system design will prevent further increases (by initiating a rod block) if adequate overla) is not maintained. Overlap between IRMs and APRMs exists w1en sufficient IRMs and APRMs concurrently have onscale readings such that the transition between MODE 1 and MODE 2 can be made without either APRM downscale rod block, or IRM upscale rod block. Overlap M between SRMs and IRMs similarly exists when, prior to fully N withdrawing the SRMs from the core, IRMs are abo >c the L downscale rod block and showing increasing flux on range 1 { before SRMs have reached 1/2 decade below the upscale rod block. . As noted. SR 3.3.1.1.7 is only required to be met during entry into MODE 2 from MODE 1. That is after the overlap requirement has been met and indication has transitioned to the IRMs. maintaining overlap is not required (APRMs may be reading downscale once in MODE 2). If overlap for a group of channels is not demonstrated (e.g., IRM/APRM overlap), the reason for the failure of the Surveillance should be determined and the appropriate channel (s) declared inoperable. Only those appropriate channels that are required in the current MODE or condition should be declared inoperable. s - [ FERMI - UNIT 2 B 3.3.1.1 - 28 Revision 6 05/28/99
l 1 RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued) A Frequency of 7 days is reasonable based on engineering judgment and the reliability of the IRMs and APRMs. SR 3.3.1.1.8 LPRM gain settings are determinc-d from the local flux j profiles measured by the Traversing Incore Probe (TIP) ; Q System. This establishes the relative local flux profile
- for appro)riate representative input to the APRM System.
d,l The 1000 40/T (i.e., "short" ton) Frequency is based on operating experience with LPRM sensitivity changes. < m d j SR 3.3.1.1.9 and SR 3.3.1.1.13 A CHANNEL FUNCTIONAL TEST is performed on each required ; channel to ensure that the entire channel will perform the ; intended function. A successful test of the. required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent vith the assumptions of the current plant l specific setpoint methodology. The 92 day Frequency of ' SR 3.3.1.1.9 is based on the reliability analysis of Reference 9. The 18 month Frequency is based on the need to perform this J Surveillance under the conditions that apply during a plant outage and the potential for an un)lanned transient if the Surveillance were performed with tie reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. l l / l FERMI UNIT 2 B 3.3.1.1- 29 Revision 6 05/28/99 I l l
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued)- SR 3.3.1.1.10 This Surveillance provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.1.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the recuirements of the. plant safety analysis. Uncer these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology. ;
" The Frequency of 92 days is based on the reliability I ed -analysis of Reference 9.
hl SR 3.3.1.1.11 and SR 3.3.1.1.14 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel
. responds to the measured parameter within the necessary range and accuracy. CHANNEL ~ CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations 'consistent with the plant specific setpoint )
methodology. SR 3.3.1.1.11 Note 1 stat'es that neutron detectors are i excluded from CHANNEL CALIBRATION because they are passive l devices, with minimal drift, and because of the difficulty l of simulating a meaningful signal. Changes in neutron detector sensitivity are compensated for by performing the 7 day calorimetric calibration (SR 3.3.1.1.2 and the jg 1000 MWD /T LPRM calibration against the TIPS (SR 3.3.1.1.8). SR 3.3.1.1.11 Note 2 is provided that requires the IRM SR to
> be performed within 12 hours of entering MODE 2 from MODE 1.
gl Testing of the MODE 2 IRM Function cannot be performed in
% MODE 1 without utilizing jumpers, lifted leads, or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.
( # l FERMI UNIT 2 B 3.3.1.1-30 Revision 6. 05/28/99
RPS Instrumentation j B 3.3.1.1 j BASES SURVEILLANCE REQUIREMENTS (continued) The Frequency of SR 3.3.1.1.11 is based upon a 184 day n calibration interval in the determination of the magnitude l 4 of equipment drift in the setpoint analysis. The Frequency J 3[ of SR'3.3.1.1.14 is based upon a 18 month calibration j interval in the determination of the magnitude of equipment 4 drift in the setpoint analysis. 1 SR 3.3.1.1.12 A CHANNEL FUNCTIONAL TEST is performed on each required ) channel to ensure that the entire channel will perform the !
-intended function. For the APRM Functions, this test J supplements the automatic self test functions that operate a continuously in the APRM and voter channels. The APRM l CHANNEL FUNCTIONAL TEST covers the APRM channels (including for Function 2.b only, the recirculation flow input function, excluding the flow transmitter). .the 2 out of 4 voter channels, and the interface connections to the RPS r trip systems from the voter channels. Any setpoint y adjustment'shall be consistent with the assumptions of the current plant specific setpoint methodology. The 184 day.
Frequency of SR 3.3.1.1.12 is based on the reliability analysis of Reference 13. (NOTE: The actual voting logic of the 2 out of 4 voter channels is tested as part of SR d 3.3.1.1.19.) A For Function 2.a. a Note that requires this SR to be performed within 12 hours of entering MODE 2 from MODE 1 is provided. Testing of the MODE 2 APRM Function cannot be performed in MODE 1 without utilizing jumpers or lifted leads. This Note allows entry. into MODE 2 from H0DE'1 if the associated Frequency is not met per SR 3.0.2. 4 SR 3.3.1.1.15 and SR 3.3.1.1.19 l The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the l O OPERABILITY of the required trip logic for a specific d' channel. = The functional testing of control rods
% -(LC0 3.1.3), and SOV vent and drain valves (LC0 3.1.8),
-Q overlaps this' Surveillance to >rovide complete testing of i the assumed safety function. :or the 2 out of 4 Voter
% Function, the LSFT includes simulating APRM trip conditions at the APRM channel inputs to the 2 out-of 4 trip voter channel to check all combinations of two tripped inputs to the 2 out of-4 trip voter logic in the voter channels.
'y Y l FERMI UNIT 2 B 3.3.1.1 - 31 Revision 6. 05/28/99
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued) The 18 month Frequency of SR 3.3.1.1.15 is based on the need Pl to perform this Surveillance under the conditions that apply ^ during a plant outage and the potential for an unplanned W transient if the Surveillance were performed with the g reactor at power. Operating experience has shown that these g components usually pass the Surveillance when performed at the 18 month Frequency. Additionally, the 24 month Frequency of SR 3.3.1.1.19 is based on Reference 13. SR 3.3.1.1.16
~
This SR ensures that scrams initiated from the Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure Functions will not be inadvertently bypassed when THERMAL POWER is = 30% RTP, This involves calibration of the bypass channels. Adequate margins for the instrument setpoint methodologies are incorporated into the actual set)oint. Additionally, consideration is given to the fact t1at main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure: where turbine first stage pressure of 161.9 psig conservatively correlates to 30% RTP), the main turbine bypass valves must remain closed at THERMAL POWER
= 30% RTP to ensure that the calibration remains valid.
~
If any bypass channel's s tpoint is nonconservative (i.e., the Functions are bypassed at a 30% RTP, either due to open main turbine bypass valve (s) or other reasons), then the affected Turbine Stop Valve-Closure and Turbine Control Valve Fast Closure Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE. The Frequency of 18 months is based on engineering judgment, reliability of the components, and = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. l FERMI - UNIT 2 B 3.3.1.1 - 32 Revision 6 05/28/99 l
RPS Instrumentation B 3.3.1.1 BASES l SURVEILLANCE-REQUIREMENTS (continued) SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification 1 that all components are tested. The RPS RESPONSE TIME acceptance criteria are included in Reference 10. RPS RESPONSE TIME for the APRM 2-out of 4 Voter Function , includes the output relays of the voter and the associated ' RPS relays and contactors. (The digital. portion of the APRM. and 2 out-of 4 voter channels are excluded from the RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.) 3 Confirmation of the time base is adequate to assure required response times'are met. 7 ' As noted,' neutron detectors are excluded from RPS RESPONSE g TIME testing because the principles of detector operation virtually ensure an instantaneous response time. In addition, Note 2 states the response time of the sensors for Functions 3 and 4 are excluded from RPS Response Time Testing. The sensors for these Functions are assumed to , I 4 operate at the sensor's design response time. This l allowance is supported by Reference 12, which determined
, that significant degradation of the sensor channel response time can be detected during performance of other Technical Specification SR's and that the sensor response time is a small part.of the overall RPS RESPONSE TIME testing.
RPS RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS. Note 3 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function. This Frequency is )i based on the logic interrelationships of the various I channels required to produce an RPS scram signal. The 18 month Frequency is consistent with the typical industry refueling cycle and is based upon plant operating 3
-experience, which shows that random failures of {
instrumentation components causing serious response time j degradation, but not channel failure, are infrequent 1 occurrences. j I g FERMI t DNIT 2 B 3.3.1.1-33 Revision 6 05/28/99
l l RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.1.1.18 A CHANNEL CALIBRATION is a complete check of the in'strument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint n methodology. For the APRM Simulated Thermal Power - Upscale Function, this SR also includes calibrating the associated recirculation loop flow channel. Pa v SR 3.3.1.1.18 is modified by a Note that states that neutron
% detectors are excluded from CHANNEL CALIBRATION because they are passive devices, with minimal drift, and because of the
- difficulty of simulating a meaningful signal. Changes in neutron detector sensitivity are compensated for by performing the 7 day calorimetric calibration (SR 3.3.1.1.3) and the 1000 MWD /T LPRM calibration against the TIPS 1(SR 3.3.1.1.8).
The Frequency of SR 3.3.1.1.18 is based upon 24 month I calibration interval in the determination of the magnitude of equipment dr.ift in the setpoint analysis. REFERENCES 1. UFSAR. Figure 7.2 2.'
- 2. UFSAR. Section 15.4.1.2.
- 3. NED0 23842, " Continuous Control Rod Withdrawal in the Startup Range," April 18. 1978.
- 4. UFSAR. Section 5.2.2.3.
- 5. UFSAR. Section 15.4.9.
- 6. UFSAR. Section 6.3.3.
- 7. UFSAR. Chapter 15.
8 P. Check (NRC) letter to G. Lainas (NRC) "BWR Scram Discharge System Safety Evaluation," December 1. 1980. ==/ l FERMI ' UNIT 2 B 3.3.1.1 - 34 Revision 6 05/28/99
RPS Instrumentation B 3.3.1.1 BASES REFERENCES (continued)
- 9. NED0 30851 P-A , " Technical Specification Improvement Analyses for BWR Reactor Protection System March 1988.
- 10. UFSAR, Table'7.2 4.
- 11. NEDC 31336, " Class III, October 1986, General Electric Instrument Setpoint Methodology." ,
- 12. NED0 32291, " System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994: and Fermi 2 SER for Amendment 111, dated April
,_ , _ 18, 1997.
n3
- 13. NEDC 32410P A, " Nuclear Measurement Analysis and j q
h h-Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," 1
'sc l
- October 1995, and Supplement 1. May 1996.
k F
)
l' FERMI UNIT 2 B 3.3.1.1 - 35 Revision 6, 05/28/99
i l 3/4.3 INSTRUMENTATION S 96Ci ffi cAmrJ 5. 3. /./ 3 n.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION
*I
,t_iMITING CONDTTION FOR OPERATION -
As a minimum, the reactor i $31d--3+}in Table 3.3.1-1 shall be OPERABLkrotection system instrumentation channels shown l APPLICABilfTY: As shown in Table 3.3.1.l. d ADD AL71pH4 NOTEk i ACT10ii: _ I
- a. With the number of OPERABLE channels less than required by the Minimum OPERABLE channels per Trip System requirement for one trip system:t LC.
- 1. Within I hour, verify iE.at reac1 Functional 'Jn' ilw"hia t'r -- I q hcWoN C MN .d" .no *'*N (E wn. ...r 2 "
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- - withi ho?urs or the Act}bH required by Table gg,ppfJ D 3.3.1-1 for the affected ional Unit shall be taken.
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- 3. if -h! ; +ha 4 aare-dh :..;. ...J 'i J, t. . -
N g A' -rdd ; ^ ___x :. x- , place the Ino.nperable ch,a,;d nnel(s) -.. fit b.. and/or that trip system in the tripped condition within 12 hours. M*O b. With the numbe'r of OPERABLE channels less than require by the Minimum ' 1 4 8 @# e ,N ERABLE Channels _per Trip _ e R Tea 'iine 1flp sys em re uirement for both rip s
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- c. d.
With one or more Tnannels requireo oy Taole 3.3.1-1 inoperable in one or more APRM Functional Units 2.a. 2.b. 2.c. or 2.d: k C,$0 N C 1. Within I hour, verify sufficient" channels remain DPERABLE or tripped *** to maintain trip capability in the Functional Unit, and JA 2. Within 12 hours, restore the inoperable channels to an OPERABLE I 4 CT10 or o status or tripped ***. Otherw' ise, take the ACTION required by ' Table 3.3.1-1 for the Functional Unit. hfcfA.2.NokjA& Tion 8N& J factions a and b not applicable to APRM Functional Units 2.a. 2.b 2.c, and H2.d.'^ Action C applies only to_APRM functions 2.a. 2.b, 2.c and 2.d.
^
iupu s au'i w'annui n 'Iruu nu De pldGu in L u t- t r I Uurl rnnn11 mon wnere paiyl t d caute teram nFene la thee esener n InU Jci di he c iannb.bcLndnnudlaias s'[i I 60 vr 6 i iii -1 ~-.s J was fir benu$rnd eter tn [odinndr.6u[.r/the abl ACTION required by fable 3.3.1 1 for that j McManO Functional Unit shall be taken. , g* l
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punu. rur @' o wn weinuui ... ny a scram to o.rtur, en . 6. ; ,, r :=place b; he h t : "i k, t M t ;- ; ,, the mos ,noperable chan s in the tripp d condition: if otksystemwit systems hf/e th b i sa u 4.n umber
-- - of inona -
hl= ch$nnalt- men either tr svetam in thp/trinn '
'"An ino 'lable channes n a not be placed in the tripped c dition where thi l would ause a scram to occur. In thes cases, if'the i erable channel not stored to OPE L by dble 3.3.1-1 for the Functional E status withi the required.ti , the ACTION re red,, d' it shall be ta nf ,
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I DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and ( revised numbering are adopted to make the ITS consistent with the l Boiling Water Reactor (BWR) Standard Technical Specifications i NUREG-1433. Rev. 1. A.2 ITS LC0 3.3.1.1 Actions are modified by a Note, which provides ! clarification that, for the purpose of the associated LCO. l
" Separate Gondition entry is allowed for each channel." This is acceptable because the Required Actions for each Condition provide !
appropriate compensatory actions for each inoperable RPS channel. Complying with the Required Actions will allow for continued l operation: with subsequent inoperable RPS channels governed by l subsequent Condition entry and application of associated Required I Actions. This is an administrative change with no impact on safety because the clarifications provided by the Note are consistent with a reasonable interpretation of the CTS. G d l 1 A.3 CTS 3.3.1. Actions a.2, a.3. and footnotes *. **, and *** provide lf directions on options for compliance with Technical Specifications (i'.e.. optional direction for not tripping channels if it would cause a scram, and optional direction to restore the inoperable channels to Operable status). ITS 3.3.1.1 Actions do not include detailed direction for these options. The CTS has been revised to lgt delete these Actions since these options always exist, and are - inherent in the ITS. During this presentation reformatting, no technical changes (either actual or interpretational) were made to the TS. The change is consistent with NUREG 1433. FERMI UNIT 2 1 REVISION 6. 05/28/99l
i DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION j A.7 CTS Table 4.3.1.1-1, Functions 9 and 10, state the Applicability for the Surveillances as Mode 1, while the same Functions are listed with an Applicability for Operability of Mode 1 at 2 30% RTP in CTS Table 3.3.1-1. ITS corrects the disparity with a single Applicability of 2 30% RTP. Since Surveillances are not required when the associated equipment is not required to be Operable, or is inoperable, this change reflects clarification of n existing requirements, and is therefore an administrative change. A.8 CTS Table 4.3.1.1-1, Note (f), requires an LPRM calibration frequency of "once per 1000 EFPH." ITS SR 3.3.1.1.8 replaces this \ f frequency with ~1000 MWD /T." Both Frequencies consider the LPRM sensitivity changes based on neutron flux exposure, and represent approximately the same time interval (about 6 weeks). The units Q change allows a more convenient tracking parameter since MWD /T is l% commonly calculated and reported by the process computer. Since the actual change in frequency of calibrations remains essentially the same, the change is considered administrative. A.9 CTS Table 3.3.1 1, Action 5. contains the requirement to "be in STARTUP" in addition to the requirement to close the MSIVs. Since MSIV closure in Mode 1 would result in an immediate automatic scram, the need to "be in startup" to close the MSIVs is simply an operational design detail that is implicit in the requirement to l close the MSIVs. This detail is therefore not included in ITS l 3.3.1.1 Action H. Its elimination does not modify any requirements. l Additionally, CTS Table 3.3.1 1. Action S, requires this MSIV closure in 6 hours, but also provides an option to be in Mode 3 in 12 hours. Since the option is an acceptable alternative for compliance with the Action, the 12 hours is implicitly allowed for either option (close MSIVs or be'in Mode 3). For example, if the option to shutdown was initially chosen, but at hour ll, the alternative action to close MSIVs was completed, the CTS Action would be satisfied without a Technical Specification violation. Therefore, to clarify the presentation, both actions are presented in ITS 3.3.1.1 Action H with a 12 hour Completion Time. Since no technical changes are introduced, this change is considered administrative. FERMI - UNIT 2 3 REVISION 6 05/28/99l
T l DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION
- 3- ]
A.10 CTS 2.2.1. specifies Actions for RPS channels with setpoints not i j within allowable values. These Actions state " declare the channel l[ ! inoperable and apply the applicable ACTION until the channel is restored to Operable ." ITS 3.3.1.1 contains all the 2 requirements and Actions for RPS channels, including the allowable l values and Actions when it is not met. The usage rules of l . Technical Specifications adequately dictate that channels be declared inoperable and Actions taken until restored to Operable, without an RPS specific statement to that effect. Therefore. l elimination of this statement is an administrative presentation l preference only, to A.11 CTS 4.3.1.2 requires an LSFT ."and simulated automatic operation" l A of all channels. The " simulated automatic operation" is e interpreted to included within with the LSFT. This additional lE detailing of the required test is unnecessary. Therefore its < elimination is an administrative change. . l7g l A.12 Not used. TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.3.1 Action a.1 specifies actions in the event of a loss of scram function (potentially one entire trip system without Operable scram capability). Footnote
- to this Action provides an extension of the allowed action time from 1 hour to 2 hours if l l
tripping the channel would result in a reactor scram. ITS 3.3.1.1 Action C limits this time to only one hour regardless of whether ) tripping the affected trip system would produce a scram (and thus ) eliminates the additional hour allowed in CTS). In both the CTS and the ITS, after this 1 or 2 hour allowance. provisions are made for a controlled reactor shutdown. Therefore, eliminating the 8 flexibility of the additional hour will not introduce any adverse j consequences to safety. I i i 1 O I FERMI - UNIT 2 ' 4 REVISION 6 05/28/99l l
1 l DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION l M.4 CTS Table 4.3.1.1 1 footnote (b) requires IRM/SRM overlap, but allows that verification to be performed anytime "after entering [ Mode 2]." ITS SR 3.3.1.1.6 also required IRM/SRM overlap, but I restricts that verification to " prior to fully withdrawing SRMs j from the core." If SRMs are fully withdrawn prior to IRMs coming ' on scale insufficient monitoring of reactor core power may result. Requiring that SRMs remain inserted until IRMs begin to respond will not have any negative impact on safety. M.5 CTS Table 3.3.1-1. Note (a), allows required surveillance testing l "without placing the trip system in the tripped condition provided at least one OPERABLE channel in the same trip system is monitoring that parameter." ITS SR Note 2 provides the same intended allowance by stating " entry into the associated Conditions and Required Actions may be delayed provided the associated Function maintains trip capability." In the case of some trip Functions (e.g.. MSIV closure and TSV closure) literal compliance with the CTS allowance may not ensure trip capability remains (i.e.. a single channel monitoring the parameter will not produce an RPS tip signal to that trip system). This represents a more restrictive change which has no significant impact on safety. TECHNICAL CHANGES - LESS RESTRICTIVE " Generic" LA.1 CTS 2.2.1. Limiting Safety System Settings, requires that RPS instrumentation trip setpoints to be within the Trip Setpoint column values of Table 2.2.1 1. Additionally, the CTS 2.2.1 Action requires that an inoperable RPS instrument be restored consistent with the trip setpoint value. However. Actions only rd apply if the allowable value is exceeded. ITS 3.3.1.1 requires A only that instrumentation setpoints be within the allowable value. rh Trip setpoints reflect operational details while the allowable - value reflects channel Operability. Requirements for trip setpoints in CTS 2.2.1 and CTS Table 2.2.1-1 (including associated ( footnote *) are relocated to the Technical Requirements Manual (TRM). which requires revisions be controlled by 10 CFR 50.59. The trip setpoint is established based on a combination of instrument design factors. environmental factors. and the allowable value (which is what is conservatively derived from the value assumed in the safety analyses). These details can be adequately defined and controlled in the TRM. This relocation provides adequate protection of the public health and safety since FERMI UNIT 2 6 REVISION 6, 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION y A l the instrument channel Operability and the allowable value continues to be required by the Technical Specifications. lg LA.2 CTS Table 2.2.1 1 footnote #. Table 3.3.1 1 Action 6, and 7 i footnotes (b), (g), (j), and (k), provide design details and } descriptive details for various RPS functions. ITS 3.3.1.1 g i addresses this information in the Bases and does not include these details in the Technical Specifications. This change is consistent with NUREG 1433. The information is being moved to the Bases, which requires changes to te controlled in accordance with the ITS 5.5.10. Bases Control Program. This relocation continues to provide adequate protection or the public health and safety since the requirement for instrument channel Operability continues to be required by the Technical Specifications. LA.3 CTS 3.3.1 Action a.1 addresses a requirement for a loss of RPS l i scram capability (one trip system with more than one inoperable d l channel in any Functional Unit) by detailing one option (i.e.. .L l trip inoperable channels or trip system). CTS Action b addresses the possible loss of the RPS scram function with inoperable ( ) channels in both trip systems ITS 3.3.1.1 Action C has relocated j specific details ,of restoration from the loss of function, by l specifying " restore RPS trip capability." ITS 3.3.1.1 addresses . the option of tripping the trip system in the Bases and does not i include these details in the Technical Specifications. This l change is consistent with NUREG 1433. The information is being r moved to the Bases, which requires changes to be controlled in accordance with the ITS 5.5.10, Bases Control Program. This i relocation continues to provide adequate protection of the public health and safety since the requirement for loss of-function ' restoration continues to be required by the Technical Specifications. . LA.4 CTS 3.3.1 Action b is modified by a footnote stating " place the trip system with most inoperable channels in the tripped condition," which applies to situations when both trip systems have inoperable channels. The specific detailed direction for l which trip system to trip is relocated from Technical Specifications to the ITS 3.3.1.1 Bases. This change is consistent with NUREG 1433. The information is being moved to the Bases, which requires changes to be controlled in accordance with the ITS 5.5.10, Bases Control Program. However. the Bases allow _, " prudent judgement" in determining which trip system should be tripped. Although placing the trip system with more inoperable FERMI UNIT 2 7 REVISION 6 05/28/99l
i DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION ; I channels in the tripped condition may provide a small increase in reliability, since RPS is still assured of maintaining trip capability for each Function (Action C would be entered if not maintained) other considerations may make it more prudent to place 1 the other trip systems in trip. Therefore, the Bases direct this more concerted consideration. This relocation continues to i provide adequate protection of the public health and safety since footnote ** is an instructional note not related to the g operational limits specified in TS. Therefore this detail can be 4 moved to the Bases, while the requirement to take action on one Q trip system within 6 hours, and continue restoration actions on the remaining trip system within 12 hours, continues to be required by the Technical Specifications. ! I LA.5 CTS Table 3.3.1-1 Notes (c) and (d) (and associated footnote *), applied to Functions 1.a and 1.b. detail requirements for the removal of RPS " shorting links" whenever any control rod is withdrawn in Mode 5 and SDM has not been demonstrated. These requirements are not detailed in ITS 3.3.1.1: but are relocated to the Technical Requirements Manual (TRM), which requires revisions be controlled by 10 CFR 50.59. This change is consistent with NUREG 1433. The removal of the " shorting links" results in any single SRM or IRM channel in trip producing a full RPS scram (as opposed to the y "taken-twice" logic otherwise in place for IRMs). This "non- ~ coincident trip function is not the primary mechanism preventing a reactivity excursion when control rods are withdrawn while in k Mode 5 If a single control rod is withdrawn, the one-rod-out intarlock and SDM are sufficient to prevent a reactivity excursion. Additionally, the IRM RPS Function, coupled with requirements that the withdrawn control rod (s) be Operable (ITS 3.9.5), provide backup protection. If multiple control rods are withdrawn in Mode 5 for SDM testing (refer to ITS LC0 3.10.7), protection from reactivity excursions is provided by requirements that either the RWM or a second qualified person limit the control rod pattern to that necessary to perform the SDM test. Because of the reliability of SDM calculations, enforcement of the rod pattern consistent with these calculations provides a measure of protection against a reactivity excursion. Additionally, the rate of reactivity addition during Mode 5 SDM demonstrations is limited by requiring that out of sequence rod withdrawals be performed y using " notch out. mode." Finally, the IRH and APRM RPS Functions, coupled with requirements that the withdrawn control rods be FERMI UNIT 2 8 REVISION 6, 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION Operable provide backup scram protection. Therefore. even with the relocation of shorting link removal +~) requirements, the ITS continues to provide adequate protection of e-the public health and safety since the requirement for Operable y RPS Functions continues to be maintained in the Technical m Speci fications. As such, moving requirements for removal of l4J shorting links to the TRM has no impact on safety. LA.6 CTS 4.3.1.2 provides LSFT performance details for the 2 out-of 4 Trip Voter logic (i.e., " simulating APRM trip conditions at the APRM channel inputs to the 2 out of 4 Trip Voter channel to check all combinations of two tripped inputs to the 2-out of 4 Trip Voter logic-in the Voter channels"). ITS SR 3.3.1.1.19 requires this same LSFT. however the performance details are relocated to the Bases for ITS SR 3.3.1.1.19. which require changes to be G l controlled in accordance with the ITS 5.5.10. Bases fontrol Program. These LSFT performance details are consistent with the 3 ITS definition of LSFT providing only the component-specific details of the tested channel. This change is consistent with the 6 level of detail found in NUREG 1433. The relocation continues to provide adequate protection of the public health and safety since the requirement for performance of an LSFT (and the definition of l an LSFT) continues to be maintained in the Technical Specifications. LA.7 CTS Table 4.3.1.1-1 Note (f) requires that LPRMs be calibrated "using the TIP System." ITS SR 3.3.1.1.8 requires LPRM l 3 calibration at the same Frequency; however, the detailed method 7 for performing LPRM calibrations is relocated to the Bases, which 2 require changes to be controlled in accordance with the ITS T 5.5.10. Bases Control Program. This change is consistent with NUREG 1433. The relocation continues to provide adequate protection of the public
- 5 th1 and safety since the requirement for LPRM calibrations at tr - equired Frequency continues to be maintained in the Technical Specifications.
LA.8 Not used. l9g 6 FERMI UNIT 2 9 REVISION 6 05/28/99l . f
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION LA.9 CTS Table 4.3.1.1 1 Note (e) requires that the calibration for the APRM Simulated Thermal Power - Upscale trip include the " flow input function, including flow transmitters." ITS SR 3.3.1.1.18 requires the APRM calibration at the same Frequency; however, the g ; specific detail that the flow transmitters and associated flow cy i function is included, is relocated to the Bases, which require changes to be controlled in accordance with the ITS 5.5.10. Bases Control Program. This change is consistent with the level of v detail found in NUREG-1433. The relocation continues to provide adequate protection of the public health and safety since the requirement for APRM calibrations at the required Frequency continues to be maintained in the Technical Specifications. ! t LA.10 CTS 4.3.1.3-requires Reactor Protection System Response Time testing of "each reactor trip functional unit"; however, the i details of the testing acceptance criteria are currently located l , in the Technical Requirements Manual (TRM): outside .of CTS. ITS 3.3.1.1 provides the Reactor Protection System Response Time Surveillance (SR 3.3.1.1.17) and each Function on Table 3.3.1.11 ! as appropriate, references the applicability of this test to that l Function. Since many of the RPS trip Functions have no specific - l acceptance criteria detailed in the TRM. these Functions will not i have ITS SR 3.3.1.1.17 listed as a Technical Specification required Surveillance. For these Functions, the Reactor g Protection System Response Time testSg requirements are currently (and continue to be) located in plant procedures, which require i revisions to be controlled by the administrative controls I governing procedure revisions. This placement continues to provide adequate protection of the public health and safety since lV the requirement for instrument channel Operability continues to be required by the Technical Specifications. i l l l i l l FERMI UNIT 2 91 REVISION 6 I 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.1.1.1 - RPS INSTRUMENTATION LA.11 Not used. LA.12. CTS 4.3.1.3. note *, allows the sensors for RPS Functions 3 and 4 (reactor vessel steam dome pressure and reactor vessel water level) to be exempted from being tested (6cceptable values are assumed and applied to overall channel response acceptance). For these two Functions ITS SR 3.3.1.1.17 includes Note 2 to specifically detail this allowance, however, the specific alternate option of assuming the response to be the design sensor response is relocated to the Bases. This detail of performance can be adequately controlled in accordance with ITS 5.5.10. Bases Control Program. The relocation continues to provide adequate protection-of the public health and safety since the requirement for RPS response time testing remains a Technical Specification requirement. LB.1 CTS Table 4.3.1.1 1 requires the performance of certain' Channel Checks at a Frequency of "S/U" (i.e., " prior .to startup"), and certain Channel Functional Tests "within 24 hours prior to startup, if not performed within the previous 7 days." ITS does not retain the rcquirement that verifications be performed within a brief period " prior to startup." This will allow the verifications to be performed at their normal Frequency prior to any plant startup. This change is acceptable because the
. Operability requirement for SRMs is unchanged. Elimination of the requirement to perform these tests within a short time prior to startup is not significant because the normal periodic Surveillance frequency is established to provide adequate ,
assurance that instrument channels are Operable. If any Surveillance has not been performed within its required interval, startup r.ay not commence. This ensures the requirements are adequately checked prior to and'during startup. 4 l e l FERMI UNIT 2 10 REVISION 6, 05/28/99l ) L
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION LC.1 . CTS 3.3.1 Action a.1 requires placing affected channels or trip system in trip sithin 1 hour when more than one channel in one trip system ci a Functional Unit are inoperable. ITS 3.3.1.1 lnI { Action C requires a similar 1 hour action but only when that Function has lost RPS trip capability. For a typical 2-channels per trip system Function, the loss of function will occur with two channels in the trip system inoperable and there is no difference in the CTS and ITS Actions. However. for the IRi. ' unction, and for the MSIV and TSV closure Functions, RP5 Function may not be lost with two or more channels in one trip system inoperable. In these cases, the ITS provides additional flexibility in allowing up to 12' hours prior to tripping the channel or trip system.
- CTS 3.3.1 Action a.2 requires commencing the " shutdown" actions specified in CTS Table 3.3.1-1 in 6 hours with one inoperable channel in one trip system, when tripping that channel would result in a reactor scram. ITS 3.3.1.1 Action A allows 12 hours for any inoperable channel regardless of the effect of tripping that channel. And, if it is desired to not trip the channel (as would be the case if tripping would result in a scram), ITS (based on the requirement for " multiple condition [
entry") would assure the appropriate shutdown action is applied.
. ' CTS 3.3.1 Action b requires placing one trip system in trip @
within 1 hour (see L.2 below for discussion of extension of 1 this 1 hour) when both trip systems have inoperable channel (s): $ and furthermore, requires commencing the " shutdown" actions specified in CTS Table 3.3.1-1 within the same hour. For this condition, ITS 3.3.1.1 Action A would continue to apply to any
)
remaining untripped channels: thereby allowing 12 hours to trip the other trip system or associated channels. prior to commencing " shutdown" actions. V l These increased allowed Completion Times are consistent with the
- allowed outage times reviewed and approved in NED0 30851 P A,
" Technical Specification Improvement Analyses for BWR Reactor Protection System " March 1988, and are considered appropriate based on the remaining capability to trip, the diversity of the sensors available to provide the trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the l
)
FERMI - UNIT 2 11 REVISION 6, 05/28/99l
1 DISCUSSION OF CHANGES i ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION initiation of a scram. Since a loss of trip function continues to require immediate (1 hour) restoration (ITS Action C), this extension will not adversely affect safety. LR.1 CTS Table 3.3.1-1 Action 9 requirement that the reactor mode I switch be locked in the shutdown position is removed from { Technical Specifications. This change is consistent with NUREG-1433. The requirement to fully insert all insertable control rods ) I remains as IT:i, 3.3.1.1 Action I. Regulatory control of changes to l this requirement (e.g., Technical Specification amendment or 10 I CFR 50.59) is not necessary to provide adequate protection of the public health and safety since the requirement for all control rods to remain inserted continues to be maintained in the Technical Specifications. LR.2 Not used. W l LR.3 CTS Table 4.3.1.1-1, footnote (b) for Functions 1 and 2 (IRMs and APRMs), requires that the Channel Functional Test for these functions include verification that instrument indication overlaps (SRM to IRM and IRM to APRM) for at least 1/2 decade. ITS SR 3.3.1.1.6 and SR 3.3.1.1.7 require verification of IRM and APRM instrument indication overlap: but an acceptance criteria is not specified. The acceptance criteria is removed from the Technical Specifications, consistent with NUREG 1433. Regulatory control of changes to this requirement (e.9/. Technical Specification 1 amendment or 10 CFR 50.59) is not necessary to provide adequate l protection of the public health and safety since: 1) the l requirement to verify overlap is maintained: 2) overlap is ' verified if both instruments (SRM and IRM or IRM and APRM) are onscale and tracking changes in neutron flux levels: 3) neutron < monitoring channels sufficient to tolerate a single failure are required to be available; and 4)'once verified to be onscale. l comparison of the response of the multiple IRM and APRM channels that are available provides indication that neutron monitoring instrumentation is functioning properly. This change has no l impact on safety.
l DISCUSSION OF CHANGES ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION Switch Shutdown position control rod withdrawal block (ITS LC0 0 3.3.2.1) will not allow any control rod to be withdrawn, and I. require insertion of any withdrawn control rod, in Mode 3 or 4. Special Operations LC0 3.10.3 and LCO 3.10.4 will allow a single 4 l control rod to be withdrawn while in Mode 3 or 4 by allowing the Reactor Mode Switch to be in the Refuel position. However, separate requirements are established within these LCOs for RPS j functions and associated Required Actions for inoperable RPS l functions. Therefore, this change has no impact on safety because appropriate requirements for RPS scram functions are still required whenever control rod (s) are withdrawn. L.4 CTS Tables 3.3.1 1 and 4.3.1.1-1 require Operability and testing of Functions 1.a (IRM Flux High).1.b (IRM Inop) 11 (Reactor mode Switch Shutdown Position) and 12 (Manual) in all of Mode 5: and Functions 8.a and 8.b in Mode 5 with control rods withdrawn from n any cell (CTS footnote (i) to Table 3.3.1-1 and footnote (j) to T Table 4.3.1.1 1). ITS Table 3.3.1.1 1 limits the required Operability of these Functions in Mode 5 to only when "any control y rod withdrawn from a core cell containing one or more fuel j assemblies." Additionally. CTS Table 3.3.1-1 Actions 3 and 9 for inoperable RPS Functions in Mode 5 require inserting all insertable control rods. ITS 3.3.1.1 Action I requires insertion of control rods only in those cells containing one or more fuel i assemblies. The purpose of these RPS Functions is to I automatically initiate insertion of control rods in response to situations where rapid insertion of negative reactivity may be required. Inserting control rods in control rod cells that do not j contain fuel assemblies has a negligible impact on core l reactivity. If a control rod will not insert any appreciable i negative reactivity into the reactor, automatic insertion I capability serves no safety function. Therefore, if all control ! rods in fueled cells are inserted in Mode 5. the safety action of i the RPS function is already satisfied and RPS Operability is not { necessary. There is no required safety function for automatic l control rod insertion capability in this condition. and ' eliminating its requirement will have no impact on safety. 1 _r' FERMI UNIT 2 14 REVISION 6. 05/28/99l
RPS Instrumentation
- 3. 3.1.1 3.3 INSTRUMENTATION 3
3.3.1.1 Reactor Protection System (RPS) Instrumentation LCO 3.3.1.1 The RPS instrumentation for each Function in Table 3.3.1.1-1 f5'. B . l shall be OPERABLE. APPLICABILITY: According to Table 3.3.1.1-1. ACTIONS
-NOTE-- --- - - ------ --
. fI.$" "b_$_ $. ** ." '""* . __. . ...
CONDITION REdUIREDACTION COMPLETION TIME I A. One or more required A.1 Place channel in 12 hours //c/,js a,z.o,3; channels inoperable. trip. b4C2. Op,l ( [NoF _~_ . Nok affircahte E for r fund 1rn 2A;7b;1% A.2 Place associated trip 12 hours g/ system in trip. QQ2., , ; _ , _,, __ _ T j 6.e4nak .A > B.40ne or more functions B.1 Place channel in one 6 hours b) with one or more trip system in trip. "5 required channels + inoperable in both E trip systems. B.2 Place'one trip system 6 hours in trip. d C. One or more Functions C.1 Restore RPS trip I hour Ah,3 a.)0 . with RPS trip capability. I capability not g0 q - maintained. k (continued) BWR/4 STS 3.3-1 Rev 1, 04/07/95 1 l 1 l
RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY l SR 3.3.1.1.5 Perform CHANNEL FUNCTIONAL TEST. 7 days ,3 hl- 1) 1 SR 3.3.1.1.6 Verify the source range monitor (SRM) and intermediate range monitor (IRM) channels PriortohM withdrawing overlap. SRMs from the f.5 fully
,m ' r-ted SR 3.3.1.1.7 ----- --
NOTE----------------- Only required to be met during entry into MODE 2 from MODE 1. ______________ Verify the IRM and APRM channels overlap. 7 days TO SR 3.3.1.1.8 Calibrate the local power range monitors. 1000 MWD /T 4 average core g exposure y SR 3.3.1.1.9 Perform CHANNEL FUNCTIONAL TEST. g,,92gdays SR 3.3.1.1.10 b thetripunity g92ydays % p - (continued) BWR/4 STS 3.3-4 Rev 1, 04/07/95 \
p i(t.Q ** RPS Instrumentation ggy Dg 3.3.1.1 o A>L'l Q.\ table 3.3.1.1 1 (pese 1 of 3) aeector Protection system Instrumentation F"vM t170 M CT5 43 Chost. AEF ol V""W APPLICA8LE CONotfl0Ns V # 8 3 /-/ se0 Dis OR ofutt afeUlttp at FtttMCD CnAmstLs Fa0M g SPECIP!tD PER TRIP Rt0UlttD SURVEILLANCE ALLOWASLE 2
- 2
FUNCTION Co m !T!0us SYSTEM ACTION D.1 steulatMENTs &
- 1. Interandlete targe 2 G sa 3.3.1.1.1 5 G..n/..L,25
.7/
Ieonitors sa 3.3.1.1.4 divisions of I'3-). b 4
=*=y sa 3.3.1.1.6 futt scate
- a. boutron Flut = Nigh s2 3.3.1.1.7 1 2'l~II !
3.3.1.1.Sh st
)
SR 3.3.1.1.15 igg /, 5(e) sa 3.3.1.1.1 s se 3.3.1.1.5 divisions of SR 3.3.1.1 futi scale , sa 3.3.1.1.15
' "" ' ' " a 3.3 H , a 5(s)
@ !:!:i:i:t5 sa 3.3.1.1.5 NA sa 3.3. . 5 e
- 2. Averose Power a monitors gg p.;:::)"Mg
=
hq
= =
H!:m = Fw =" SR 3.3.1.1.7
@.Q b st 3.3.1.1.8 sa 3.3.1.1. _
34 3.3.1.1.
.e<W=aw)+u a %
- b. tavus44Msinut oted 1 ?.!.:.t.. s Thernst Pouer ={ M F
j ; st3.3.1.1.2 + tt)E RTP and [,h p scal 360 a 3.3.i.1.3 sa 3.3.1.1.8 s m5. afp(b)g
-se--LL : . . .n
= H ! !.edD
= > r +r@
(continued) (a) With any contret red withdrain from a core cell containing one or more fuel essenbtles. (b;'-
~^ g""" en es{for single loop operation per LCO 3.4.1,
- Recirculation Loops ,
-3{CA W= s% . osvalu. d W = o /. .
(e) Each MRM ckonni WiYes inPds k bo"Ik hi$ Syshn3'
. a (F.Motck)
BWR/4 STS 3.3-7 Rev 1, 04/07/95 l
)
RPS Instrumentation B 3.3.1.1 INSERT B 3.3.1.1 7 There is no Allowable Value for the Turbine Control Valve Fast Closure Function since the channels are actuated solely on de energization of the solenoid dump valve. l l FERMI - UNIT 2 B 3.3-19 (Insert) REVISION 6. 05/28/99l
RPS Instrumentation B 3.3.1.1 l BASES SURVEILLANCE SR 3.3.1.1.3 (continued) REQUIRENENTS accurately eflects the requir d setpoint as a nction of ) flow. Ea flow si nal from he respective f1 unit must ! be s 105 of the ca ibrated low signal. If he flow unit l signal s not within the l' it, one require APRM that f,j receiv s an input from t deci ed inoperable. inoperable flow nit cust be , I Th Frequency of 7 da is based on en neering judg t,
'op rating experience /and the reliabil ty of this strumentation. _
SR 3.3.1.1.4
,d. A CHANNEL FUNCTIONAL TEST is performed on each required
~/37F-7o r channel to ensure that the entire channel will perfom the g7 intended functionyw' Any setpoint adjustment shall be consister)t with the assumptions of the current plant specific setpoint mett.o1 ology.
As noted, SR 3.3.1.1.4 is not required to be performed when entering MODE _2 fram MODE 1, since testing of the MODE 2 i required IRM(ar6APRiffunctions cannot be performed in MODE 1 without utt11 zing jumpers, lifted leads, or movable links. This allows entry into MODE 2 if the 7 day Frequency is not met per SR 3.0.2. In this event, the SR sust be performed within 12 hours after entering MODE 2 from MODE 1. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR. A Frequency of 7 days provides an acceptable level of system average unavailability over the Frequency interval and is based on reliability analysis (Ref. 9). SR 3.3.1.1.5
~
I 2 g, A CHANNEL FUNCTIONAL TEST is performed on each required 37F Mf channel to ensure that the entire channel will perforin the 1
/A/SM O -
intended function #A Frequency of 7 days provides an acceptable level of system average availability over the h (continued) ; BWR/4 STS B 3.3-27 Rev 1, 04/07/95 REV (O i i
RPS Instrumentation B 3.3.1.1 INSERT: TSTF-205 l INSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the ! other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applic Ele extensions. INSERT B A successful test of the required contact (s) of a channel relay may be performed by the ver,1fication of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the oti)er required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. In accordance with Reference 9, the scram contactors must be tested as part of the Manual Scram Function. 4 i i l FERMI UNIT 2 B 3.3 27 (Insert) REVISION 6, 05/28/99l
i RPS Instrumentation B 3.3.1.1 BASES SR 3.3.1.1.5 (continued g g g Frequency and is based on th: r;? eti? ity ....;,, ,, .T
. R:':r;;..; M. (The Manual Scram Function's CHANNEL FUNCTIONAL TEST Frequency was credited in thefiinalysis tot kgg q j j
extend many automatic scram Functions' Frequencies.) - l SR 3.3.1.1.6 and SR 3.3.1.1.7 These Surys!11ances are established to ensure that no gaps in neutron flux indication exist from suberitical to power operation for monitoring core reactivity status. The overlap between SRMs and IRMs is required to be e demonstrated to ensure that reactor power will not be
- increased into a neutron flux region without adecuate t4k indication. This is required prior to6tithdrawing 5RMs from OP.5 the fully e::rt;c p::it er. since indication is being transitioned from t s to the IRMs.
Cort . The overlap between RMs and APRMs is of concern when reducing power into the IRM range. On power increases, the system design will prevent further increases (by initiating a rod block) if adequate overlap is not tained. Overlap between IRMs and APRMs exists when su' t IRMs and APRMs concurrently have onscale readings suu. ont the transition between MODE I and MODE 2 can be made wit.hout either APRM downscale rod block, or IRM upscale rod block. Overlap g % between SRMs and IRMs similarly exists when, prior to withdrawing the SRMs from the fully ir..erted yv.ii.ivu, IRMs d d de are above C : R gQ upscale rod bloc [.?"on range 1 before SRMs have reach _ed% _ _ (P JibeQ Mock.4Ad 6how As noted, SR 3.3.1.1.7 is only required to be met during IggO FMg entry into MODE 2 from MODE 1. That is, after the overI4p requirement has been met and indication has transitioned to E the IRMs, maintaining overlap is not required (APRMs may be - reading downscale once in MODE 2). - to N If overlap for a group of channels is not demonstrated 1 (e.g., IRM/APRM overlap), the reason for the failure of the T Surveillance should be determined and the appropriate T channel (s) declared inoperable. Only those appropriate v channels that are required in_the current MODE or condition i should be declared inoperable. (continued) BWR/t STS B 3.3-28 Rev 1, 04/07/95 REV' fp
RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.6 and SR 3.3.1.1.7 (continued) REQUIREMENTS l A Frequency of 7 days is reasonable based on engineering judgment and the reliability of the IRMs and APRMs. SR 3.3.1.1.8 LPRM gain settings are detemined from the local flux profiles measured by the Traversing Incore Probe (TIP) System. This establishes the relative local flux profile for appropriate representative input to the APRM Systa.r. The 1000 MWD / requency is based on operating experience M f.9 with LPRM sen es. i shoe 1" b SR 3.3.1.1.9andSRI.3.1.1 A CHANNEL FUNCTIONAL TEST is performed on each required I channel to ensure that the entire cilannel will perform the WI *M intended function.f Any setpoint ad;}ustment shall be lb l M scr&T (N J consistent with the assuuptions of the current plant specific setpoint methodology. The 92 day Frequency of SR 3.3.1.1.9 is based on the reliability analysis of Reference 9. The 18 month Frequency is based on the need to perform this
, Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. '
Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. This DNeillancL) Op,3 diMtba ef tM p rit / provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.1.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel perfomance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be (continued) BWR/4 STS B 3.3-29 Rev 1, 04/07/95 e psv 6
RPS Instrumentation B 3.3.1.1 INSERT: TSTF-205 INSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. l l 7 FERMI UNIT 2 B 3.3 29 (Insert) REVISION 6. 05/28/99l
)
s RPS Instrumentation l B 3.3.1.1 , l BASES j l SURVEILLANCE SR 3.3.1.1.10 (continued) REQUIREMENTS 3 readjusted to be equal to or more conservative than j accounted for in the appropriate setpoint methodology. ' The Frequency of 92 days is based on the reliability analysis of Reference 9. ! 14 SR 3.3.1.1.11 and SR S.3.1.1. A CHANNEL CALIBRATION is a complete check of the instrument I loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. l 6R 3.3.1.l. Il- a Note I states that neutron detectors are excluded from s l CHANNEL CALIBRATION because they are passive devices, with minimal drift, and because of the difficulty of simulating a meaningful signal. Changes in neutron detector sensitivity ' PS are compensated for by perfoming the 7 day calorimetric l P.l calibration (SR 3.3.1.1.2) and the 1000 MWD SR 3.3.LI.8). /T LPRM M":t: gy,gt,(,Il_ calibration against is provided that the TIPS requires the (En .4IRM SRMto be
^ ::::n?
gg performed within 12 hqurs of ehtering MODE 'Yrom MODE 1. Testing of the MODE 2 \ApR8. antr]IRM Function cannot be l performed in MODE 1 without utilizing jump rs, lifted leads, ) or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. l Twelve hours is based on operating experience and in ' consideration of providing a reasonable time in which to complete the SR. The Frequency of SR 3.3.1.1.11 is based upon th: :.;;r;t hn I bt17 se6 a 184 day calibration interval in the determination of {
.the magnitude The Frequency of of SRequipment 3.3.1.1 d@
is rift inupon based the Wsetpoint . analysis.
- r;t':n
-e6(QD18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
,l I bl5&g-T
.fJ / /-// '
(continued) BWR/4 STS B 3.3-30 Rev 1, 04/07/95 !
RPS Instrumentation B 3.3.1.1 INSERT B 3.3.1.1-14 j l SR 3.3.1.1.12 { A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended n function. For the APRM Functions, this test supplements the d automatic self-test functions that operate continuously in the @ APRM and voter channels. The APRM CHANNEL FUNCTIONAL TEST covers oc the APRM channels (including for Function 2.b only, the V recirculation flow input function excluding the flow ) transmitter), the 2 out of 4 voter channels, and the interface connections to the RPS trip systems from the voter channels. Any setpoint adjustment shall be consistent with the as'sumptions of the current plant specific setpoint methodology. The 184 day Frequency of SR 3.3.1.1.12 is based on the reliability analysis of Reference 13. (NOTE: The actual voting logic of the 2 out-of-4 voter channels is tested as part of SR 3.3.1.1.19.) For Function 2.a. a No'te that requires this SR to be performed within 12 hours of entering MODE 2 from HODE 1 is provided. Testing of the MODE 2 APRM Funct. ion cannot be performed in MODE 1 l without utilizing jumpers or lifted leads. This Note allows entry into MODE 2 from HODE 1 if the associated Frequency is not met per SR 3.0.2. 1 FERMI UNIT 2 B 3.3 30 (Insert) REVISION 6, 05/28/99l i
r l JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.1.1 RPS INSTRUMENTATION NON-BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent 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. Specifically, some of these changes are discussed below:
- a. The Channel Calibration requirements for the IRM RPS Function is indicated in the ISTS as SR 3.3.1.1.13 at 18 months. However.
the CTS Frequency for this calibration is "SA" (i.e.,184 days). In adopting the existing CTS requirement, the ISTS is modified to eliminate SR 3.3.1.1.13 and combine the IRM Channel Calibration requirement with SR 3.3.1.1.11. As such, the ISTS Note in SR 3.3.1.1.13 is deleted and its equivalent is added to ISTS SR 3.3.1.1.11. l7 3
- b. In accordance with Fermi CTS Amendment #122 (to incorporate the PRNM System), the ITS and Bases are modified utilizing NEDC-32410 b
as guidance. P.2 Bases changes are made to reflect plant specific design details. equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for additional detail. P.4 Change made for editorial preference or clarity. Specifically, m one change adds Bases for " MWD /T" to clarify "short" ton versus L metric ton. l$ l t i FERMI UNIT 2 1 REVISION 6, 05/28/99l
JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.1.1 - RPS INSTRUMENTATION .
)
l P.5 ITS SR 3.3.1.1.6 is established to ensure that no gaps in neutron flux indication exist from subtritical to power operation. NUREG- ! 1433 stipulated that SRMs must remain full-in until IRM indication had overlapped with SRMs. CTS requirements simply require that ; overlap exist. Since the SRMs are inserted to approximately 2/3 l core height. withdrawal of the SRMs can be made while still maintaining neutron flux indication, and overlap can be i established with the SRMs partially withdrawn. At Fermi 2, SRM ! indication can be upscale (initiating a rod block and potentially reaching offscale reading) prior to IRM overlap (i.e., onscale reading). Therefore consistent with CTS requirements. SR q 3.3.1.1.6 is revised to only require SRM/IRM overlap prior to !
" fully withdrawing SRMs from the core."
P.6 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
I P.7 Change made for presentation preference to eliminate ISTS Table B 3.3.1.11, which only summarizes background information that is unrelated to the ITS RPS requirements. This information is adequately available in other docaments. The remaining Bases provide sufficient information for these ITS. GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG 1433. l
- l l
/ j FERMI UNIT 2 2 REVISION 6. 05/28/99l
SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE REQUIREMENTS (continued) sufficient irradiated fuel assemblies, to establish the minimum count rate. To accomplish this, the SR is modified by a Note that states that the count rate is not required to be met on an SRM that has less than or equal to four fuel assemblies adjacent to the SRM and no other fuel assemblies are in the associated core quadrant. With four or less fuel assemblies loaded around each SRM and no other fuel assemblies in the associated core quadrant, even with a control rod withdrawn, the configuration will not be critical. The Frequency is based upon channel redundancy and other
~information available in the control room, and ensures that the required channels are frequently monitored while core reactivity changes are occurring. When no reactivity changes are in )rogress, the Frequency is relaxed from 12 hours to 24 1ours.
SR 3.3.1.2.5 and SR 3.3.1.2.6 Performance of a CHANNEL FUNCTIONAL TEST demonstrates the associated channel will function properly. A successful test of the. required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. SR 3.3.1.2.5 is required in MODE 5. and the 7 day Frequency ensures that the channels are OPERABLE while core reactivity changes could be in progress. This Frequency is reasonable, based on operating experience and on other Surve111ances (such as a CHANNEL CHECK). that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. SR 3.3.1.2.6 is required in MODE 2 with IRMs on Range 2 or below, and in MODES 3 and 4. Since core reactivity changes do not normally take place in MODES 3 and 4. and since core l reactivity changes in H0DE 2 are typically due to control ; rod movement, the Frequency has been extended from 7 days to 31 days. The 31 day Frequency is based on operating experience and on other Surveillances (such as CHANNEL l FERMI UNIT 2 B 3.3.1.2 - 7 Revision 6. 05/28/99
SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE REQUIREMENTS (continued). . CHECK) that ensure proper functioning between CHANNEL l FUNCTIONAL TESTS. Verification of the signal to noise ratio also ensures that the detectors are inserted to an acceptable operating level. In a fully withdrawn condition, the detectors are sufficiently removed from the fueled region of the core to essentially eliminate neutrons from reaching the detector. Any count rate obtained while the detectors are fully withdrawn is assumed to be " noise" only. The Note to j SR 3.3.1.2.5 and Note 1 to SR 3.3.1.2.6 modify this j requirement to not require the signal to-noise ratio to be ! determined when the associated SRM count rate is a 3.0 cps. This is acceptable since there is no limitation on signal-to-noise ratio when the SRM is a 3.0 cps. The Note 2 to SR 3.3.1.2.6 allows the Survei.llance to be delayed until entry into the specified condition of the Applicability (THERMAL POWER decreased to IRM Range 2 or below). The SR must be performed within 12 hours after-IRMs are on Range 2 or below.- The allowance to enter the Applicability with the 31 day Frequency not met is reasonable, based on the limited time of 12 hours allowed after entering.the Applicability and the desire not to , s perform the Surveillance while at higher power levels. t /Jthough the Surveillance could be performed while on IRM Range 3. the plant would not be expected to maintain steady state operation at this power level. In this event, the 12 hour Frequency is reasonable. based on the SRMs being l otherwise verified to be OPERABLE (i.e.. satisfactorily performing the CHANNEL CHECK) and the time required to perform the Surveillances. SR 3.3.1.2.7 Performance of a CHANNEL. CALIBRATION at a Frequency of 18 months verifies the performance of the SRM associated circuitry. The Frequency considers the plant conditions required to perform the test. the ease of performing the test, and the likelihood of a change in the system or component status. The neutron detectors are excluded from the CHANNEL-CALIBRATION because they cannot readily be adjusted. The detectors are fission chambers that are designed to have a relatively constant sensitivity over the range and with an accuracy specified for a fixed useful life. l FERMI UNIT 2 B 3.3.1.2 - 8 Revision 6. 05/28/99
SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE REQUIREMENTS (continued) Note 2 to the Surveillance allows the Surveillance to be delayed until entry into the specified condition of the Applicability. If not performed within the previous 18 months (plus 25% allowed by SR 3.0.2), the SR must be performed within 12 hours of entering MODE 2 with IRMs on Range 2 or below. 11N2 allowance to enter the Applicability with the 18 month Frequency not met is reasonable, based on the limited time of 12 hours allowed after entering the A)plicability and the desire not to perform the Surveillance w111e at higher power levels. Although the Surveillance 's could be performed while on IRM Range 3. the plant would not I be expected to maintain steady state operation at this oower Q leve]. In this event, the 12 hour Frequency is reasonable. based on the SRMs being otherwise verified to be OPERABLE (i.e.. satisfactorily performing the CHANNEL CHECK) and the time required to perform the Surveillances. PEFERENCES None. 1 I l FERMI UNIT 2 B 3.3.1.2 - 9 Revision 6 05/28/99
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.2 - SRM INSTRUMENTATION LB.1 CTS 4.3.7.6.b.1 requires performing an SRM Channel Functional Test "within 24 hours prior to moving the reactor mode switch from the l shutdown position if not performed within the previous 7 days" for Mode 2 operation, as well as once per 31 days during all of Mode 2. CTS 4.9.2.b.1 requires performing an SRM Channel Functional Test "within 24 hours prior to the start of Core j Alterations." as well as once per 7 days during all of Mode 5. ITS eliminates the requirement that verifications be performed within a brief period " prior to" an event (e.g. moving the mode switch or the start of Core Alterations). This will allow the I verifications to be performed at their normal Frequency prior to reactor startup or any Core Alteration. This change is acceptable because the Operability requirement for SRMs is unchanged. Elimination of the requirement to perform this test within a short time prior to the activity is not significant because the normal i periodic Surveillance Frequency is established to provide adequate . assurance that SRMs are Operable. If any SRM Surve.illance has not l been performed within its required interval, moving the mode l switch or Core Alterations may not be performed. This ensures the requirements are adequately checked prior to and during these activities. - I
'LR.1 CTS 4.3.7.6.c. 3.9.2. and 4.9.2.a.2 require the SRMs be positioned l
" fully inserted" and " inserted to the normal operating level."
These details of plant operation are removed from the Technical Specifications. The SRM design includes alarm and control rod block functions when SRM detectors are not properly inserted. Proper insertion included being maintained fully inserted until SRM count rate exceeds 100 cps (which is not expected during the majority of Mode 3. 4. or 5 operations). Furthermore. ITS y SR 3.3.1.2.4 requires a signal to noise ratio that ensures that i SRMs are sufficiently inserted to respond to neutron level in the Tt core. Regulatory control of changes to this requirement (e.g., T Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and safety since the requirement for SRM Operability is maintained in the ITS. l w FERMI UNIT 2 4 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.2 SRM INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE
Speci fi c" L.1 CTS 3.3.7.6 requires three Operable SRM channels while in Mode 2 with IRMs in Range 2 or below. If one of the three required SRM channels is inoperable CTS 3.3.7.6, Action'a, allows 4 hours to restore at least three Operable SRM channels. If the required SRMs are not restored within 4 hours or if more than one of the three required SRM channels is inoperable, CTS 3.3.7.6 defaults to CTS-LCO 3.0.3 and requires that.the plant be in Mode 3 within 13 hours. Under the same conditions, ITS 3.3.1.2 Action A allows all three required SRM channels to be inoperable for up to 4 hours prior to requiring a plant shutdown (per ITS 3.3.1.2 Action C);
but precludes control rod withdrawal (per ITS 3.3.1.2 Action B). Provided one (instead of two as required by CTS) of the three required SRM channels is Operable, control rod withdrawal may continue during this 4 hour period (ITS Action B is not entered). This may permit proceeding to IRM Range 3 or greater (with SRM/IRM overlap required by SR 3.3.1.1.6), and thereby exiting the Applicability of this LCO.
-This change allows: 1) all three required SRM channels to be inoperable for up to 4 hours before a shutdown is required, and 2) control rod withdrawals to proceed with only one of the three required SRM channels Operable. The first of these changes (allowing 4 hours to restore when all three required SRM channels are inoperable) is acceptable because ITS Action B precludes reactivity additions by control rod withdrawal. This may allow repairs to one or more SRM channels, thereby precluding a reactor shutdown without neutron monitoring capability. The second change (allowing control rod withdrawals to proceed with only one of the three required SRM channels Operable) is acceptable because SRM channels normally provide no input to automatic safety systems and the rate of reactivity additions can be monitored and controlled even with a single Operable SRM channel. Additionally, there is
. limited risk of an event during the 4 hours and a reactor shutdown can be avoided by restoring the required SRMs to Operable status
~or increasing power to establish IRM monitoring capability.
Therefore, this change has no significant impact on safety. 1 FERMI UNIT 2 5 REVISION 6, 05/28/99
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.2 - SRM INSTRUMENTATION L.2 CTS 3.3.7.6. Action b. requires an operator to " lock" the reactor mode switch in the shutdown position if there are less than two Operable SRM channels when in Mode 3 or 4. The intent of locking the reactor mode switch is to prevent control rod withdrawal until the required number of SRM channels are Operable. Under the same conditions. ITS 3.3.1.2 requires all insertable control rods to be inserted and the reactor mode switch be placed in the shutdown l position, but does 'not require that it be locked. Adequate l protection of the public health and safety is maintained with the requirement for control rods to be inserted and the mode switch l to be in shutdown. With less than the required number of SRMs Operable, Technical Specification requirements will continue to prevent withdrawal of control rods until the required number of SRM channels are Operable. Therefore, this change has no impact on safety. L.3 CTS 4.3.7.6.b.2, SRM Channel Functional Test, and CTS 4.3.7.6.a.2. SRM Channel Calibration are required at all times during the required Applicability for SRM Operability. For these same tests. ITS SR 3.3.1.2.6 and 3.3.1.2.7 are modified by Note 2 stating that these SRs are not required to be performed until 12 hours after IRMs are on Range 2 or below. This change is acceptable for the following reasons: redundant SRM channels are available to monitor neutron level during a reactor shutdown: SRM response to reactivity changes are distinctive and are closely monitored allowing Operators to readily identify a potentially inoperable SRM channel: and. the SRMs are used to monitor neutron level only , and are not assumed to perform any automatic function during any l design basis accident or transient analysis. Therefore, this change has no impact on safety. L.4 CTS 3.9.2 and 4.9.2.a.3 require two Operable SRM channels in Mode 5 and if Core Alterations 'are in progress, then CTS further j requires "one of the required SRM detectors located in the i quadrant where CORE ALTERATIONS are being performed and the other i required SRM detector located in an adjacent quadrant." ITS 3.3.1.2 allows exceptions to the quadrant requirements when the associated or adjacent SRM is not within the " fueled region" (ITS SR 3.3.1.2.2 b and c). Furthermore, ITS SR 3.3.1.2.2 Note 2 l and Table 3.3.1.2 1 Note (b) allows only one SRM to be required Operable if spiral reload patterns are being implemented during the time the fueled region has spiraled to include only a single SRM detector. FERMI - UNIT 2 6 REVISION 6. 05/28/99lh
DISCUSSION OF CHANGES ITS: SECTION 3.3.1.2 SRM INSTRUMENTATION The change that limits the requirement for an Operable SRM to one ; located in a fueled region removes requirements for SRMs that can I not adequately respond to core reactivity changes since they are located beyond the fueled region. This also ensures that an SRM is not utilized to meet LC0 requirements if it is located in a region where it may be incapable of responding to changes in neutron level. , The change that requires only one SRM channel to be Operable during spiral offload or reload when the fueled region includes only that SRM detector is acceptable because of the following: SRMs are used to monitor neutron level and have no safety function and are not assumed to function to prevent or mitigate any postulated event: a single SRM detector adequately monitors neutron level as long there is a single contiguous fueled region (i.e., spiral loading or unloading is performed); and. SRM detectors located in an adjacent quadrant but outside the fueled region do not provide reliable indication of changes in neutron levels. Therefore, this change has no impact on safety. l L.5 CTS 3.9.2 Action requires all insertable control rods to be ' inserted when in Mode 5 when the number of Operable SRM channels is less thari required. ITS 3.3.1.2, Required Action E.2, requires inserting control rods only in core cells "containing one or more fuel assemblies." This change is needed because refueling pr6cedures could have cells empti'ed with control rods withdrawn but insertable. However, due to a variety of considerations I (e.g., location of blade guides, ongoing maintenance, etc.), it may not be desirable to insert these control rods. Inserting a control rod has a negligible impact on core reactivity if all fuel assemblies are removed from the associated core cell. The ITS continues to require all cells containing one or more fuel p assemblies to have its control rod inserted. This continues to ,L ensure adequate SDM. Therefore, this change has no impact on safety because there is no impact on SDM when a control rod is { allowed to remain withdrawn in the cell with no fuel. l FERMI UNIT 2 7 REVISION 6. 05/28/99l
l DISCUSSION OF CHANGES ITS: SECTION 3.3.1.2 SRM INSTRUMENTATION L.6 CTS 3.9.2 footnote
- restricts the use of special movable detectors in place of SRMs to "during CORE ALTERATIONS." The ITS provides the allowance for special movable detectors during all of Mode 5. The SRMs are used to only to monitor neutron level. They have no safety function and are not assumed to function to prevent or to mitigate any postulated event. In Mode 5 at times other 7 than during Core Alterations, the function of the SRMs is even 2 less critical. Therefore, since special movable detector use is <
acceptable, and allowed by CTS during more risk significant operations (i.e. during Core Alterations), their use for routine monitoring is also acceptable. RELOCATED SPECIFICATI0E None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.3.1.2 consistent with the BWR STS. NUREG 1433. Rev. 1. - 4 FERMI UNIT 2 8 REVISION 6. 05/28/99l
)
SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE SR 3.3.1.2.4 , REQUIREMENTS (continued) This Surveillance consists of a verification of the SRM instrument readout to ensure that the SRM reading is greater i than a specified minimum count rate, which ensures that the detectors are indicating count rates indicative of neutron l flux levels within the core. With few fuel assemblies 4 loaded, the S'RMs will not have a high enough count rate to l satisfy the SR. Therefore, allowances are made for loading j Op.y sufficient x= =tum, i:; tr.; ';. ;' irradiated fue1 . assemblies, to establish the minimum count rate. To a~ omplish this, the SR is modified by a Note that states , that the count rate is not required to be met on an SRM that i has less than or equal to four fuel assemblies adjacent to '
~
the SRM and no other fuel assemblies are in the associated core quadrant. With four or less fuel assemblies loaded around each SRM and no other fuel assemblies in the i associated core quadrant, even with a control rod withdrawn, l the configuration will not be critical. l The Frequency is based upon channel redundancy and other information available in the control room, and ensures that
)
the required channels are frequently monitored while core E reactivity changes are occurring. When no reactivity changes are in progress, the frequency is relaxed from 12 hours to 24 hours. i SR 3.3.1.2.5 and SR 3.3.1.2.6 m f37F ,'205' - Performance of a CJiANNEL FUNCTIONAL TEST demonstrates the associated channel will function properly./ SR 3.3.1.2.5 is JNS6RT 4 I required in MODE 5, and the 1 day Frequency ensures that the 4 channels are OPERABLE while core reactivity changes could be in progress. This Frequency is reasonable, based on operating experience and on other Surveillances (such as a CHANNEL CHECK), that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. SR 3.3.1.2.6 is required in MODE 2 with IRMs on Range 2 or below, and in MODES 3 and 4. Since core reactivity changes
/4 Nove$ 3 AND f> AMP do not normally take placeA the Frequency has been extendeh from 7 days to 31 days. The 31 day Frequency is based on c operating experience and on other Surveillances (such as G el Moog f.A4g q TV7/CAU.Y DVB 70 cc^!TleL. f AM MOVEMEAJ5 /
(continued) BWR/4 STS B 3.3-41 Rev 1, 04/07/95 I k
r SRM Instrumentation B 3.3.1.2 Insert B 3.3.1.2-2 INSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. i FERMI - UNIT 2 Page B 3.3 41 (Insert) REVISION 6 05/28/99l
SRM Instrumentation B 3.3.1.2 BASES SURVEILLANCE SR 3.3.1.2.5 and SR 3.3.1.2.6 (continued) REQUIREMENTS . CHANNEL CHECK) that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Op,\ Verification of the signal to noise ratio also ensures that the detectors arc inserted to an acceptable operating level. f_lDN7 In a fully withdrawn condition, the detectors are sufficiently removed from the fueled region of the core to g y*3,/,2-/J essentially eliminate neutrons from reaching the detector. j N Any count rate obtained while the detectors are fully M ithdrawn is assumed to be " noise" only.g g k $U. 9.l. 2.(, The Note /a th; % rveiller,;; allows the Surveillance to be delayed until entry into the specified condition of the Applicability (THERMAL POWER decreased to IRM Range 2 or below). The SR must be performed within 12 hours after IRMs are on Range 2 or below. The allowance to enter the Applicability with the 31 day Frequency not met is reasonable, based on the limited time of 12 aours allowed de5Iro -+after performentering the Applicability the Surveillance .andpower while at higher the P"itit; levels.J OP.5 00+ +of Although the Surveillance could be performed while on IRM ; Range 3, the plant would not be expected to maintain steady R state operation at this power level, in this event, the 12 hour Frequency is reasonable, based on the SRMs being otherwise verified to be OPERABLE (i.e., satisfa;torily performing the CHANNEL CHECK) and the time requittd to l perform the Surveillances. SR 3.3.1.2.7 Performance of a CHANNEL CALIBRATION at a Frequency of l
. 18 months verifies the performance of the SRM det;;ter; ;r.d ( l associated circuitry. The Frequency considers the plant conditions required to perform the test, the ease of performing the test, and the likelihood of a change in the system or component status. The neutron detectors are excluded from the CHANNEL CALIBRATION because they cannot readily be adjusted. The detectors are fission chambers that are designed to have a relatively constant sensitivity over the range and with an accuracy specified for a fixed useful life.
(continued) l BWR/4 STS B 3.3-42 Rev 1, 04/07/95 l l i
SRM Instrumentation B 3.3.1.2 BASES Mitof pubw d u>itNn 4 ha pr<vioo$),4h fCorulhS (pla 2f_'I. ollowed by SR ?.o.1 SURVEILLANCE SR 3.3.1.2.7 (continued) REQUIREMENTS Note 2 to the Surveillance allows the Surveillance to be delayed untill entr f,q Applicability % y into the specified SR must be performedcondition of the 4W:310DE:3 within 12 hours of entering MODE 2 with IRMs on Range 2 or below. The allowance to enter the Applicability with the 18 month Frequency not met is reasonable, based on the limited time Qg,yt. got of 12 ka" G =;_ -Ed"@rs allowed afterthe entering the Applicability while at higherand the to perform levels. Although the Surveillance could be performed while Surveillance power y Op,3 on IRM Range 3, the plant would not >e expected to maintain steady state operation at this power level. In this event, the 12 hour Frequency is reasonable, based on the SRMs being otherwise verified to be OPERABLE (i.e., satisfactorily performing the CHANNEL CHECK) and the time required to
- perform the Surveillances.
REFERENCES None. , 1 1 BWR/4 STS B 3.3-43 Rev 1, 04/07/95 1
JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ' ITS: SECTION 3.3.1.2 SRM INSTRUMENTATION P.5 Procedures could be drafted such that SRM calibrations could be performed with the unit at power. Therefore the NUREG Bases statement regarding the " inability to perform" is revised to more accurately reflect the plant-specific " desire to not perform." Given the impact on the SRM detector at higher neutron flux levels ] (reduction in operational life due to burnout), and the offscale reading that would result (complicating test performance), there p is a justified desire to avoid testing above IRM range 2. Therefore the Bases are revised to clarify inaccurate statements regarding the prerequisites for SRM calibrations. GENERIC CHANGES g C.1 TSTF 205: NRC approved change to NUREG-1433. I e 4 FERMI UNIT 2 - 2 REVISION 6 05/28/99l 1
Control Rod Block Instrumentation 3.3.2.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1.1 Verify a 12 rods Immediately withdrawn. 08
. I C.2.1.2 Verify by Immediately administrative methods that startup with RWM inoperable has not been pg performed in the i
current calendar gg year. m During control C.2.2 Verify movement of rod movement control rods is in compliance with the prescribed withdrawal sequence by a second licensed operator or other qualified member of the technical staff. i D. RWM inoperable during D.1 Verify movement of During control I reactor shutdown. control rods is in rod movement accordance with the prescribed withdrawal sequence by a second licensed operator or other qualified ; member of the ' technical staff. i (continued) l FERMI UNIT 2 3.3-18 Revision 6, 05/28/99
Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E. One or more Reactor E.1 Sus)end control rod Immediately Mode Switch-Shutdown wit 1drawal . Position channels inoperable. ANQ
- '3- E.2 Initiate action to Immediately i fully insert all insertable control
($b rods in core cells containing one or more fuel assemblies. SURVEILLANCE REQUIREMENTS
..................................... NOTES -- -- - - --- - -- ----
- 1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function. .
- 2. When an RBM channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the associated Function maintains control rod block capability.
SURVEILLANCE FREQUENCY W l SR 3.3.2.1.1 - - -
- - - - - NOTE . - - - - - - - - - - -
Not required to be performed until 1 hour after any control rod is withdrawn at s 10% RTP in MODE 2. Perform CHANNEL FUNCTIONAL TEST. 92 days (continued) l FERMI - UNIT 2 3.3 19 Revision 6. 05/28/99
Control Rod Block Instrumentation 3.3.2.1 l SURVEILLANCE REQUIREMENTS (continued) ) SURVEILLANCE FREQUENCY l SR 3.3.2.1.2 ---- - --- -
-NOTE -- - ---------
1 Not required to be performed until 1 hour after THERMAL POWER is s 10% RTP in l MODE 1. l Perform CHANNEL FUNCTIONAL TEST. 92 days l SR 3.3.2.1.3 Perform CHANNEL FUNCTIONAL TEST. 184 days l SR 3.3.2.1.4 -- - -- --- NOTE-- - - --- - Not required to be performed until 1 hour after reactor mode switch is in the shutdown position. Perform CHANNEL FUNCTIONAL TEST. 18 months l SR 3.3.2.1.5 Verify the RBM is not bypassed when 24 months
. THERMAL POWER is = 30% RTP.
l I l SR 3.3.2.1.6 --- - ----
- NOTE -- --- -- -----
I Neutron detectors are excluded. J ( ......................................... Al Perform CHANNEL CALIBRATION. 24 months N kN SR 3.3.2.1.7 Verify control rod sequences input to the Prior to 1 y RWM are in conformance with the declaring RWM prescribed withdrawal sequence. OPERABLE 6 following loading of sequence into RWM l FERMI UNIT 2 3.3-20 Revision 6, 05/28/99
Control Rod Block Instrumentation 3.3.2.1 Table 3.3.2.1 1 (page 1 of 1) Control Rod Block Instrumentation APPLICABLE MODES OR OTHER
. SPECIFIED REQUIRED SLRVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS REQUIREMENTS VALUE
- 1. Rod Block Monitor m
4 a. Upscale (a) 2 SR 3.3.2.1.3 As specified in SR 3.3.2.1.5 the COLR h SR 3.3.2.1.6 Dl b. Inop (a) 2 SR 3.3.2.1.3 NA k c. Downscale (a) 2 SR 3,3.2.1.3 SR 3.3.2.1.6 As specified in the COLR
- 2. Rod Worth Minimizer 1(b) 2(b)
. 1 SR 3.3.2.1.1 NA SR 3.3.2.1.2 h SR 3.3.2.1.7 ,
N 3. Reactor Mode Switch- Shutdown Position (c) 2 SR 3.3.2.1.4 NA . i T I 2l (a) THERMAL POWER a 30% RTP. i (b) With THERMAL POWER s 101 RTP. i (c) Reactor mode switch in the shutdown position. 1 1 l l I FERMI UNIT 2 3.3-21 Revision 6. 05/28/99
l i l l Control Rod Block Instrumentation B 3.3.2.1 BASES ACTIONS (continued) D_1 With the RWM inoperable during a reactor shutdown, the operator is still capable of enforcing the prescribed control rod sequence. Required Action D.1 allows for the RWM Function to be performed manually and requires a double check of compliance with the prescribed rod sequence by a second licensed operator (Reactor Operator or Senior Reactor Operator) or other qualified member of the technical staff. The RWM may be bypassed under these conditions to allow the reactor shutdown to continut.. l E.1 and E.2 b With one Reactor Mode Switch-Shutdown Position control rod withdrawal block channel inoperable, the remaining OPERABLE channel is adequate to perform the control rod withdrawal block function. However, since the Required' Actions are consistent with the normal rod block action of an OPERABLE Reactor Mode Switch-Shutdown Position Function (i.e., p maintaining all control rods inserted), there is no g distinction between having one or two channels inoperable. , In both cases (one or both channels inoperable), suspending all control rod' withdrawal and initiating action to fully insert all insertable control rods in core cells containing one or more fuel assemblies will ensure that the core is subtritical with adequate SDM ensured by LCO 3.1.1. Control rods in core cells containing no fuel assemblies do not 0 affect the reactivity of the core and are therefore not required to be inserted. Action must continue until all insertable control rods in core cells containing one or more fuel assemblies are fully inserted. SURVEILLANCE As noted at the beginning of the SRs, the SRs for each REQUIREMENTS Control Rod Block instrumentation Function are found in the SRs column of Table 3.3.2.1-1. The Surveillances are modified by a Note to indicate that when an RBM channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the associated Function maintains control rod block capability. Upon completion of the s l FERMI UNIT 2 B 3.3.2.1 - 7 Revision 6 05/28/99
Control Rod Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued) Surveillance, or expiration of the 6 hour allowance. the channel must be returned to OPERABLE status or the b applicable Condition entered and Required Actions taken. 1l This Note is based on the reliability analysis (Ref. 8) 4 assumption of the average time required to aerform channel Surveillance. That analysis demonstrated tlat the 6 hour j testing allowance does not significantly reduce the l probability that a control rod block will be initiated when necessary. l SR 3.3.2.1.1 and SR 3.3.2.1.2 A CHANNEL FUNCTIONAL TEST is performed for the RWM to ensure f that the entire system will perform the intended function. l A successful test of the required contact (s) of a channel { relay may be performed by the verification of the change of I state of a single contact of the relay. This clarifies what j is an acce) table CHANNEL FUNCTIONAL TEST of'a relay. This 1 is accepta)le because all of the other required contacts of j the relay are verified by other Technical Specifications and i non Technical Specifications tests at least once 3er refueling interval with applicable extensions. T1e . SR 3.3.2.1.1 CHANNEL FUNCTIONAL TEST for the RWM is I performed by attempting to withdraw a control rod not in compliance with the prescribed sequence and verifying a selection error is indicated and a control rod block occurs. Control rod withdrawal sequences are normally established consistent with the rules of the generic BPWS analysis. Occasionally, operational limitations (e.g., power suppression of failed fuel) may dictate the insertion of control rods which do not meet the minimum cell separation criteria of the generic BPWS analysis. In such situations. I sufficient cycle s)ecific analyses are performed to ' demonstrate that t1e resulting control rod worths of the ?
- p modified control rod withdrawal sequence are bounded by the rod worths allowed by rigorously following the rules of the w generic BPWS analysis, thereby assuring that the 280 cal /gm fuel damage limit will not be violated during a CRDA.
The prescribed withdrawal secuence" is defined as the I combination of both the procecurally specified control rod l movement sequence and any analytically allowed deviations from this sequence. Some prescribed withdrawal sequences (e.g., BPWS) have more flexibility in allowed deviations than other prescribed withdrawal sequences (e.g., a cycle-l FERMI UNIT 2 B 3.3.2.1 - 8 Revision 6 05/28/99
Control Rod Block Instrumentation
' 3.3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued)
O specific sequence developed for power suppression of failed fuel may not allow any deviations), s SR 3.3.2.1.1 is performed during startup. As noted in the t SRs, SR 3.3.2.1.1 is not recuired to be performed until 2 1 hour after any control roc is withdrawn at s 10% RTP in D MODE 2. The SR 3.3.2.1.2 CHANNEL FUNCTIONAL TEST is performed by attempting to insert and withdraw a control rod , not in compliance with the prescribed sequence and verifying l a selection error is indicated and a control rod insert and withdraw block (respectively) occur. SR 3.3.2.1.2 is performed during a plant shutdown when transitioning to s 10t RTP. As noted, SR 3.3.2.1.2 is not required to be l performed until 1 hour after THERMAL POWER is s 10% RTP in ml MODE 1. This allows entry into MODE 2 for SR 3.3.2.1.1, and j 4 THERMAL POWER reduction to 5 10% RTP when in MODE 1 for SR gl 3.3.2.1.2. to perform the required Surveillance if the s 92 day Frequency is not met per SR 3.0.2. The 1 hour allowance is based on operating experience and in consideration of providing a reasonable time in which to in complete the SRs. The Frequencies are based on operating J. experience that shows the RWM usually passes the 4 Surveillance when performed at these Frequencies. l 1 l SR 3.3.2.1.3 j A CHANNEL FUNCTIONAL TEST is performed for each RBM channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a ' relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable , extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint h methodology. The Frequency of 184 days is based on ' E reliability analyses (Ref. 9). e l FERMI - UNIT 2 B 3.3.2.1 - 9 Revision 6 05/28/99 l 1
Control Rod Block Instrumentation B 3.3.2.1 BASES n SURVEILLANCE REQUIREMENTS (continued) e4 l SR 3.3.2.1.4 Y A CHANNEL FUNCTIONAL TEST is performed for the Reactor Mode Switch-Shutdown Position Function to ensure that the entire channel will perform the intended function. The CHANNEL FUNCTIONAL TEST for the Reactor Mode Switch-Shutdown Position Function is performed by attem) ting to withdraw any control rod with the reactor mode switc1 in the shutdown position and verifying a control rod block is present. As noted in the SR, the Surveillance is not required to be performed until I hour after the reactor mode switch is in the shutdown position, since testing of this interlock with ! the reactor mode switch in any other position cannot be i performed without using jumpers, lifted leads, or movable ) links. This allows entry into MODES 3 and 4 if the 18 month Frequency is not met per SR 3.0.2. The 1 hour allowance is based on operating experience and in consfderation of providing a reasonable time in which to complete the Srs. The 18 month Frequency is based on the need to perform this 1 Surveillance under the conditions that apply during a plant i outage and the potential for an un)lanned transient if the ! Surveillance.were performed with t1e reactor at power. 1 0)erating experience has shown these components usually pass tie Surveillance when performed at the 18 month Frequency. SR 3.3.2.1.5 - The power at which the RBM is automatically by)assed is based on the APRM signal's in)ut to each RBM clannel. Below the minimum )ower setpoint, tie RBM is automatically bypassed. T11s >ower Allowable Value must be verified periodically to )e less than 30% RTP. If this setpoint is nonconservative, then the affected RBM channel is considered inoperable. Alternatively, the power range channel can be 73 placed in the conservative condition (i.e.. enabling the RBM Function' If placed in this condition, the SR is met and Wl the RBF, nannel is not considered inoperable. The 24 month 4 Frequency is based on the actual trip setpoint methodology utilized for these channels. I FERMI UNIT 2 B 3.3.2.1 - 10 Revision 6 05/28/99
Control Rod Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued) m Nl SR 3.3.2.1.6 A CHANNEL CALIBRATION is a complete check of the instrument
' loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
As noted, neutron detectors are excluded from the CHANNEL CALIBRATION because they are passive devices, with minimal drift. and because of the difficulty of simulating a n meaningful signal. Neutron detectors are adequately ol l surveilled in SR 3.3.1.1.1 and SR 3.3.1.1.7. Y hl The Frequency is based upon the assumption of a 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. SR 3.3.2.1.7 The RWM will only enforce the proper control rod sequence if the rod sequence is properly input into the RWM computer. This SR ensures that the proper sequence is loaded into the RWM so that it can perform its intended function. Control rod withdrawal sequences are normally established consistent with the rules of the generic BPWS analysis. Occasionally, operational limititions (e.g., power suppression of failed fuel) may dictate the insertion of control rods which do not meet the minimum cell separation criteria of the generic BPWS analysis. In such situations, sufficient cycle specific analyses are performed to demonstrate that the resulting control rod worths of the modified control rod withdrawal sequence are bounded by the rod worths allowed by Q rigorously following the rules of the generic BPWS analysis, thereby assuring that the 280 cal /gm fuel damage limit will d not be violated during a CP,DA. The prescribed withdrawal secuence" is defined as the combination of both the procecurally specified control rod movement sequence and any analytically allowed deviations from this sequence. Some prescribed withdrawal sequences (e.g. BPWS) have more flexibility in allowed deviations than other prescribed withdrawal sequences (e.g., a cycle- ! l FERMI - UNIT 2 B 3.3. 2.1 - 11 Revision 6 05/28/99
! Control Rod Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued) i l q specific sequence developed for power suppression of failed ' fuel may not allow any deviations). L k ~ The Surveillance is performed once arior to declaring the RWM OPERABLE following loading of t1e )rescribed withdrawal sequence into the RWM, since this is w1en rod sequence input errors are possible. 1 REFERENCES 1. UFSAR Section 7.6.2.13.5. t
- 2. UFSAR, Section 7.6.1.20.
- 3. General Electric Energy, " Maximum Extended Operating Domain Analysis for Detroit Edison Company Enrico Fermi Energy Center Unit 2." NEDC 31843P. . July 1990.
- 4. NEDE 24011 P A 10 US. " General Electric Standard Application for Reload Fuel." Supplement for United States. March 1991.
- 5. " Modifications to the Requirements for Conti- Rod Drop Accident. Mitigating Systems." BWR Owners' Group, !
July 1986. i
- 6. NED0 21231. " Banked Position Withdrawal Sequence "
January 1977.
- 7. NRC SER, " Acceptance of Referencing of Licensing Topical Report NEDE 24011-P,A." " General Electric Standard Application for Reactor Fuel, Revision 8.
Amendment 17," December 27, 1987.
- 8. NEDC 30851-P A, " Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation,"
October 1988. hJ 9. NEDC-32410P A, " Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Q Retrofit Plus Option III Stability Trip Function," October 1995, and Supplement 1. May 1996. I FERMI UNIT 2 B 3.3.2.1 - 12 Revision 6, 05/28/99
i GPECWichTiots 3.3 2.I LSO 60- I' Co hih1 b. l (, i pEACTIVITY CONTROL SYSTEMS 3/4 4 4 CONTROL R00 PROGRAM CONTROLS ROD VORTH MINIH17ER , LIMITING CONDITION FOR OPERATION LCo 33212.1 ' .1- The rod worth minimizer (RWM) shall be OPERABLE. TBLlte't 2. W APPLICABil1TY: OPERATIONAL CONDITIONS 1_ and 2*, when THERMAL POWER is less than ' i Ior equal to 10% of RATED THERMAL POWERf ty m1pmum allopble prpset power 1pvelD
- l TSL dofc(b)
ACTION:
- a. With the RWM inoperable, verify control rod movement and compliance with r th'r Re .4ttc2 2 th' Pr'5 crib'd c " trol rod P*tt'ra by
- 5'cond lic'"5'd oS'r*tortechnicallyE'qualified member of t Reg Act f I startup A mor wiin r orn u'rr) The use of this provision during reactor p l prior to the first 12 control rods being fully withdrawn is C 1.i.Z- restricted to one startup per calendar year. Otherwise, control rod Ni j g$ g c.2.. l.) i g g g, j movement may be only by actuating the manual scram or placing the reactor mode switch in the shutdown position.
$ j SURVEf tt ANCE REOUIREMENTS l
6, 4.1.4.1 The RWM shall be demonstrated OPERABLE: P 2*y e - My ~ itt.= w:: 0? e-tm N 3O+ M l
- a. In 0 10NAL CONDITION 2 withinfo amm.
ff9b cr ;n: perp;;; ; .' ...,. . . . , . h ; : : r- r
> m -
. u u aim and in OPERATl6NAL /
bh,[ k CONDITION 1 within I hour after KWM automatic initiation when reducing _ b S R 3 3.*2.l . L THERMAL POWER p erliy pro inoi anon yr tne unection/ error op atj fgg contr rod '4 ( QeasY one oct-o sequen . (4,2.Maysl & mur s m ier t u A : .. ; : :: c:atrol ,f i g 3'3, g,f,l b. SIn #0r OPERATIONAL CONDITION 2 within(A r m puronoi nr =v! n> Lae--ream-- m! mm by veri f vina the rod
,Q a nnt 1 Q y a r r a
in g s1 nour after RWM automatic initi on < l 3352gc. In OPERATIONAL CONDITION 1 I gg when reducing THERM _AL POWER,rp aemannraying tne wunpaw oiou anopnser (blocyfunctions. f _ _ trovtk
- d By demonstrating that the S W. d P0:iti;.'e tt.dr. J sequence input to the-N 3 52*l7 RWH computer is correctly loaded following any loading of the program into ;
the computer. WO -
*Y ITION 2 and withdrawal of selected control rods is S gg A. 3.3.za l
- Entry into/0PERATIONAL Cpermitted/for the purpose of determining the OPERABILITY N of the RW withdrawal of control rods /cr-th 9--- --
l uuim- ,. l 3/4 1 16 Amendment No. /J. J/, 83 l FERMI - UNIT 2
- PAGE l _ 0F 09 i Rel (o
Sf &CiF/pr706) & 3. 2./ Leo 3.3.2 1
-T C E 3.; l ? (Continued)
CONTROL ROD BLOCK INSTRUMENTATION ACTION STATEMENTS
@T10N40 - Declar/the RBM inoppfable and ta4Fthe ACTION reAdired b L SoecMitation 3.1.V.3. / ~ *
~
{ ACTION /l - With the number of wt.RABLE anne rs. l a. One less than requ ied by the Minimum 0 RABLE Channels er Trip Function re O'I I i rement, restore the inoperable channe t OPERA 8LE status ithin 7 days or pla the inoperable k.Z. channel in the ripped condition wi in the next hour. ,
- b. Two or more ess than required by he Minimum OPERABLE U Channels r Trip Function requi ement, place at least ne )
_operab channel in the tr1DE d condition within 1 our). OLCTION62- ith the number of RABLE channels less tha equired by in f.Q Minimum OPERABLE annels per Trip Function equiremen.t. p a the inoperable cha 1 in the tripped condit witi.in I hour. R5 b" N 6 ACT! "-A3 - With the number of OPERABLE channels less than required by the !!
'I Minimum OPERABLE Channels per Trip Function requirement. -taitide ]
t-rei-M+ek lk ( & TABLE NOTATIONS T yg[g i
- With THERMAL POWER greater than or equal to 30% of RATED THERMAL POWER.
l han one control ydd withdrawn, 1(ith ende rem more)d 4e oer jpecificafinn L0.10.1 or. 3. V10 . . , , 2 /--Not yplicabTeysp4ontrop"
# A 00 ' u t no Ft.EO, The RBM shall ::t r:tteel?y bypassedfwhen eference are enavnel indi.g peri (nneeni '3 cont %t roa/1 M I4 Y (a) svhewo or t ateslist: t"- of RATED l
HERMAL POWE h c??;.fd function ~ sha n-M ;w.T.Q.icellye L5; ::d . . ........ -- - - - - L 43
> 00 cps or the IRM cha els are on ran e 3 or higher.
lc) his funct n shall be tomatically b assed when the ssociated channels re on range or higher. d This fu tion shall automatica11 yeassed when t e IRM cha als araJ '1 e 3 or hiahe . /-- E on ra iu on shaii be sviomancgiiy byp ined whui is im cnannen arup
~
D Tt.7c;ification Sp [ 3..,y. 9.2.rgiaors f 'f.;eshall Sew pt -- OPERABLE of reautred Dyg FERMI - UNIT 2 3/4343 Amendment No. Jp, 112 PAGE 6 0F 09 g
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9 i DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 - CONTROL R00 BLOCK INSTRUMENTATION ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications
-(CTS) to the proposed plant specific Improved Technical Specifications (ITS). certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes. reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1.
A.2 CTS 3.3.6 specifies Actions for control rod block channels with r setpoints not within allowable values. These Actions state 8
" declare the channel inoperable until the channel is restored to Operable status." ITS 3.3.2.1 contains all the requirements and lk_
Actions for control rod block channels, including the allowable ( values and Actions when its not met. The usage rules of Technical Specifications adequately dictate that channels be declared inoperable and Actions taken until restored to Operable, without a specific statement to that effect. Therefore. elimination of this l statement is an administrative presentation preference only. l A.3 CTS Table 3.3.61 Action 60 (for inoperable RBM channels) simply transfers actions to CTS 3.1.4.3. ITS 3.3.2.1 Actions provide the actions for inoperable RBM channels without transferring actions b'etween Specifications. This reflects an administrative presentation preference. O A.4 Not used ly T A.5 CTS 3.1.4.1 Applicability details a "name" ("the minimum allowable preset power level") for the applicable power level of 10t RTP. ITS 3.3.2.1 does not include this cross-reference "name." The ITS requirements adequately detail the required power level, and a reference to a common name for this power level serves no functional purpose. and its removal is purely an administrative preference. M FERMI UNIT 2 1 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION TECHNICAL CHANGES MORF,BESTRICTIVE M.1 CTS Table 3.3.6 1 Action 63 for inoperable Mode Switch-Shutdown Position requires only the initiation of a control rod block. ITS 3.3.2.1 Action E requires suspending control rod withdrawal (essentially equivalent to the CTS required rob block), but also y imposes a requirement to fully insert all insertable control rods g I in fueled cells. This additional requirement results in a more g conservative all rods in core condition. Therefore, this additions will not introduce any nagative impact on safety. M.2 CTS Tables 3.3.6 1 and 4.3.6 1 require the reactor mode switch shutdown position rod block to be Operable in Modes 3 and 4. ITS Table 3.3;2.1 1 Note'(c) requires this rod block function to be Operable when the mode switch is in the shutdown position. This change adds rod block function Operability requirements while in Mode 5 with the mode switch in shutdown position. Mode 5 operation with the mode switch in shutdown credits this rod block function. Therefore, this change will not introduce any negative impact on safety. M.3 CTS Table 3.3.6 1 footnote (a) states that "the RBM shall be automatically bypassed when < 30t RTP." However CTS contains no specific surveillance of this automatic enable / bypass function for the RBM. Furthermore, the footnote (a) wording is misleading fn its intent to assure an Operable function at 2 30% RTP: it i specifically would only enforce that the automatic trip be bypassed below 30% RTP. leaving s'ilent any requirements at 2 30% RTP. ITS 3.3.2.1 includes SR 3.3.2.1.5 that requires the RBM to be not-bypassed at 2 30% RTP. This imposes a periodic verification and enhances the presentation to avoid potential misinterpretation. M.4 CTS 4.1.4.1.a and b and footnote *. allow the withdrawal of control rods to perform the RWM functional test anytime, and for any duration prior to withdrawal of control rods for the purpose of [ making] the reactor [ critical]." The ITS allowance in Notes e4 to SR 3.3.2.1.1 and SR 3.3.2.1.2 imposes a time frame (1 hour) to lt complete the test in Mode 2: not allowing unlimited rod $ withdrawals. These additional restrictions do not impose any negati,ve impact on safety. FERMI UNIT 2 2 REVISION 6 05/28/99l i 1
{ DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" LA.1 CTS 3.3.6 requires that control rod block instrumentation trip setpoints to be within Trip Setpoint column values of CTS ,
Table 3.3.6-2. Additionally, CTS 3.3.6 Action a requires that an l inoperable rod block monitor (RBM) instrument channel setpoint be j restored consistent with the trip setpoint value. However. Actions only apply if the allowable value is exceeded. ITS 3.3.2.1 requires only that instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip setpoints are generally being relocated to the Technical Requirements Manual (TRM), however, for the RBM Upscale Function, its trip setpoint and allowable value limits are located in the COLR (per the CTS). For the RBM Downscale l Function, its trip setpoint and allowable value limits are also l found in the COLR, but the CTS had also repeated the specific limits. Since the methodologies utilized to derive the COLR-
- specified RBM Upscale limits are the same as those utilized to derive the RBM Downscale limits, it too is being relocated to the COLR for consistency. This relocation continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability and the methodologies for deriving the allowable value continues to be r'equired by the Technical Specifications. Revisions to these relocated values are made in accordance with the provisions of ITS 5.6.5. COLR.
LA.2 CTS 4.1.4.1.a. b, and c include detailed steps for the verification of RWM Operability. These details are outlined in the Bases for ITS SRs 3.3.2.' and 3.S.2.1.3. This change is acceptable because ITS SRs 3.3.2.1.2 and 3.3.2.1.3 continue to maintain the requirement to perform periodic verification of RWM Operability without any change in requirements. Any revisions to t these details, which are located in the ITS Bases, require change control in accordance with the ITS 5.5.10. Bases Control Program. \ Therefore, these details can be adequately defined and controlled 9 outside of Technical Specifications, consistent with NUREG-1433. 2 This relocation continues to provide adequate protection of the public health and safety since the requirement for RWM Operability g and peHodic verification of RWM Operability continues to be required by the Technical Specifications as described in the Y Bases. FERMI - UNIT 2 3 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 - CONTROL R00 BLOCK INSTRUMENTATION CTS Table 3.3.61 footnote (a) details specifics regarding when LA.3 the RBM is bypassed. These design details are adequately described in the Bases, which require change control in accordance
)
with the ITS 5.5.10. Bases Control Program. This relocation e continues to provide adequate protection of the public health and
- safet, since the requirements for RBM Operability remain in the d Technical Specifications and the relocation of design detail does not impact the ITS requirement to verify that the RBM trip functions are not inappropriately bypassed.
LB.1 Not used. l7 LC.1 CTS 4.3.6 requires Surveillances be performed on the RBMs: but ) contains no provisions for avoiding Technical Specification lb ) Actions when the surveillance causes the RBM to be inoperable. I ITS 3.3.2.1 Surveillance Requirements are provided with Note 2 allowing RBM surveillances that result in an inoperable RBM to be conducted for up to 6 hours without entering the associated Conditions and Required Actions for the inaperable RBM, provided f the other RBM is Operable. N l These changes are based on analysis of system reliability l documented in NEDC 30851. Supplement 1. " Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation." l October 1988. Fermi has confirmed the plant specific application N ; of this NRC reviewed and approved Topical Report, and its application to Fermi was reviewed and approved by the NRC in l Amendment #75 to the Fermi 2 CTS. (Note however, at the time of Amendment #75. DECO did not seek approval of this item.) Therefore, this change has no significant impact on safety. 4 LR.1 CTS 3.1.4.1 Action a allows verification of control rod movement by a second qualified individual in the event of an inoperable RWM: however, the CTS also details that this individual must be "present at the reactor control console." ITS 3.3.2.1 Required Actions C.2.2 and D.1 provide the same allowance: but do not detail the specific location of the individual. This detail can be removed from the Technical Specifications. Regulatory control of changes to this requirement (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 requirement for verification by a second individual continues to be required , by the Technical Specifications. FERMI UNIT 2 4 REVISION 6. 05/28/99l
i DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 - CONTROL R00 BLOCK INSTRUMENTATION l l l IECHNICAL CHANGES - LESS RESTRICTIVE "Speci fi c" i' L.1 CTS 3.1.4.3 Action a.1 requires verification that the reactor is not " operating on a LIMITING CONTROL R00 PATTERN" when one RBM is inoperable. CTS 4.1.4.3.b requires an additional Channel Functional Test prior to control rod withdrawal when the reactor is operating on a LIMITING CONTROL R00 PATTERN." ITS 3.2.1 does not contain these requirements. This does not result in a reduction in the level of safety because a Limiting Control Rod Pattern is defined as operating precisely on a power distribution limit (such as APLHGR or MCPR). Any operation exceeding a power distribution limit requires correction within 2 hours (as required ) by Specifications in Section 3.2). Any operation even slightly ' below the' power distribution limit does not invoke the special requirements. This condition (exactly on a power. distribution ; limit) is very unlikely, and due to the fluctuations occurring in l all process input parameters used to calculate the operating l thermal limit parameter, the equality would not likely exist on any subsequent calculation. Fermi practice is to maintain an l operating margin to the power distribution limits, and frequent monitoring is performed as operation approaches any limit. Therefore, these additional requirements have been deleted, and this less restrictive change will not impact safety. L.2 CTS Table 4.3.6-1 requires a Channe Functional Test of the reactor mode switch shutdown position rod block function. ITS SR 3.3.2.1.4 imposes this same requirement but includes a 1 hour allowance after placing the mode switch in shutdown, to conduct lh the surveillance. This allowance provides an ability to transition into the Applicability for the Function's Operability to conduct the testing without' imposing limitations (i.e.. Mode change restrictions of CTS 4.0.4 or ITS SR 3.0.4) that would necessitate the use of jumpers and/or lifted leads to prove the function's Operability. This is acceptable since the expected outcome of any surveillance is confirmation of that Function's continued Operability. Additionally, in this condition, all rods are expected to be fully inserted due to the concurrent reactor scram generated by the mode switch position. Therefore, this change will not impact safety. FERMI UNIT 2 5 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION L'. 3 CTS 4.1.4.1.d requires that the " Banked Position Withdrawal Sequence" is correctly loaded in the RWM. However. if this is not satisfied, the associated Action a of CTS 3.1.4.1 allows control rod movement to continue provided it is in compliance with the
" prescribed control rod pattern." ITS SR 3.3.2.1.7 requires '; hat the'" prescribed withdrawal sequence" be loaded into the RWM.
" Banked Position Withdrawal Sequence" (BPWS) is revised to rare generally refer to "the prescribed withdrawal sequence." TFis allows operation that conforms to an approved sequence to tu conducted with an operable RWM, in lieu of placing the operator in a required action. Plant / cycle specific analysis may reedire certain deviations from BPWS (which are utilized as initial assumptions for CRDA analyses and form the " prescribed withdrawal sequence"T. Therefore, while this essentially reflects a !
terminology change with no technical change in practice, it ! represents additional flexibility in programming the RWM with the I approved sequence being followed. This will result in an overall enhanced margin of safety. L.4 CTS 4.1.4.1.a and b require RWM Channel Functional Tests within 8 hours prior to withdrawing control rods for startup, and CTS 4.1.4.1.c. requires RWM Channel Functional Test within 1 hour of reaching RWM automatic initiation during a reactor shutdown. These surveillances are required to be performed every reactor startup and S' ' wn, regardless of the frequency of these events. ITS SR 3.3.2.1.2 and ITS SR 3.3'.2.1.2 only require that the Channel Functional Test be performed every reactor startup and shutdown if it was not performed in the previous 92 days. Typical 4 : operating experience involves intervals between successive .L startups (or shutdowns) much greater than 92 days, and the performance of these surveillances has been shown to usually pass Q the surveillance when performed at these intervals. Therefore, that operating experience supports eliminating testing that is required at more frequent intervals. Based on this operating experience, the change will not impose a significant impact on safety. i a
/
FERMI - UNIT 2 - 6 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION RELOCATED SPECIFICATIONS R.1 The APRM control rod block functions to prevent a control rod withdrawal at high power to flow conditions to minimize the potential for inadvertent reactor trip on high flux. The APRM utilizes LPRM signals to create the APRM rod block signal. APRMs provide information about the average core power; however, the rod block function is not used to mitigate a design basis accident (DBA) or transient. . Comoarison to Screenino Criteria:
- 1. The APRM Control Rod Block Instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA.
i
- 2. The APRM Control Rod Block Instrumentation does not monitor l a process variable that is an initial condition of a DBA or l transient analyses. )
- 3. The APRM Control Rod Block Instrumentation is not a part of a primary success path in the mitigation of a DBA or transient. -
- 4. As discussed in Sections 3.5 and 6 and summarized in
~
Table 4-1 (item 135) of NED0 31466, the loss of the APRM Control Rod Block function was found to be a nonsignificant risk contributor to core damage frequency and offsite releases. DECO has reviewed this evaluation, considers it applicable to Fermi 2, and concurs with the assessment. Moreover, this subsystem is not included in the Maintenance Rule (MR) and thus is considered by the MR Expert Panel to be non-risk significant.'
Conclusion:
g i Since the screening criteria have not been satisfied, the Control (O Rod Block Instrumentation LC0 and Surveillances applicable to APRM M instrumentation are relocated to the Technical Requirements - Manual, where revisions are controlled by 10 CFR 50.59. FERMI UNIT 2 7 REVISION 6, 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION R.2 The Source Range Monitor (SRM) control rod block functions to prevent a control rod withdrawal error during reactor startup utilizing SRM signals to create the rod block signal. SRM signals , are used to monitor neutron flux during refueling, shutdown, and l startup conditions. No design basis accident (DBA) or transient analysis takes credit for rod block signals initiated by the SRMs. Comoarison to Screenino Criteria:
- 1. The SRM Control Rod Block Instrumentation is not used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary prior to a DBA.
- 2. The SRM Control Rod Block Instrumentation does not monitor a process variable that is an initial condition of a DBA or transient analyses.
- 3. The SRM Control Rod Block Instrumentation is not a part of a primary success path in the mitigation of a DBA or transient.
- 4. As discussed in Sections 3.5'and 6 and summarized in Table 41 (item 137)"of NED0-31466, the loss of the SRM Control Rod Block function was found to be a nonsignificant risk contributor to core damage frequency and offsite releases.
DECO has reviewed this evaluation, considers it applicable to Fermi 2, and concurs with the assessment. Moreover, this subsystem is not included in the Maintenance Rule (MR) and thus is considered by the MR Expert Panel to be non risk significant.
Conclusion:
Since the screening criteria have not been satisfied, the Control r0 Rod Block Instrumentation LC0 and Surveillances applicable to SRM A instrumentation are relocated to the Technical Requirements ed Manual, where revisions are controlled by 10 CFR 50.59. p T w' FERMI UNIT 2 8 REVISION 6 05/28/99l
E l h DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 - CONTROL R00 BLOCK INSTRUMENTATION l R.3 The Intermediate Range Monitor (IRM) control rod block functions to prevent a control rod withdrawal error during reactor startup l utilizing IRH signals to create the rod block signal. IRMs are l l provided to monitor the neutron flux levels during refueling. shutdown, and startup conditions. No design basis accident (DBA) or transient analysis takes credit for rod block signals initiated by IRMs. Comoarison to Screenina Criteria: l
- 1. The IRM Control Rod Block Instrumentation is not used for.
nor capable of, detecting a significant abnormal degradation i of the reactor coolant pressure boundary prior to a DBA.
- 2. The IRM Control Rod Block Instrumentation does not monitor a process variable that is an initial condition of a DBA or transient analyses.
- 3. The IRM Control Rod Block Instrumentation is not a part of a primary success path in the mitigation of a DBA or transient.
- 4. As discussed iri Sections 3.5 and 6, and summarized in Table l
41 (item 138) of NED0-31466, the loss of the IRM Control Rod Block function was found to be a non significant risk contributor to core damag'e frequency and offsite releases. DECO has reviewed this evaluation, considers it applicable to Fermi 2, and concurs with the assessment. Moreover, this subsystem is not included in the Maintenance Rule (MR) and thus is considered by the MR Expert Panel to be non risk l significant.
Conclusion:
Since the screening criteria have not been satisfied, the Control i Rod Block Instrumentation LC0 and Surveillances applicable to IRM 7 to instrumentation are relocated to the Technical Requirements d Manual, where revisions are controlled by 10 CFR 50.59. ~ t
~
FERMI UNIT 2 9 REVISION 6, 05/28/99l
1 DISCUSSION OF CHANGES ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION R.4 (continued) I
- 4. As discussed in Sections 3.5 and 6. and summarized in Table !
4-1 (item 139) of NED0-31466, and Table 4-1 (item 365) of NED0 31466 Supplement 1. the loss of the SDV Control Rod Block function was found to be a non significant risk contributor to core damage frequency and offsite releases. DECO has reviewed this evaluation. considers it applicable to Fermi 2, and concurs with the assessment. Moreover, this ' subsystem is not included in the Maintenance Rule (MR) and thus is considered by the MR Expert Panel to be non-risk significant.
Conclusion:
l Since the screening criteria have not been satisfied. the Control fl Rod Block Instrumentation LC0 and Surveillances applicable to SDV $3 instrumentation are relocated to the Technical Requirements "4 Manual, where revisions are controlled by 10 CFR 50.59. j{ t l 1 4 w FERMI - UNIT 2 11 REVISION 6 05/28/99l
~
Control Rod Block Instrumentation 3.3.2.1 ACTIONS CONDITION REQUIRED ACTION COMPLET!ON TIME 1 C. (continued) C.2.1.1 Verify 2 12 rods I withdrawn. Imediatel[yg.I.y.i, /)d/m a.) f na C.2.1.2 Verify by Imediately administrative methods that startup with RWM inoperable has not been
, performed in the calendar year.
y U y AND '@ C.2.2 Verify movement of During control control rods is in rod movement compliance with - p,g b-.d n;u. wp-- - - -<< k y withdrawal sequence
~
-f89WG)-by a second licensed operator or other !;ualified ,
member of the ' technical staff. D. RWM inoperable during D.1 Verify movement of During control reactor shutdown. control rods is in d movement accordance wit'AMtt" k #"# ' IN by a second licensed l 6 operator or other Wi drawa( ' qualified member of p the technical staff. (continued) BWR/4 STS 3.3-16 Rev 1, 04/07/95 RevG
Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E. One or more Reactor E.1 Suspend control rod Imediately 6L T 3 % Mode Switch-Shutdown withdrawal . g4;,43 Position channels inoperable, b@ 4 E.2 Initiate action to Imediately fully- insert all 5 insertable control ) rods in core cells containing one or m re fuel assemblies. j SURVEILLANCE REQUIREMENTS
----------------NOTES-----------------------------------h'I'41k l 1.
Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Ro NO b\ Block Function. /
- 2. When an RBM channel is placed in an inoperable status solely for perfonnance of required Surveillances, entry into associated Conditions C Ul and Required Actions may be delayed for up to 6 hours provided the associated Function maintains control rod block capability.
SURVEILLANCE FREQUENCY
, l SR 3.3.2.1 Perform CHANNEL FUNCTIONAL TEST. days J A
3 b
~
(continued) e thave up 62 3 3.7.t. / h z from n eyf& BWR/4 STS 3.3-17 Rev 1, 04/07/95 ; l l l
Control Rod Block Instrumentation 3.3.2.1 tabt 3.3.2.1 1 (p. Control R.d OlocttriIn.e.1 ci 1) m t. tion g 75) (( T6 Ls ; 3. 3. (,-l J L3. 6 -2.] APPLICA8LE N' 'b ~ se0 DES OR oTHER SPECIFIED REQUIRED SLRyt!LLANet ALLOWASLE FL.lCTION CO W ITICIf8 CNANNELS REGUIREM NTS VALLE
- 1. aed stock ,ionitor fg o
- "' " ~c" "> a :st 3.3.2.1
- w;;ptgt v 6 fatt g [")-L,,.h
\
3.1, Lf.3) Inte to Po.or (b @ sa 3.3.2.1 1 s (199.7/1 1 Rerve le st 3.3.2 .4 divi.f.n. f ! sit 3.3. 1.7 futt .ca
- c. leh Power - L. (c),(d, (23 sa . 11 1251 3.3.2.1.7 f 1. cat e j h inn, ,pf 4 an3.32.8m u ,s.m. -
lb l. g> -- y a : :ieggg.1g 3 . g , .... . .. , t...t., n : ,v .; . .. y -3
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g,s ::1gg ,. , . , . o b (Er:riid.jg '-l ia. t 3. g.gej u. . -- g 3.3.3. iga (TeL3 16 7 > nao <s,1 9 3 . a > .'- c.> 1===t == =W:Enne-iern)irP p,e = - ; m 1= = Pown, mix A mixer,.nax,.<1.nl. ((78L f.3.G,-1; * > l$ rrst 4.3.c,-t,v) p'\ u, 6 - .,a.(,a = ,,, ~ 4P,<,.n.J W rn t m . /= .7, w - <ilo. # we> vE,a -, , An .no m nrP .6 ep < 1.n> g) with tunmAt PoWEa a gop air. h,l,9.l,ApplMYi
, <p .e tor ..no in ti - -ni-(n t. 5 3 6-1 /-b 7 )
BWR/4 STS 3.3-20 Rev 1, 04/07/95
Control Rod Block Instrumentation B 3.3.2.1 BASES ACTIONS C.1. C.2.1.1. C.2.1.2. and C.2.2 (continued) The RW may be bypassed under these conditions to allow continued operations. In addition, Required Actions of LCO 3.1.3 and LCO 3.1.6 may require bypassing the RW, during which time the RW must be considered inoperable *1rth-g Condition C entered and its Required Actions taken. /_ k Sndifdurin u <uche s%%g a With the RW inoperable during a reactor shutdown operator is still capable of enforcing the prescribed control rod sequence. Required Action D.1 allows for the RW Function to be performed manually and requires a double _ check of compliance with the prescribed rod sequence by a second licensed operator (Reactor Operator or Senior Reactor Operator) or other qualified member of the technical staff. The RW may be bypassed under these conditions to allow the reactor shutdown to continue. E.1 and E.2 With one Reactor Mode Switch-Shutdown Position control rod h withdrawal block channel inoperable, the remaining OPERABLE fod N ocE channel is adequate to perfona the control rod withdrawal block function. However, since the Required Actions are i consistent with the normaTVaction of an OPERABLE Reactor Mode Switch-Shutdown Position Function (i.e., maintaining all control rods inserted), there is no distinction between -
, having one or two channels inoperable. T In both cases (one or both channels inoperable), suspending i all control rod withdrawal and initiating action to fully g insert all insertable control rods in core cells containing one or more fuel assemblies will ensure that the core is subcritical with adequate SDM ensured by LCO 3.1.1. Control rods in core cells containing no fuel assemblies .do not affect the reactivity of the core and are therefore not required to be inserted. Action must continue until all insertable control rods in core cells containing one or more fuel assemblies are fully inserted.
(continued) BWR/4 STS B 3.3-50 Rev 1, 04/07/95
1 Control Rod Block Instrumentation B 3.3.2.1 BASES (con}inued) l
--~w CURVEILLANCE Note: Certain Frequencies are base T REQUIREMENTS topical repo . r for o use these Frequencies Frequencies as g j ..wu py the staff SER for the topical ~repo .
s noted at the beginning of the SRs, the SRs for each Control Rod Block instrumentation Function are found in the SRs column of Table 3.3.2.1-1. The Surveillances are modified by a Note to indicate that when an R8M channel is placed in an inoperable status solely i for performance of required Surve111ances, entry into l associated Conditions and Required Actions may be delayed for up to 6 hours provided the associated Function maintains control rod block capability. Upon completion of the Surveillance, or expiration of the 6 hour allowance, the ; channel must be returned to OPERABLE status or the g l applicable Condition entered and Required Actions taken. g p* o This Note is based on the reliability analysis (Ref. Q l I O assumption of the average time required to perform c annel x l Surveillance. That analysis demonstrated.that the 6 hour I testing allowance does not significantly reduce the probability that a control rod block will be initiated when necessary.
]
3.3.2.1 3 : r- t SR
' T517 -74 5' i A CHANNEL FUNCTIONAL TEST is performed for each RBM channel i
gyr~kl to ensure that the entire channel will perform the intended ' functtoni*-It in:ld: th; neuter ",;.nni C;ntr:1 l
,Of.1
.;1tiplexin; ";iete.. input.
I Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of days is based on reliability analyses (Ref. ). sgy y , i 9 1 5 fel SR 3.3.2.1 and SR 3.3.2.] A c.HANNEL FUNCTIONAL TEST is performed for the RWM to ensure w t the entire system will perform the intended function. g yg 3,fQ Thr$ CHANNEL FUNCTIONAL TEST for the RWM is performed by attempting to withdraw a control rod not in compliance with (continued) BWR/4 STS B 3.3-51 Rev 1, 04/07/95
q Control Rod Block Instrumentation B 3.3.2.1 { j l l l Jnsert: TSTF 205 (2 places) INSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. j l i i FERMI - UNIT 2 Page B.3.3 51 (Insert) REVISION 6 05/28/99l
Control Rod Block Instrumentation B 3.3.2.1 BASES
. m re is SURVEILLANCE SR y
3.3.2.1 " and SR 3.3.2.1 I (continued) ind ua d *W a ornUIREME i fggert,7 ., . the prescribed sequence and verifying a dontrol rod block D'I*I ' b occurs.J As noted in the SRs, SR 3.3.2.1 is not required
'to be perfonned untti 1 hour after any control rod is withdrawn;. "^^: 1. As noted, SR 3.3.2.1 7 to be performed until I hour after THERMAL @ POWER isis not required
(/ M 56ET / $ 10% RTP in DE 1. This allows entry into MODE 2 for 6 3 3.2..l - 2. h SR 3.3.2.1 1 d entry 4=+"0E 1 -h n THERMAL POWER # 4duckrn When.in s 10% RT9f for SR 3.3.2.18o perfonn the required +o surveillance if the 92 day Frequency is not met per r N'M \ 1 (Wo0 F i SR 3.0.2. The I hour allowance is based on operating experience and in consideration of providing a reasonable ' y l 6 3 31 1 -2 C., L - t time in which to complete the SRs. The Fre uencies are g elidi'ity ;n.ly.ci: '";f
*). pg ffJSEttT s2 3 3 2 IA *SR
# fMA 3.3.2 & 1 Ned "The R&i setpcint: Or: esteseti;;ily ..ried :: ; fur-ti:n of f,3 % C} ; = r. Three ^.11;weble Vaiues are av.J T;;d ir_
s t -
- il. 0.0.0.M each .iithin e specific p. .r r.nye. f The l QM Igdmalic,(( *poweratwhichthefent teseticelly ;h;ng er /r;'-red based bleck A!!APRM on the e dlesignal's Vainstinput to %
each RBM channel. Below the minimum power setpointJihe RBM bg"55[g I6 is automatically bypassed. Thestpower Allowable Value,h' must be verified periodically to be less than er equ:1 t;- l "h ;F;;ifi d '=lu=>- If ""Y "~"" "'"':= setpoint is o'/oRTPM - nonconservative,thentheaffectedRBMcliannel is considered
- +NS '
inoperable. Alternatively, the power ran9e channel can be placed in the conservative condition (i.e., enabling the (uwdfM ^
-prePe* RBK % tp;ir,t). If placed in this condition, the SR is metneutron nntad and thedeteetnre RBM channel is notf-a-see ::;1;d:d considered
+ke ! r;;jil. inoperable g;;-
Th e : :: the., e,. p.aeive ds. cee, .;ith ainiael a,i h , and' Is
% L e r r Ns[NW "$! b "! N N N = 55 55 5 [ d"k" N N #$
i~)"f ,~ ' Ent d rEquUc[is'5asAd on Ye a t trip setpoint methodology utilized for these channels. 2.V I SR 3.3.2.1.5k o The RWM i automatically byp sed when power is abov a f- specift value. The power evel is determined fr feedw er flow and steam ow signals. The autom ic bypas s d., (continued) BWR/4 STS B 3.3-52 Rev 1, 04/07/95
- k. #
Control Rod Block Instrumentation B 3.3.2.1 Insert B 3.3.2.1-2a Control rod withdrawal sequences are normally established consistent with the rules of the generic BPWS analysis. Occasionally, operational limitations (e.g., power suppression of failed fuel) may dictate the insertion of control rods which do not meet the minimum cell separation criteria of the generic BPWS analysis. In such situations, sufficient cycle specific analyses are performed to demonstrate that the resulting control rod worths of the modified control rod withdrawal sequence are bounded by the rod worths allowed by rigorously following the rules of the generic BPWS analysis, thereby assuring that the 280 cal /gm fuel damage limit will not be violated during a CRDA. q
~
l The " prescribed withdrawal sequence" is defined as the q combination of both the procedurally specified control rod 9C. ; movement sequence and any analytically allowed deviations from this sequence. Some prescribed withdrawal sequences (e.g., BPWS) have more flexibility in allowed deviations than other prescribed withdrawal sequences (e.g., a cycle specific sequence developed for power suppression of failed fuel may l not allow any deviations). SR 3.3.2.1.1 is performed during startup. k Insert B 3.3.2.1-2b at 5 10t RTP in MODE 2. The SR 3.3.2.1.2 CHANNEL FUNCTIONAL TEST is performed by attempting to insert and withdraw a control lk N rod not in compliance with the prescribed sequence and verifying { a selection error is indicated and a control rod insert and withdraw block (respectively) occur. SR 3.3.2.1.2 is performed - during a plant shutdown when transitioning to s 10t RTP. 4 Insert B 3.3.2.1 2c operating experience that shows the RWM usually passes the b i Surveillance when performed at these Frequencies I ,e FERMI UNIT 2 Page B 3.3-52 (Insert) REVISION 6 05/28/99l
Control God Block Instrumentation B 3.3.2.1 BASES SURVEILLANCE SR 3.3.2.1 continued) ; REQUIREMENTS adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. As noted, neutron detectors are excluded from the CHANNEL CALIBRATION because they are passive devices, with minis drift, and because of the difficulty of simulating a Wmilled
, meaningful si 1. Neutron detectors are adequately W in SR 3.3.1.1 nd SR 3.3.1.1.
Pq/ The Frequency based upon the assumption of an B month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. SR 3.3.2.1 f gg y The RWM will only enforce the proper control rod sequence if j the rod sequence is properly input into the RWM computer. tr) I f3'3.'3 2.l- I j - ,- This SR ensures that the proper sequence is loaded into the RWM so that it can perform its intended function.4 The
)
i Surveillance is performed once prior to declaring RWM Q oc
/ OPERABLE following loading of sequence into , since this
- p. 5 ' , when rod sequence inp errors are possi .
+kt Vestf%ed WMsdrwa r -
REFERENCES 1. V FSAR, Section [7.5.2.2.5). ~/ 6.2.13,6
, 2. U FSAR, Section -y.0.0.2.G}. 7.p, /, 2o ,.
W 3. E -3b 4-r, itet , R n BI~
~
it , an ech al S cifica n nt A ) Pr ram f Edw 1. Ha N[,afprove ear P an , aber loat ~
- 4. NEDE-240ll-P-A-[US " General Electried Standard Application for Reload Fuel," Supplement for' United States, Srt':: 2.2.2.1, :;t:--M. ;;". AfM64, /19/.
- 5. " Modifications to the Requirements for Control Rod Drop Accident Mitigating Systems," BWR Owners' Group, July 1986. _
- MAftMUM CXTEAb60 OPERAT1007 DoMAid OEklEf.,AL ELECTRIC. GM6A(nf,CavtPAay EMPJC0 FERMt ENEAWf CENTER.
AMt.Q5LS fot DETRbtr NEDC, 3t 843 r, JULY 1990- - EDisco M eontinued) w ____ - _ _ - - BWR/4 STS B 3.3-54 Rev 1, 04/07/95 .,/
l l i !- Control Rod Block Instrumentation B 3.3.2.1 Insert B 3.3.2.1 5 I Control rod withdrawal sequences are normally established consistent with the rules of the generic BPWS analysis. l Occasionally, operational limitations (e.g., power i l suppression of failed fuel) may dictate the insertion of l control rods which do not meet the minimum cell separation l criteria of the generic BPWS analysis. In such situations, sufficient cycle specific analyses are performed to demonstrate that the resulting control rod worths of the ; modified control rod withdrawal sequence are bounded by the ' rod worths allowed by rigorously following the rules of the generic BPWS analysis, thereby assuring that the 280 cal /gm g fuel damage limit will not be violated during -a CRDA.
<t The " prescribed withdrawal sequence" is defined as the combination of both the procedurally specified control rod movement sequence and any analytically allowed deviations from this sequence. Some prescribed withdrawal sequences (e.g. BPWS) have more flexibility in allowed deviations than other prescribed withdrawal sequences (e.g.. a cycle specific sequence developed for power suppression of failed fuel may not allow any deviations).
l l 1 l
/
FERMI UNIT 2 Page B 3.3-54 (Insert) REVISION 6 05/28/99l
Control Rod Block Instrumentation B 3.3.2.1 BASES REFERENCES 6. NED0-21231, " Banked Position Withdrawal Sequence," (continued) January 1977.
- 7. NRC SER, " Acceptance of Referencing of Licensing Topical Report NEDE-24011-P-A," " General Electric Standard Application for Reactor Fuel, Revision 8, Amendment 17," December 27, 1987.
- 8. NEDC-30851-P-A, " Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation,"
October 1988.
^
. GE" -770-00-l' " Addendum iv 5. ' for unanges i - ^
'h rveillanc est Intervals d Allowed Out- -Service g A
Times fo elected Instr ntation Tech - S;::i'.;;tiens," T.L. ... ., 2 001. - i l msar N , g3.32J-3 0 l BWR/4 STS B 3.3-55 Rev 1, 04/07/95 i I
i l Control Rod Block Instrumentation B 3.3.2.1 1 I 2 4 Insert B 3.3.2.1 3 l
- 9. NEDC-32410 P A, " Nuclear Measurement Analysis and Control .
.+ b Power Range Neutron Monitoring (NUMAC PRNM) Retrofit Plus L Option III Stability Trip Function," October 1995, and Supplement 1 May 1996.
k 1 1 i l I i i FERMI UNIT 2 Page 8 3,3 55 (Insert) REVISION 6 05/28/99l
JUSTIFICATION FOR DIFFERENCES FROH NUREG - 1433 I ITS: SECTION 3.3.2.1 CONTROL R0D BLOCK INSTRUMENTATION I I NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license l requirements and comitments. Refer to CTS Discussion Of Changes to l the related requirement for a detailed justification of changes made j to the current licensing basis which are also reflected in the ITS as l presented. Additional rewording, reformatting, and revised numbering l is made to incorporate these changes consistent with Writer's Guide conventions. Specifically, some of these changes are discussed below:
- a. NUREG Required Action C.2.1.2 has a provision for a verification in the "last calendar year." This is revised (based on CTS) to d
" current calendar year." Literal reading of the NUREG words 4. I would allow unlimited use of the associated allowance in the current calendar year if the allowance had not been used "last" Q year. This is clearly not the intent of CTS, and is therefore editorially revised for clarity.
P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for l additional detail. P.4 d ! Other editorial corrections made to more clearly and accurately L reflect the requirement as detailed in the Bases. lk P.5 "BPWS" is revised to more generally refer to " prescribed withdrawal sequence." Plant / cycle specific analysis may require certain deviations from BPWS, which are utilized as initial assumptions for CRDA analyses. Therefore, this essentially reflects a terminology change with no technical change in practice. P.6 Clarifying details of the performance of the Channel Functional Tests required by SR 3.3.2.1.1 and SR 3.3.2.1.2 is added to the Bases. This detail is provided to enhance operator understanding lGg g of the intent of and differences in these two Channel Functional Tests.' FERMI - UNIT 2 1 REVISION 6 05/28/99l
r l l JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.2.1 - CONTROL R00 BLOCK INSTRUMENTATION P.7 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
P.8 ISTS Reference 8 (Control Rod Block Topical Report) is erroneously I referenced for ISTS SRs 3.3.2.1.2 and 3 (ITS SRs 3.3.2.1.1 and 2) Bases. There is no Topical Report basis for the RWM functional te'st Frequency of 92 days that is provided in the NRC issued y NUREG-1433. The correct basis for this Frequency is provided. p Additionally, Reference 8 is the correct reference for the 6 hour T allowance for testing the RBM without entering the Actions. The ISTS erroneously indicates Reference 9 as the supporting basis. This error is corrected. I GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG 1433. O t I l w FERMI UNIT 2 2 REVISION 6. 05/28/99l L
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.2.1 CONTROL R00 BLOCK INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.2.1 "L.4" Labeled Comments / Discussions) I i Detroit Edison has evaluated the proposed Technical Specification change l identified as "Less Restr1ctive" in accordance with the criteria specified by l 10 CFR 50.92 and has determined that the proposed change does not involve a l significant hazards consideration. ' The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
This change will require that the Channel Functional Test only be performed every reactor startup and shutdown if it was not performed in \p the previous 92 days. The Surveillance intervals are not a parameter or J., system assumed to be an initiator for any accidents previously analyzed. Therefore, this change does not significantly increase the probability g ' of a previously analyzed accident. The proposed change does not involve l a significant increase in the consequences of an accident previously evaluated because this change does not further degrade the capability of i the RWM to perform its required funct' ion (only the test interval is ' affected by this change). Additionally, the increased times allowed will not adversely affect the performance of any other credited equipment. As such, the consequences remain unchanged from those tnat would apply utilizing the existing CTS requirements, and will therefore not result in any significant increase in consequences of a previously analyzed accident.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant operation. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated. ' FERMI - UNIT 2 7 REVISION 6. 05/28/99l
i N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.2.1 - CONTROL ROD BLOCK INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.2.1 "L.4" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety?
Typical Fermi 2 operating experience involves intervals between successive startups (or shutdowns) much greater than 92 days, and the , performance of these RWM surveillances has been shown to usually pass the surveillance when performed at these intervals. Therefore, that dkh i operating experience supports eliminating testing that is required at ! more frequent intervals. Based on this operating experience, the i proposed change does not involve a significant reduction in a margin of ! safety. -
)
1 4 w FERMI UNIT 2 8 REVISION 6 05/28/99l
m Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 ! BASES
-SURVEILLANCE REQUIREMENTS (continued)
The Frequency is based on operating experience that l demonstrates channel failure is rare. The CHANNEL CHECK ) supplements less formal, but more frequent, checks of channel status during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.2.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustr.2nt shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of 31 days is reasonable, based on operating experience and on other Surveillances that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furthermore. 0)erating experience shows that failure of more than one clannel in a given 31 day period is a rare event. SR 3.3.2.2.3 j CHANNEL CALIBRATION is a complete check of the instrument i loop and the sensor. This test verifies the channel l responds to the measured parameter within the necessary , range and accuracy. CHANNEL CALIBRATION leaves the channel j adjusted to account for instrument drifts between successive j calibrations consistent with the plant specific setpoint j methodology. j The Frequency is based upon the assumption of a = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis, i i l FERMI UNIT 2 B 3.3.2.2 - 6 Revision 6 05/28/99
Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.2.2.4 I 1 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the feedwater and main turbine valves is included as part of this Surveillance j and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide i complete testing of the assumed safety function. Therefore, if a valve is incapable of operating, the associated instrumentation would also be inoperable. The 18 month l Frequency is based on the need to perform this Surveillance J under the conditions that apply during a plant outage and the. potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. REFERENCES 1. UFSAR, Section 15.1.2. l
- 2. UFSAR. Section 15.3. I E
d' l FERMI UNIT 2 B 3.3.2.2-7 Revision 6, 05/28/99
DISCUSSION OF CHANGES ) ITS: SECTION 3.3.2.2 - FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION 1 TECHNICAL CHANCtES - MORE RESTRICTIVE None. 1 TECHNICAL CHANGES LESS RESTRICTIVE " Generic" LA.1 CTS 3.3.9 requires that feedwater and main turbine high water i level actuation instrumentation be set to the trip setpoint values l shown in Table 3.3.9-2. Additionally, the CTS 3.3.9 Action a requires that an inoperab1' ieedwater and main turbine high water level instrument be restored to the trip setpoint value. However. Actions only apply if the allowable value is exceeded. ITS 3.3.2.2 requires only that instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details k while the allowable value reflects channel Operability. Therefore, requirements for trip setpoints in CTS 3.3.9 and CTS )y ; Table 3.3.9-2 (including footnote *) are relocated to the s Technical Requirements Manual (TRM), which requires revisions be 2 controlled by 10 CFR 50.59. The trip setpoint is established l based on a combination of instrument design factors, environmental factors, and the allowable value (which is what is conservatively derived from the value assumed in the safety analyses). Therefore, these details can be~ adequately defined and controlled in the TRM, consistent with the NUREG 1433. This relocation continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability q and the allowable value continues to be required by the Technical Specifications.
. i FERMI - UNIT 2 2 REVISION 6, 05/28/99l l
4
DISCUSSION OF CHANGES ITS: SECTION 3.3.2.2 - FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE "Speci fic" L.1 CTS 3.3.9 Action b requires inoperable feedwater and main ~ turbine trip instrumentation channels to be restored to Operable status within 7 days or to commence a plant shutdown. ITS 3.3.2.2 Action a allows inoperable channels to be placed in trip within 7 days (the option to " restore" remains implicitly allowed), thereby I allowing continued plant operation and avoiding a required plant shutdown. With channel (s) placed in the tripped condition, the safety function of the inoperable channel is maintained, and the remaining Operable channels can continue to provide the necessary automatic protective function. Therefore, this change will not adversely impact safety. L.2 CTS Table 3.3.91 and Table 4.3.9.11 require an Applicability of Mode 1 for this function. Consistent with this. CTS 3.3.9 Actions I b and c. for inoperable feedwater and main turbine trip actuation I instrumentation that is not restored or tripped in the required time requires the unit to be "in at least Startup within the next 6 hours." ITS 3.3.2.2 requires the Applicability of Thermal Power , a 25t RTP. and for inoperable feedwater and main turbine trip actuation instrumentation that is not restored or tripped in the required time. ITS 3,3.2.2. Action C requires power to be reduced t'o< 25% RTP in 4 hours. Feedwater and main turbine trip actuation instrumentation is intended to enforce assumptions associated with the analysis that established MCPR limits. The MCPR limits are not Applicable below 25% RTP (due to the large inherent margin that ensures the MCPR Safety Limit is not exceeded). Therefore, the Applicability has been modified to be 2 25% RTP. and the shutdown action has been changed to only require power to be reduced to '<25t RTP instead of a requirement to enter Mode 2. The Completion Time changes (from 6 to 4 hours for the plant shutdown) is consistent with other Completion Times to reduce power to < 25% power when MCPR related limits are not met. This change has no impact on safety because the Applicability for this function, and the Action times, are consistent with the Applicability and Action times for the MCPR limits. g
1 1 l DISCUSSION OF CHANGES l ITS: SECTION 3.3.2.2 FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION L.3 CTS 3.3.9 Action c.provides 72 hours for two inoperable feedwater and main turbine trip actuation instrumentation thannels. The Fermi logic for the feedwater and main turbine trip actuation instrumentation is 1 out-of 2-twice. Therefore two inoperable
]
channels will either: 1) still allow for the trip function (i.e., i 2 out-of 2 trip) if the inoperability is a single channel in each trip system, or 2) result in a loss of function if both inoperable channels are in the same trip system (note: this " function" is related to initial assumptions of MCPR analyses). ITS 3.3.2.2 Action B provides for a more restrictive 2 hour restoration time in the event of a loss of function: however ITS 3.3.2.2 Action A (allowing a less restrictive 7 days) will apply to two inoperable channels ff trip capability is maintained. This less restrictive change is consistent with the NUREG 1433 " standard" provision for inoperabilities that result in the remaining Operable logic constituting a 2 out of 2 trip. I I Additionally. there are no CTS Actions provided for three or four inoperable channels: thereby requiring CTS LC0 3.0.3 entry with three or four inoperable channels. ITS 3.3.2.2 Action B allows 2 hours to restore sufficient channels (at least two Operable channels) to maintain' trip capability. or a plant shutdown to exit the Applicability within the following 4 hours. The resulting Completion Time changes are consistent with other Completion Times t'o reduce power to < 25% power shen MCPR-related limits are not met. Together. these changes provide an improvement in safety by eliminating the allowance for 72 hours of continued operation in the event of a loss of safety function, and providing Actions consistent with other Specifica. tion allowances for operation with MCPR parameters not within limits. RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.3.2.2 consistent with the BWR STS, j NUREG 1433. Rev. 1. FERMI UNIT 2 4 REVISION 6. 05/28/99h
Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 BASES SURVEILLANCE SR 3.3.2.2.1 (continued) REQUIREMENTS indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels, or something even more serious. A CHANNEL CHECX will detect gross channel failure; thus, it is key to verifyir; the instrumentation continues to operate properly betwtei each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a char.nel is outside the criteria, it may be an indication that the instrument has drifted outside its limits. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less fonnal, but more frequent, checks of channel status during normal operational use of the displays
, associated with the channels required by the LCO.
TSTF'24f l 6TlrA- G SR 3.3.2.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the r'3 c) intended functioD Any setpoint adjustment shall be I consistent with the assumptions of the current plant specific setpoint me'thodology. f } I 6331'23 4 I Y Y " O #f = i;2; i; b . 'A-
"J "' "1i*5"'I ";l 2;i' SR 3.3.2.2.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive (continued)
BWR/4 STS B 3.3-61 Rev 1, 04/07/95 )
Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 i INSEPsT B 3.3.2.2-3 The Frequency of 31 days is reasonable, based on operating experience and on other Surveillances that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furthermore. operating experience shows that failures of more than one channel in a given 31 day period is a rare event. INSERT: TSTF-205 LNSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. .This clarifies what is an acceptable CHANNEL 8 FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other l Technical Specifications and non-Technical Specifications tests at I least once per refueling interval with applicable extensions. ! FERMI UNIT 2 B 3.3 61 (Insert) REVISION 6. 05/28/99l
JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.2.2 - FEEDWATER AND MAIN TURBINE HIGH WATER LEVEL TRIP INSTRUMENTATION NON BRACKETED Pl. ANT SPECIFIC CHANGES P.1 These changes are made to_NUREG-1433 to reflect Fermi 2 current licensing basis: including design features.. existing license requirements and commitments. Additional rewording, reformatting. and revised numbering is made to incorporate these changes consistent 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. Specifically, some of the changes are discussed below:
- a. NUREGe1433 reflects allowances from GE Topical Report GENE 770.
Fermi 2 has not performed the necessary evaluations to adopt this flexibility for the Feedwater and Main Turbine Trip
, Instrumentation. -
P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer.to the Specification, and associated JFD if applicable, for additional detail. P.4 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES C.1 TSTF-205: NRC approved change to NUREG 1433. i i l e h FERMI UNIT 2 1 REVISION 6, 05/28/99l
PAM Instrumentation B 3.3.3.1 BASES
.LC0 (continued)
Therefore, the PAM Specification deals specifically with this portion of the instrument channel.
- 10. Primary Containment Isolation Valve (PCIV) Position PCIV position is a Type B. Category I variable, and is provided for verification of containment integrity. In the case of PCIV position, the important information is the isolation status of the containment penetration. The LC0 requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one control room indication. Note (b) requires a single Of}l channel of valve position indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of
~
each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow Jath is isolated, position indication for the PCIV(s) in tse associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE. The PCIV position PAM instrumentation consists of position switches. wiring, cabling, and control room indicating lamps for active PCIVs. Therefore, the PAM s)ecification deals specifically with these instrument clannels. APPLICABILITY- The PAM instrumentation LC0 is a)plicable in MODES 1 and 2. These variables are related to tie diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3. 4. and 5. plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore. PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS Note 1 has been added to the ACTIONS to exclude the MODE change restriction of LC0 3.0.4. This exception allows entry into the applicable MODE while relying on the ACTIONS s/ l FERMI - UNIT 2 B 3.3.3.1 - 6 Revision 6 05/28/99
l DISCUSSION OF CHANGES ITS: SECTION 3.3.3.1 - PAM INSTRUMENTATION j A.5 CTS Table 4.3.7.5-1 footnote # states that the provisions of Specification 4.0.4 are not applicable. This is not required in ! ITS 3.3.3.1 because any potential confusion concerning when the e surveillance is required is eliminated by specifying the precise d requirements for performance of the Surveillance such that an explicit exception to 4.0.4 is not necessary. The ITS SR 3.3.3.1.2 Note 2 modifies the Frequency such that it is "Not required to be performed Q) l
- until 72 hours for one channel and 7 days for the second channel after > i l 15% RTP." This is an administrative change with no impact on safety.
TECHNICAL CHANGES MORE RESTRICTIVE None l l TECHNICAL CHANGES LESS RESTRICTIVE
" Generic"
- LR.1 CTS Table 3.3.7.5 1. Action 81, requires that with the Operable channels less than the minimum required, initiate the preplanned alternate method of monitoring the appropriate parameter (s) within 72 hours and restore the inoperable' channel within 7 days. ITS 3.3.3.1, Action C. requires the channel restored within 7 days, but does not require the preplanned alternate method of monitoring -
to be initiated within 72 hours. This is acceptable because the rbquirement to initiate an alternate monitoring plan does not _ impact the requirement to restore the channel within 7 days. i Additionally, the requirement to initiate alternate methods of 2 l monitoring post accident parameters can be removed from the _ Technical Specifications is not of any safety significance until a
- post accident event requires this monitoring. Regulatory control f of changes to this requirement (e.g., Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate l protection of the public health and safety since the requirement for post accident instrument channel Operability and actions for
- inoperable instrumentation, continues to be required by the Technical Specifications. l l
I FERMI UNIT 2 2 REVISION 6. 05/28/99l
)
DISCUSSION OF CHANGES ITS: SECTION 3.3.3.1 PAM INSTRUMENTATION
- LR.2 CTS Table 4.3.7.51 footnotes
- and ** provide details of performing Channel Calibrations. ITS SRs 3.3.3.1.2 and 3.3.3.1.3 do not include these details; they are removed from the Technical Specifications. Regulatory control of changes to this requirement (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 relocation of procedural detail from the A Technical Specifications does not change any requirement, nN including the requirement for Channel Calibrations, which continue - to be required by the Technical Specifications. 8 TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" - L.1 CTS 3.3.7.5 does not contain explicit exception to LC0 3.0.4: however. ITS 3.3.3.1 Actions Note 1 allows that LC0 3.0.4 is not i applicable for any inoperable post accident monitoring instrument (s). This is consistent with NUREG 1433. Post accident l monitoring instrumentation do not impact normal operation of the lo plant and hence, would not provide any additional initiators for i plant transients during startup or Mode changes. Furthermore, in addition to the PAM instrumentation there are additional capabilities for backup monitoring and/or compensatory actions that are addressed by plant specific Emergency Operating P'rocedures. Therefore, the LC0'3.0.4 exception will have an l insignificant impact on safety. L.2 CTS Tables 3.3.7.51 and 4.3.7.51 present the Applicability for l most Functions as only Modes 1 and 2. However, for the post l accident monitoring function of the containment high range radiation monitor and PCIV position, the CTS required
~
Applicability is Modes 1, 2. and 3. ITS 3.3.3.1 maintains the required Applicability for all post accident monitoring Functions as Modes 1 and 2. Post accident monitors are provided to assist the operator in the response to and diagnosis of design basis ; accidents (DBAs). The initial conditions for the DBAs that rely y on these functions are assumed to occur in Modes 1 and 2. The i likelihood of an event in Mode 3 that would require post accident E monitoring instrumentation is extremely low; therefore these T Functions are not required to be Operable in Mode 3. .w
~ FERMI UNIT 2 -
3 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.3.1 - PAM INSTRUMENTATION l l l L.3 CTS Table 3.3.7.51. Action 80.a requires the plant to be in Mode 3 within 12 hours. if the instrument channel is not restored within the allowed out of service time. ITS 3.3.3.1. Action B, ) allows the submission of a special report to the NRC (in accordance with ITS Specification 5.6.7), in lieu of a required shutdown. This alternative action is acceptable since only one of two required channels are inoperable such that monitoring l capability remains available, and since the likelihood of a DBA ) i that would require information from the monitor is low. Therefore. this less restrictive change will have a negligible impact on safety. L.4 CTS Table 3.3.7.5-1 Action 80.a and Action 81.1) require restoration of a single inoperable channel within 7 days. CTS lnni 3 Table 3.3.7.5 1 Action 80.b and Action 83 require restoration of lv one channel when two are inoperable within 48 hours. ITS 3.3.3.1 Action A requires restoration of a single inoperable channel within 30 days: ITS 3.3.3.1 Action C requires restoration of one channel when two are inoperable (except two inoperable hydrogen or oxygen concentration channels) within 7 days: and ITS 3.3.3.1 < Action D requires restoration of one channel when two hydrogen or I oxygen concentration channels are inoperable, within 72 hours. These increased allowed out of service times are consistent with NUREG-1433. and are acceptable based on the remaining Operable post accident monitoring channels, other non-Regulatory Guide 1.97
' instrument channels which monitor the function. the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments). and the low probability of an event j requiring PAM instrumentation during this interval. Therefore. j this less restrictive change will have a negligible impact on j safety. ]
I L.5 CTS 3.3.7.5 1 requires 1 channel per valve for the primary j containment isolation valve (PCIV) position. and its Action 82 for j inoperable channels requires restoration within 48 hours. ITS i Table 3.3.3.1 1 states requirements on a penetration basis - i requiring 2 channels per penetration: but also including Note (b) ; allowing the requirement to drop to 1 channel on penetrations with l only one installed control room indication channel. This results p 3 in equivalent requirements. While this change reflects an 1 l administrative presentation preference, it is provided to assist d ; clarification of the ITS 3.3.3.1 Actions which are less T l restrictive: FERMI - UNIT 2 4 REVISION 6. 05/28/99l 1 i i
DISCUSSION OF CHANGES ITS: SECTION 3.3.3.1 PAM INSTRUMENTATION L.5 (continued)
. ITS 3.3.3.1 Action A allows 30 days if one channel in a penetration is inoperable, and only requires submission of a special report (in accordance with ITS 5.6.7) if not restored in 30 days; and
. Action C allows 7 days if both channels in a penetration are inoperable, and requires plant shutdown to Mode 3 if one channel is not restored within 7 days.
These increased allowed out of service times are consistent with NUREG 1433, and are acceptable based on the remaining Operable post accident monitoring channels, other non Regulatory Guide 1.97 instrument channels which monitor the function, the passive nature , i of the instrument (no critical automatic action is assumed to occur from these instruments). and the low probability of an event requiring PAM instrumentation during this interval. Therefore, this less restrictive change will have a negligible impact on
)
safety.
# F i
l FERMI - UNIT 2 ~ 5 REVISION 6. 05/28/99 h i l
l DISCUSSION OF CHANGES ITS: SECTION 3.3.3.1 PAM INSTRUMENTATION l R.1 (continued) Conclusion Since the screening criteria have not satisfied for non Regulatory Guide 1.97 Type A or Category 1 variable instruments, their na associated LCO and Surveillances are relocated to the Technical $3 Requirements Manual, where revisions are controlled by 10 CFR Fi 50.59. The instruments to be relocated are as follows (numbers '- i reflect the CTS Table 3.3.7.51 Instrument Functions): bb i
- 5. Suppression Chamber Air Temperature:
- 6. Suppression Chamber Pressure:
3
- 8. Dry 9 ell Air Temperature: 1
- 11. Safety / Relief Valve Position Indicators:
- 13. SGTS Radiation Monitors; and ,_s ej b
u V 4 6 1 l l l l 6 FERMI UNIT 2 7 REVISION 6 05/28/99l
PM Instrumentation B 3.3.3.1 BASES LCO h Primary Containment Area Radiation (Hiah Ranac/
. (co nued) this pla primary containment area radia on (high range)
PM instr tation consists of the foi ing:]
- 6. Drvwell Sumo le 1 Drywell sump level is a S .ory I variable provided for verification of ECCS fun l s that operate to maintain RCS integrity. lFor this ant, drywell sump level PM instrumentatnon con ts of the 11owing:]
- 7. Drywell in Sumo level Drywell ain sump level is a Category I vari e provided to de et breach of the RCPB and for verificatio nd long te surveillance of ECCS functions that operate to aintain integrity. [For this plant, the drywell drain su evel PM instrumentation consists of the following:]
I N Primary Containment Isolation Valve (PCIV) Position t$ A NFh B CArcGoty I'VAftA8L6, MD IV positionfi s provided for verification of containme h
-~
integrity. In the case of PCIV position, the important information is the isolation status of the containment penetration. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.'e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one L ... FC E b.9,3 4 control room indication, Note (b) requires a sing 12 channel of valve position indication to be OPERABLE. This is i sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of,the active valve, as applicable, and prior knowledge of passive valve or system boundary status. If a penetration flow path is I isolated, position indication for the PCIV(s) in the associated penetration flow path is-not needed to determine ' status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be_ OPERABLE 6 % -- - CmVllAIAl tv minoa PsM tairemeurAvea musn " Mm0" ""'MC, CA 6 Lj Af(.p AAlp CeWMel,,gegM mDICAp LAMM fot MTIVL - f0ZYE. ,711tlifeg6,, Th$ PAM .$ftfGf/64WOU bfALS ntNut& f flCAU.-Q BWR/4 STS B 3.3-67 Rev I, 04/07/95 tairH THESE JAI.STAdMEMr . , ouweu. -
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.3.1 - PAM INSTRUMENTATION l TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.3.1 "L.2" Labeled Comments / Discussions) Detroit Edison has_ evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. 1 l The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below. l l l 1. Does the change involve a significant increase in the probability or j consequences of an accident previously evaluated? l The proposed change eliminates the Mode 3 Applicability for the containment high range radiation monitor and PCIV position indication. l The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the PAM instrumentaticn is not considered as an initiator for any accidents l previously analyzed. The proposed change does not involve a significant increase in the consequences of an accident previously evaluated because initial conditions for the DBAs that rely on these functions are assumed d j .L to occ'ur in MODES 1 and 2. Therefore the consequences of an event in Mode 3 that would require post accident monitoring is expected to be ( substantially less. Furthermore, the impact on consequences is not significant due to the passive function of the instruments, the operator's ability to diagnose an accident using alternative instruments and the likelihood of plant conditions that would require information provided by these instrumentation.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? l This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant operation. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously l
evaluated. ! t FERMI UNIT 2 3 REVISION 6, 05/28/99l !
'l N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.3.1 - PAM INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.3.3.1 "L.2" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not involve a significant reduction in a margin of safety because initial conditions for the DBAs that rely on these d ; functions are assumed to occur in Modes 1 and 2. Therefore the safety 1 significance of an event in Mode 3 that would require post accident monitoring is expected to be substantially less. Furthermore, the lk impact is not significant due to the passive function of the instrument, the operator's ability to diagnose an accident using alternative instruments and the likelihood of plant conditions that would require information provided by these instrumentation.
- i l
t FERMI UNIT 2 , 4 REVISION 6 05/28/99l
1 4 l i
$ 9EC ( FICA T10 rJ F. 3. 3,2._
i l INSTRUMENTATION ,g REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS q LIMITING CONDITION FOR OPERATION [DeVi IAAM J l
. <'-ww LLO 3.3 3.'l 3.3.7.4 The8 remote shutdown system instrumentation and controls shown in )
Table 3.3.7.4 1 shall be OPERABLE. , APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2. ACTION:
- a. With the number of OPERABLE remote shutdown system instrumentation hCTION k channels less than required by Table 3.3.7.4-1, r store the inoi.Jrable channel (s) to OPERABLE status within da s or be in at ACT109 6 least HOT SHUTDOWN within the next 12 hours. 3o f,, f
- b. With the number of OPERABLE, remote shutdown system controls less hCTION A than reautred by Table 3.3.7.4-1. restore the inocerable control (s) to OPERABLE status within days or be in at least HOT SHUTDOWN AcTloA) 6 within the next 12 hours. gy Octop Note 1 c. The provisions of Specificat on 3.0.4 are not applicable.
ADD AcT100 Norr 2.) -- 4, g SURVEILLANCE RE0VIPEMENTS SR 3 3 5.1.1 4,3,7,4,;.- Each of the above required remote shutdown monitoring SA J.3 32.$ instrumentation channels shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations et the frequencies shown in Table 4.3.7.4 1. .
'.3.7.'_? rach of the above remote shutdown control switches and control 1 G 3.3.'5.2.~L circuits s 11 be demonstrated OPERABLE by verifying its capability to perform its intende. function (s) at least once per 18 months.
FERMI - UNIT 2 3/4 3-57 PAGE l 0F 03
$dh
ATWS-RPT Instrumentation 3.3.4.1 l i SURVEILLANCE REQUIREMENTS l ....................................-NOTE -- ---- - -------- -------- I When a channel'is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 2 hours provided the associated Function maintains ATWS RPT trip capability. ! SURVEILLANCE FREQUENCY 1 SR 3.3.4.1.1 Perform CHANNEL CHECK. 12 hours l , SR 3.3.4.1.2 Perform CHANNEL FUNCTIONAL TEST. 31 days l SR 3.3.4.1.3 Perform CHANNEL CALIBRATION. The 18 months Allowable Values shall be:
- a. Reactor Vessel Water Level-Low Low.
Level 2: a 103.8 inches; and
- b. Reactor Vess'el Pressure-High:
5 1153 psig. A 1l SR 3.3.4.1.4 Perform LOGIC SYSTEM FUNCTIONAL TEST 18 months 2! including breaker actuation. l l i l l
-l FERMI - UNIT 2 3.3 33 Revision 6, 05/28/99 l
l l l l ATWS RPT Instrumentation B 3.3.4.1 l BASES SURVEILLANCE REQUIREMENTS (continued) channels during normal operational use of the displays associated with the required channels of this LCO. SR 3.3.4.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required l channel to ensure that the entire channel will perform the
- intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a
- ; ingle contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all ;
of_the other required contacts of the relay are verified by j i other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions.
. l Any setpoint adjustment shall be consistent with the ;
assumptions of the current plant specific setpoint methodology. i The Frequency of 31 days is reasonable, based on operating I experience and on other Surveillances that ensure ) roper functioning be. tween CHANNEL FUNCTIONAL TESTS. Furt1ermore, c)erating experience shows that the failure of more than one clannel in a given 31 day period is a rare event. l SR 3.3.4.1.3 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. The Frequency is based upon the assumption of a a 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. j i l FERMI - UNIT 2 B 3.3.4.1 - 8 Revision 6. 05/28/99 l l l
ATMS-RPT Instrumentation B 3.3.4.1 BASES
~
SURVEILLANCE REQUIREMENTS (continued) S.R 3.3.4.1.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as part of this Surveillance and ovarlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel (s) would be inoperable. The 18 month Frequency is based on the need to perform this Surye111ance under the conditions that apply during a plant outage and the potential for an un)lanned transient if the q Surveillance were performed with t1e reactor at power.
.:. 0)erating experience has shown these components usually pass i (I t1e Surveillance when performed at the 18 month Frequency.
l l REFERENCES 1. UFSAR Figure 7.7 3. Reactor Recirculation System ,FCD. t i l l l FERMI UNIT 2 B 3.3.4.1 - 9 Revision 6. 05/28/99
I I l 5Pec sp\ ca,,ou 33 tt. I \ l I INSTRUMENTATION 3/4.3.4 ATWS RECTRCULATION PUMP TRIP SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION L(o 3,3,4,l t:t:1r" The anticipated transient without scram recirculation pump trip (ATWS-RPT) system instrumentation channels shown in Table 3.3.4-1 shall be OPERABLE conf u sen t witn Ine ytlues snown ing ne trim g*j Ewitn Aneir trip sepoinu >utSeL#bint column of Table 3.3.4 Vf-- APPllCABillTY: OPERATIONAL CONDITION 1. g ACTION.
.- -[ ADO ACT70M S P4D7E)
- a. With an ATWS-RPT system instrumentation channel trip setpoint less - 3 SCT16N A conservative than the value shown in the Allowable Values column of Table J l
[4094 d up6114dMf}OPERABL[ .3.4-2 declare the statusrgrtn tne sy.nn . uchannel ip suppointinoperable aa.iustmountil the channel consistnt wit is H. ra"arad A +n Cthe prio setooto( value.1 1 i-404 REQvid50 Acnon A.1 Matt With the numoet of OPERABLE channels o(ne less than reoutred by the - b. Minimum OPERABLE Channels cer Trip System reouirement for one or both h inoperable cnannel(s) in the tripped conditioni 4 $ l gGON 4 trip systems. pia i j within . da 5 - With the numoer of OPERABLE channels two or more less than required by ACW b c. the Minimum OPERABLE Channels per Trip System requirement for one trip g g-system and: gg
- 1. If the Inoperable channels consist of one reactor vessel water level channel and one reactor vessel pressure channel, lac h/r'--
.Ilor, if inoperable channels in the tripped condition within this action will initiate a pump trip, declare the trip system inoperable.
- 2. If the inoperable channels include two reactor vessel water level channels or two reactor vessel pressure channels, declare the trip system inoperable. g (
4
- d. With one trio system nooerable,/festore the inoperable trip system to U l OPERABLE status withingfor be in at least STARTUP within the next 2 M
kCTION b 6 hours, g- hq m w%r g Acytog g system to With both trip systems i rabl , restore at least one trikin the next 6 or be in at least STARTUP wit NON be. - OPERABLE status within S RVE1 E UNNS 3 R M.9. l .1 1.0.0.P Each ATWS-RPT system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST and g 5,3 9, g ,s CHANNEL CAllBRATION operations at the frequencies shown in Table 4.3.4-1. sa 3 3 413 4.3.'.2 LOGIC SYSTEM FUNCTIONAL TESTS 6 >i, a t:d = t = u : n = u r :f J. N 3 3 4*I*9 wp shall be performed at least once per la montns. g ACM an h 3/4 3 32 Amenoment No. 55 FERMI - UNIT 2 PAGE / OF 04 bv (o
DISCUSSION OF CHANGES ITS: SECTION 3.3.4.1 - ATWS RPT INSTRUMENTATION ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical - Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433, Rev. 1. A.2 ITS LC0 3.3.4.1 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LC0. I
" Separate Condition entry is allowed for each channel." This is acceptable because the Required Actions for each Condition provide ;
appropriate compensatory actions for each inoperable ATWS-RPT ' channel. Complying with the Required Actions will a.llow for continued operation: with subsequent inoperable ATWS RPT channels governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on safety because this clarification is consistent with the existing interpretation of the CTS. A.3 CTS 3.3.4 specifies Actions for ATWS RPT channels with setpoints not within allowable values. These Actions state " declare the ly. channel inoperable until the channel is restored to Operable 7 status." ITS 3.3.4.1 contains all the requirements and Actions I for ATWS RPT channels, including the allowable values and Actions
- when it is not met. The usage rules of Technical Specifications
- adequately dictate that channels be declared inoperable and Actions taken until restored to Operable, without a specific statement to that effect. Therefore, elimination of this statement is an administrative presentation preference only.
FERMI - UNIT 2 1 REVISION 6 05/28/99l f
DISCUSSION OF CHANGES ITS: SECTION 3.3.4.1 - ATWS RPT INSTRUMENTATION A.4 For CTS Specification 3.3.4 (and ITS 3.3.4.1), the ATWS RPT system instrumentation is interpreted to include the actuated device (s) (i.e., two trip breakers per recirculation pump). Since each instrumentation channel (reactor water level and reactor pressure) ultimately provides signals that can result in all four breakers tripping, any inoperable breaker is necessarily associated with ! portions of all channels being inoperable. For limited number of channels CTS 3.3.4 Actions b and c.1 allow inoperable channels to be placed in trip and continued operation permitted. Where - multiple channels are inoperable and tripping them could result in i a recirculation pump trip, CTS Actions c.1 c.2, d, and e do not <t' permit tripping inoperable channels. Since ITS Action A can 'pply T to one or many inoperable channels, The-Note to Required Action A.2 is provided to direct a restoration requirement (and preclude a channel tripping allowance) in the event of an inoperable trip breaker. This explicit limitation is only a clarification of the requirements that would be imposed by compliance wi.th CTS 3.3.4 requirements. Therefore, this change only reflects a presentation clarification necessitated by the ITS format. A.5 CTS 4.3.4.2 requires an LSFT "and simulated automatic operation" of all channels. The simulated automatic operation is interpreted in the CTS to be included in the LSFT, since the CTS LSFT b definition " includes the actuated device." ITS SR 3.3.4.1.4 4 requires an LSFT but explicitly states " including breaker p actuation." Since the ITS LSFT definition is revised to exclude y the actuated device (refer to Section 1.0), explicitly adding
" breaker actuation" captures the CTS requirement. This clarification is an administrative presentation preference only.
A.6 CTS Table 3.3.41. Note (*), allows required surveillance testing "without placing the trip system of the tripped condition provided the other channel in the same trip function is OPERABLE." ITS SR Note'2 provides the same allowance stated as " entry into the associated Conditions and Required Actions may be delayed provided the associated Function maintains trip capability." This represents consistency in presentation with other Specifications, and as such, is considered an administrative change. TECHNICAL CHANGES - MORE RESTRICTIVE None FERMI UNIT 2- 2 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.4.1 - ATWS RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE " Generic ~ LA.1 CTS 3.3.4 requires that ATWS-RPT actuation instrumentation trip setpoints to be within Trip Setpoint column values of CTS Table 3.3.4 2. Additionally. CTS 3.3.4 Action a' requires that an inoperable ATWS RPT actuation instrument channel setpoint be restored consistent with the trip setpoint value. However. Actions 'only apply if the allowable value is exceeded. ITS 3.3.4.1 requires only that instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip setpoints are relocated to the Technical Requirements Manual (TRM). which requires revisions be controlled by 10 CFR 50.59. The trip setpoint is established based on a e4 combination of instrument design factors, environmental factors. i and the allowable value (which is what is conservatively derived from the value assumed in the safety analyses). Therefore, these [_ details can be adequately defined and controlled in the TRM. consistent with the NUREG-1433. This continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability and the allowable K , value setpoint continues to be required by the Technical Specifications. TECHNICAL CHANGES - LESS RESTRICTIVE "Speci fic~ L.1 CTS 3.3.4 Actions b and c.1 require tripping inoperable channel.s within 1 hour: however CTS 3.3.4 Action d would allow 72 hours with both channels in one trip system inoperable prior to requiring a plant shutdown. ITS 3.3.4.1 Action A allows 14 days to trip inoperable channels: and ITS 3.3.4.1 Action B allows 72 hours to restore trip capability in the event one of two trip ; Functions has lost trip capability. 1 The ATWS RPT design is such that either trip system will trip both recirculation pumps. Each trip system can be tripped by either of two Functions (reactor vessel low water level or reactor vessel . high pressure), arranged in a 2 out-of 2 trip logic for each y Function. (Note: although not assumed or credited the logic of s the two separate functions is also combined such that one low level and one high pressure signal would cause a trip system trip. g FERMI UNIT 2 3 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.4.1 ATWS RPT INSTRUMENTATION This feature would be described as a 1 out of 2-taken twice d 2. logic.) Due to the following considerations. the extended ( ITS 3.3.4.1 Completion Times do not reflect a significant impact on safety: 1) the significant redundancy and diversity of trip initiating signals, which may allow for maintaining trip ; capability even in the event of multiple ATWS-RPT ciiannel inoperabilities: 2) increased likelihood of an inadvertent loss of forced circulation while operating with inoperable ATVS-RPT channels that have been tripped to comply with required Actions: I and 3) the extremely low probability of an ATWS event that would ! require ATWS-RPT trips to function. I l L.2 CTS 3.3.4 Action d and e require a plant shutdown in the event I that required restoration or required channel tripping is not accomplished in the required time. ITS 3.3.4.1 Action D includes an option to the required plant shutdown - the option to remove the associated recirculation pump from service. This option accomplishes the functional purpose of the instrumentation and enables continued operation in a previously approved condition (under the restridon of other Specifications for single loop lpd. operation). Thy Me. these changes do not have a significant impact on safety. Q RELOCATED SPECIFICATIONS None i TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect , the format and applicable content of ITS 3.3.4.1 consistent with the BWR STS. NUREG 1433. Rev. 1. ! l l l J FERMI - UNIT 2 4 REVISION 6, 05/28/99l
ATWS-RPT Instrumentation 3.3.4 h 3.3 INSTRUMENTATION CTS) 3.3.4. Anticipated Transient Without Scram Recirculation Pump Trip l (ATWS-RPT) Instrumentation LCO 3.3.4. Two channels per trip system for each ATWS-RPT < r. 34> l instrumentation Function listed below shall be OPERABLE:
- a. Reactor Vessel Water Level-Low Low, Level 2; and
- b. Reactor - Pressure-High.
Vessel APPLICABILITY: MODE 1. ACTIONS __ ______________~_. -___.
.--- NOT E------------------- -
- 0 N'
!S $. SS $$_ Sf_3 __ _. $b*' . "$$b_______. . ._
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Restore channel to inoperable. OPERABLE status. 14 days /g'g" 3
\ fg a l$
A.2 ------- NOT E--------- Not applicable if inoperable channel is \
~
the result of an 00c A 4/ J-inoperable breaker. <
.. .___.___.___.._ M Place channel in 14 days trip. 5 1
(continued) l BWR/4 STS 3.3-33 Rev 1, 04/07/95
ATWS-RPT Instrumentation / 3.3.4 SURVEILLANCE REQUIREMENTS (continued) [ CTS) SURVEILLANCE FREQUENCY j SR 3.3.4. 2 Perform CHANNEL FUNCTIONAL TEST. days [y.3 4' l)
) QBt.4.').H~l)
.3.4.2.3 Cal brate e trip units. (92]da /
SR 3.3.4 Perform CHANNEL CALIBRATION. The L 4 3 9-3 {3 Allowable Values shall be: gI8p, months y,3.% /) )
- a. Reactor Vessel Water Level-Low Low, Level 2: 2 m nches; and (T8L 3.3 4 -1)-
Ib3.
- b. Reactor "- Pressure-High: ,
5 psig. Y SR 3.3.4. . Perform LOGIC SYSTEM FUNCTIONAL TEST 4 ciudio, ereater actuation.
,,, 18g months (ti.3.q.t.)
er I BWR/4 STS 3.3-35 Rev 1, 04/07/95 i
ATWS-RPT Instrumentation B3.3.4.h 4 8 3.3 I RUMENTATION i 83.3,4/ nticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation BASES BACKGROUND The ATWS-RPT System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. OP.2. Tripping the recirculation pumps adds negative reactivity from the increase in sk:aa voiding in the core area as core VESS EL, flow decreases. When ketctor Vessel Water Level-Low Low, Level z or Reactor-it; = :: : Pressure-High setpoint is
~ ( reached, the recirculation pump drive motor breakers trio.
G SET GDJUATOC ng
~
The ATWS-RPT System (Ref. 1) includes sensors, relay , bypass capability circuit breakers, and switches that are necessary to cause initiation of an RPT. The channels include electronic equipment (e.g., trip units) that ' compares measured input signals with pre-established setpoints. When the setpoint is exceeded; the channel po output relay actuates, which then outputs an ATWS-RPT signal I . I- to the trip logic, gg The ATWS-RPT consists of two independent trip systems, with two cnannels of Reactor 7 t; z ?: : Pressure-High and two channels of Reactor Vessel Water Level-Low Low, Level 2 in each trip system. Each ATWS-RPT trip system is a two-out-of-two logic for each Function. Thus, either h - Reactor Water Level-Low Low, Level 2 or two Reactor e---VE5 Pressure-High signals are needed to trip a trip system. -
. The outputs of the channels in a trip system are combined in a logic so that either trip system will trip both ggg pgg g recirculation pumps by tripping the respective drive motor breakers).4 2 TWO TRIP COILS, WHlCH -
Mr SET C,ENELATOC RCLD ud ALLOWIS EACH Tf tp 5)$ TEM There is one rive reaker pro'viaea ~for each of the TD TRIP 6OTH BREAKERS two recirculation pumps for a total of two breajarj The y - -
,,., , output of each trip system is provided to both recirculation pumpfb reakers.
7DC. FlELD Awp OtuE mci 1DR.} hf b P/L LIMSEET I B3.3.4.I-l (continued) BWR/4 STS B 3.3-91 Rev 1, 04/07/95 W
ATWS-RPT Inst umentation B 3.3.4.4 t BASES SURVEILLANCE SR 3.3.4. .1 (continued) REQUIREMENTS something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the > instrument has drifted outside its limit. The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the required channels of this LCO. I i gy wg SR 3.3.4.8.2
/dsdT k A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perfom the
_ intended function. / f'l Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint ( f methodology. 6 3,3 4.1 - 3 _.!b. , _ IT.Iy'. , . . .nq 6. _an 2.2. .<.a P3 celi ~ 'i r i 1 - ;" provides = check ta =ctua trip setpoint The channel must be deci ed inoperable i the trip se ing is discovered to be 1 conservative than the All le Yalue specified in SR .4.2.4. If the tri settin s discovered to be less e servative than the sett g accounted for in the app priate setpoint odology, but is not beyond he Allowable Value, e { 4 (continued) BWR/4 STS B 3.3-98 Rev 1, 04/07/95 i 's 1 1 I
ATWS RPT Instrumentation B 3.3.4.1 ! Insert B 3.3.4.1 3 The Frequency of 31 days is reasonable, based on operating experience and on other Surveillances that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furthermore. operating experience shows that failures of more than one channel.in a given 31 day period is a rare event. INSERT: TSTF 205 l INSERT A l A successful test of.the required contact (s) of-a channel relay may be performed by the verification of the change of state of a single contact of the relay. This -clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. l l l l-l- I FERMI UNIT 2 Page' B 3.3 98 (Insert) REVISION 6, 05/28/99l
ATWS-RPTInstrumentatio/n ( B 3.3.4. I BASES SURVEILLANCE (G 3 . .s . 4. z . 3 /(cDiil ; . J REQUIREMENTS channel p formance is still withi the requirements of t e j f,3 plant s ety analysis. Under the must readjusted to be equal conditions, the set in or more conservativ tha ace nted for in the appropri e setpoint methodolo . The Frequency of 92 days is ased on the reliabil t
.r:lph :f ":f:r:::: ?.
b 3.3.4.8.# S_R A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary l range and accuracy. CHANNEL CALIBRATION leaves the channel ! adjusted to account for instrument drifts between successive ! calibrations consistent with the plant specific setpoint I methodology.
)
fl The Frequency is based upon the assumption of a /18 month I calibration interval in the determination of the magnitude I of equi t drift in the setpoint analysis. l.y SR 3.3.4.d.g y* The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is
~
included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a breaker is incapable of operating, the associated instrument channel (s) would be inoperable. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. p
\
k 1v (continued) BWR/4 STS B 3.3-99 Rev 1, 04/07/95 Re4&
~ATWS RPT Instrumentation B 3.3.4.1 Insert B 3.3.4.1-2
<< Removec in Rev 5 >>
1
- l l
l J FERMI UNIT 2 Page - B 3.3 99 (Insert) REVISION 6 05/28/99l
1 JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.4.1 - ATWS RPT INSTRUMENTATION NON-BRACKETED PLANT SPECIFIC CHANGES l l P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current I licensing basis: including design features, existing license requirements and commitments. Additional rewording. reformatting, j and revised numbering is made to incorporate these changes consistent I 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 l ITS as presented. Specifically, some of the changes are discussed i below:
- a. NUREG 1433 reflects allowances from GE Topical Report GENE 770.
Fermi 2-has not performed the necessary evaluations to adopt this flexibility. P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for additional detail. P.4 Change made for editorial preference or clarity. P,5 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG-1433. @ 1 i FERMI - UNIT 2 1 REVISION 6 05/28/99l
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.4.1 - ATWS RPT INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.4.1 "L.2" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below. j I
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? j The proposed change allows the option to remove the associated p recirculation pump from service. -
significant increase in the probabilityThe of proposed change an accident does not involve a l k previously , evaluated because this option accomplishes the functional purpose of the l instrumentation and enables continued operation in a previously approved condition (under the restriction of other Specifications for single loop operation). The proposed change does not involve a significant increase in the consequences of an accident previously evaluated because this l option accomplishes the functional purpose of the instrumentation and enables continued operation in a previously approved condition (under : the restriction of other Specifications for single loop operation). As such, the consequences remain unchanged from those that would apply utilizing the existing CTS requirements.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC) or changes in normal plant operation. Therefore, this change wi'~ ct create the possibility of a new or different kind of accident from any accident previously evaluated. FERMI - UNIT 2 3 REVISION 6. 05/28/99l
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Volume 5: SECTION 3.3.5.1-3.3.8.2 (cont'd) Remove Replace 3.3.7.1 DOCS pg 5 Rev 0 3.3.7.1 DOCS pg 5 Rev 6 3.3.7.1 DOCS pg 6 Rev 0 3.3.7.1 DOCS pg 6 Rev 6 3.3.7.1 NUREG M/U pg 3.3-71 3.3.7.1 NUREG M/U pg 3.3-7i Rev 6 3.3.7.1 NUREG M/U pg 3.3-72 3.3.7.1 NUREG M/U pg 3.3-72 Rev 6 B 3.3.7.1 NUREG M/U pg B 3.3-213 B 3.3.7.1 NUREG M/U pg B 3.3-213 Rev 6 B 3.3.7.1 NUREG M/U pg B 3.3-214 B 3.3.7.1 NUREG M/U pg B 3.3-214 Rev 6 ! B 3.3.7.1 NUREG M/U pg B 3.3-216 B 3.3.7.1 NUREG M/U pg B 3.3-216 Rev 6 B 3.3.7.1 NUREG M/U pg B 3.3 217 B 3.3.7.1 NUREG M/U pg B 3.3-217 Rev 6 3.3.7.1 NUREG M/U og B 3.3 217 (Insert) Rev 0 3.3.7.1 NUREG M/U pg B 3.3-217 (Insert) Rev 6
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3.3.7.1 NUREG M/U pg B 3.3-218 3.3.7.1 NUREG M/U pg B 3.3-218 Rev 6 l 3.3.7.1 NUREG M/U pg B 3.3-219 3.3.7.1 NUREG M/U pg B 3.3-219 Rev 6 3.3.7.1 JFD's pg 2 Rev 6 3.3.7.1 JFD's pg 3 Rev 6 3.3.7.1 JFD's pg 4 Rev 6 3.3.8.1 ITS pg 3.3-72 Rev 0 3.3.8.1 ITS pg 3.3-72 Rev 6 3.3.8.1 ITS pg 3.3-74 Rev 0 3.3.8.1 ITS pg 3.3-74 Rev 6 B 3.3.8.1 ITS pg B 3.3.8.1-1 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-1 Rev 6 B 3.3.8.1 ITS pg B 3.3.8.1-2 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-2 Rev 6 B 3.3.81 ITS pg B 3.3.8.1-3 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-3 Rev 6 B 3.3,8.1 ITS pg B 3.3.8.1-4 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-4 Rev 6 l B 3.3.8.1 ITS pg B 3.3.8.1-5 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-5 Rev 6 ! B 3.3.8.1 ITS pg B 3.3.8.1-6 Rev 0 B 3.3.8.1 ITS pg B 3.3.8.1-6 Rev 6 B 3.3.8.1 ITS pg B 3.3.8.1-7 Rev 6 3.3.8.1 CTS M/U (3/4 3-25) pg 2 of 5 3.3.8.1 CTS M/U (3/4 3-25) pg 2 of 5 Rev 6 3.3.8.1 CTS M/U (3/4 3-26) pg 3 of 5 3.3.8.1 CTS M/U (3/4 3-26) pg 3 of 5 Rev 6 3.3.8.1 DOCS pg i Rev 0 3.3.8.1 DOCS pg i Rev 6 3.3.8.1 DOCS pg 2 Rev 0 3.3.8.1 DOCS pg 2 Rev 6 3.3.8.1 DOCS pg 3 Rev 0 3.3.8.1 DOCS pg 3 Rev 6 3.3.8.1 DOCS pg 4 Rev 6 3.3.8.1 NUREG M/U pg 3.3-75 3.3.8.1 NUREG M/U pg 3.3-75 Rev 6 3.3.8.1 NUREG M/U pg 3.3-77 3.3.8.1 NUREG M/U pg 3.3-77 Rev 6 B 3.3.8.1 NUREG M/U pg B 3.3-220 B 3.3.8.1 NUREG M/U pg B 3.3-220 Rev 6 B 3.3.8.1 NUREG M/U pg B 3.3-220 (Insert) Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-220 (Insert) Rev 6 B 3.3.8.1 NUREG M/U pg B 3.3-222 Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-222 Rev 6 Rev 6 05/28/99
Volume 5: SECTION 33.5.133.8.2 (cont'd): Remove Replace B 3.3.8.1 NUREG M/U pg B 3.3 223 Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-223 Rev 6 B 3.3.8.1 NUREG M/U pg B 3.3-224 Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-224 Rev 6 B 3.3.8.1 NUREG M/U pg B 3.3-225 Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-225 Rev 6 l B 3.3.8.1 NUREG M/U pg B 3.3-225 (Insert) Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-225 (Insert) Rev 6 - l B 3.3.8.1 NUREG M/U pg B 3.3 226 Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-226 Rev 6 j B 3.3.8.1 NUREG M/U pg B 3.3-226 (Insert) Rev 0 B 3.3.8.1 NUREG M/U pg B 3.3-226 (Insert) Rev 6 l 3.3.8.1 JFD's pg i Rev 0 3.3.8.1 JFD's pg 1 Rev 6 3.3.8.1 JFD's pg 2 Rev 6 i Rev 6 05/28/99
ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS
..................................... NOTES --
- 1. Refer to Table 3.3.5.11 to determine which SRs apply for each ECCS Function.
- 2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required m Actions may be delayed as follows: (a) for up to 6 hours for T Functions 3.c and 3.f: and (b) for up to 6 hours for Functions other than g 3.c and 3.f provided the associated Function or the redundant Function q maintains ECCS initiation capability.
SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.5.1.3 Verify the trip unit setpoint. 92 days SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. 18 months SR 3.3.5.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months l FERMI - UNIT 2 3.3 41 Revision 6 05/28/99
ECCS Instrumentation 3.3.5.1 , l Table 3.3.5.1 1 (page 1 of 6) Emergency Core Cooling System Instrunentation APPLICABLE CONDITIONS l NODES REQUIRED REFERENCED OROTER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE i I
- 1. Core Spray System
- a. Reactor Vessel Water 1.2.3. 4(b) B SR 3.3.5.1.1 = 24.8 inche.s Level - Low Low Low. SR 3.3.5.1.2 Level 1 4(a),5(a) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- b. Drywell 1,2,3 4(b) B SR 3.3.5.1.1 s 1.88 psig Pressure - High SR 3.3.5.1.2 ,
SR 3.3.5.1.3 I SR 3.3.5.1.4 1 l SR 3.3.5.1.5 l c. Reacter Steam Dome 1.2.3 4 C SR 3.3.5.1.1 a 441 psig i Pressure - Low SR 3.3.5.1.2
- (Injection Permissive) SR 3.3.5.1.3 8
SR 3.3.5.1.4 SR 3.3.5.1.5 kl 4(a). 5(a) 4 B SR 3.3.5.1.1 SR 3.3.5.1.2 a 441 psig SR 3.3.5.1.3 SR 3.3.5.1.4 g SR 3.3.5.1.5 l
' d. Core Spray Punp 1.2.3. 2 E SR 3.3.5.1.2 (c) 2 Discharge Flow- Low SR 3.3.5.1.4 W (Bypass) 4(a)5(a) ,
- 2. Low Pressure Coolant Injection (LPCI) System
- a. Reactor' Vessel Water 1.2.3. 4 B SR 3.3.5.1.1 a 24.8 inches Level - Low Low Low. SR 3.3.5.1.2 Level 1 4(a). 5(a) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)
(a) When associated subsystem (s) of LCO 3.5.2 are required to be OPERABLE. A (b) Also required to it.itiate the associated emergency diesel generator (EDG). 1 k (c) Administratively controlled. l FERMI UNIT 2 3.3 42 Revision 6. 05/28/99
c l l l ECCS Instrumentation 3.3.5.1 Table 3.3.5.1 1 (page 2 of 6) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS N00ES REQUIRED REFERENCED OROTER CHANNELS FRON SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREENTS VALUE
- 2. LPCI System (continued)
- b. Drywell 1.2.3 4 8 SR 3.3.5.1.1 s 1.88 psig Pressure - High SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- c. Reactor Steam Dome 1.2.3 4 C SR 3.3.5.1.1 a 441 psig Ql 4
Pressure - Low (In,)ection Permitsive) SR 3.3.5.1.2 SR 3.3.5.1.3 "d SR 3.3.5.1.4 Q - SR 3.3.5.1.5 (l 4(a). 5(a) 4 B SR 3.3.5.1.1 a 441 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.4 j SR 3.3.5.1:5 l l d. Reactor Vesse e Water 1.2.3 4 B SR 3.3.5.1.1 e 103.8 Level - Low Lo ' Level SR 3.3.5.1.2 inches 2 (Loop SeleG Logic) 4(a). 5(a) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- e. Reactor Steam Dome 1.2.3 4 'C SR 3.3.5.1.1 e 886 psig Pressure - Low (Break SR 3.3.5.3.2 l Detection Logic) 4(8)5(a) .
SR 3.3.5.1.3 SR 3.3.5.1.4 l SR 3.3.5.1.5
- f. Riser Differential 1.2.3 4 C SR 3.3.5.1.1 s 0.927 psid Pressure ~ High (Break SR 3.3.5.1.2 Detection) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- g. Recirculation Pimp 1.2.3 4/ptap B SR 3.3.5.1.1 s 1.927 psid Differential SR 3.3.5.1.2 Pressure - High (Break SR 3.3.5.1.3 Detection) SR 3.3.5.1.4 l SR 3.3.5.1.5 (continued)
(a) When associated subsystem (s) of LCO 3.5.2 are required to be OPERABLE. 1 l' FERMI UNIT 2 3.3 43 Revision 6. 05/2d/99
ECCS Instrumentation 3.3.5.1 Table 3.3.5.1 1 (page 3 of 6) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS N00ES OR REQUIRED REFERENCED OTHER CHANNELS FRON i SPECIFIED PER REQUIRED SlRVE!LLANCE ALLOWABLE l FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS ~VALUE
- 2. 'LPCI System (continued) s h. Low Pressure 1.2,3, 2 E SR 3.3.5.1.2 (c)
Coolant In etion Pump SR 3.3,5.1.4 S"' l 4(a). 5(a) M Discharf (Bypass ow - Low
- 3. High Pressure Coolant Injection ( WCI) System
- a. Reactor Vessel Water 1, 4 B SR 3.3.5.1.1 a 103.8 Level - Low Low.
SR 3.3.5.1.2 inches l Level 2 2(d),3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- b. Drywell 1, 4 B SR 3.3.5. 1 s 1.88 psig Pressure - High SR 3.3.5. 2 l 2(dl. 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 1 SR 3.3.5.1.5
- c. Reactor Vessel Water 1. 2 C SR 3.3.5.1.1 s 219 inches Level - High. Level 8 SR 3.3.5.1.2 l 2Id). 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4
. SR 3.3.5.1.5
- d. Condensate Storage 1, 2 D SR 3.3.5.1.1 a 0 inches Tank Level - Low SR 3.3.5.1.2 l 2(d),3(d) SR 3.3.5.1.3
. SR 3.3.5.1.4 SR 3.3.5.1.5
- e. Suppression Pool Water 1. 2 D SR 3.3.5.1.1 s 5.0 inches i Level - High SR 3.3.5.1.2 yl 2(d), 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued)
(a) When the associated subsystem (s) are required to be OPERABLE. M} l (c) Administratively controlled. l (d) .With reactor steam dome pressure > 150 psig. l FERMI UNIT 2 3.3 44 Revision 6. 05/28/99 l
ECCS Instrumentation 3.3.5.1 Table 3.3.5.11 (page 4 of 6) Emergency Core Cooling System Instrunentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTER CHANNELS FROM SPECIFIED PER REQUIRED SLRVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREENTS VALUE
- 3. WCI System (continued) 4 f. High Pressure Coolant 1. 1 E SR 3.3.5.1.2 (c)
Injection Pump SR 3.3.5.1.4 Discharge Flow-Low 2 ( d,,,3(d) (8ypass)
- 4. Automatic Depressurization System (ADS) Trip System A t
N a. Reactor Vessel Water- 1. 2 F SR 3.3.5.1.1 a 24.8 Level - Low Low Low. SR 3.3.5.1.2 inches l Level 1 2(d),3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- b. Drywell 1. 2 F SR 3.3.5.1".1 s 1.88 psig Pressure - High SR 3.3.5.1.2 l
2(d), 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- c. Automatic 1. 1 G SR 3.3.5.1.2 s 117 seconds Depressurization SR 3.3.5.1.4 l System Initiation 2(d), 3(d) SR 3.3.5.1.5 Timer , j
- d. Reactor Vessel Water 1. 1 F SR 3.3.5.1.1 a 171.9 !
Level - Low. Level 3 SR 3.3.5.1.2 inches l l (Confirmatory) 2(d), 3(d) SR 3.3.5.1.3 1 SR 3.3.5.1.4 ) SR 3.3.5.1.5 ' cd i i l e. Core Spray Punp 1. 1/punp G SR 3.3.5.1.1 a 125 psig i T. Discharge SR 3.3.5.1.2 i Q l Pressure - High 2(d)3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued) l (c) Adninistratively controlled. l ifl (d) With reactor steam dome pressure > 150 psig. l l FERMI - UNIT 2 3.3 45 Revision 6. 05/28/99
1 ECCS Instrumentation 3.3.5.1 Table 3.3.5.11 (page 5 of 6) Emergency Core Cooling System Instrunentation APPLICABLE CONDITIONS NODES OR REQUIRED REFERENCED OTER CHANNELS FRON SPECIFIED PER REQUIRED SLRVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIRENENTS VALUE
- 4. ADS Trip System A (continued) d, 4l f. Low Pressure Coolant 1, 2/ptmp G SR 3.3.5.1.1 a 115 psig
- Injection Pimp SR 3.3.5.1.2 Discharge 2(d)3(d) SR 3.3.5.1.3 Q l Pressure - High SR 3.3.5.1.4 SR 3.3.5.1.5
- g. Depe11 1, 2 G SR 3.3.5.1.2 s 450 seconds Pressure-High Bypass SR 3.3.5.1.3 l 2(d). 3(d) SR 3.3.5.1.4
- SR 3.3.5.1.5
- h. Nanual Inhibit 1. 1 G SR 3.3.5.1.5 NA l 2(d),3(d)
- 5. ADS Trip System B
-a. Reactor Vessel Water 1. 2 F SR 3.3.5.1.1 = 24.8 inches Level - Low Low Low. SR 3.3.5.1.2 l Level 1 2(d),3(d) SR 3.3.5.1.3 a SR 3.3.5.1.4 r/ SR 3.3.5.1.5 I
- b. Drpell 1, 2 F SR 3.3.5.1.1 s 1.88 psig Pressure - High
- SR 3.3.5.1.2 l 2(d), 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
- c. Automatic 1. 1 G SR 3.3.5.1.2 s 117 seconds Depressurization SR 3.3.5.1.4 l System Initiation 2(d),3(d) SR 3.3.5.1.5 Timer
- d. Reactor Vessel Water 1, 1 F SR 3.3.5.1.1 m 171.9 Level- Low. Level 3 SR 3.3.5.1.2 inches l (Confirmatory) 2(d),3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5
~
8 l e. Core Spray Ptap 1, 1/ptmp G SR 3.3.5.1.1 = 125 psig Discharge SR 3.3.5.1.2 hl i Pressure - High 2(d). 3(d) SR 3.3.5.1.3 SR 3.3.5.1.4 SR 3.3.5.1.5 (continued) Vl (d) With reactor steam dome pressure > 150 psig. ./ l FERMI UNIT 2 3.3 46 Revision 6. 05/28/99
r l l l \ i ! ECCS Instrumentation l 3.3.5.1 Table 3.3.5.1 1 (page 6 of 6) Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SLRVEILLANCE ALLOWABLE [ FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREENTS VALUE hi- 5.- ADS Tri System B- \ (conti ued) l 4l f. Low Pressure Coolant Injection Ptsp
- 1. 2/pu9 G SR 3.3.5.1.1 SR 3.3.5.1.2 e 115 psig Al ' Discharge 2(d),3(d) SR 3.3.5.1.3 Pressure - High SR 3.3.5.1.4 l SR 3.3.5.1.5 '
g .- Dryw11 1. 2 G SR 3.3.5.1.2 s 450 seconds Pressure-High Bypass SR 3.3.5.1.3 2(d),3(d) fl - SR 3.3.5.1.4 SR 3.3.5.1.5
- h. Manual Inhibit 1. 1 G SR 3.3.5.1.5 NA Il 2(d), 3(d) ,
l (d) With reactor steam dome pressure > 150 psig. 1 i I 1 l l FERMI UNIT 2 3.3 47 Revision 6. 05/28/99 i
i ECCS Instrumentation 1 B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES. LC0. and APPLICABILITY (continued) Four channels of Reactor Steam Dome Pressure-Low Function are only required to be OPERABLE when the ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude ECCS initiation. Refer to LC0 3.5.1 and LC0 3.5.2 for Applicability Bases for the low pressure ECCS subsystems. O charo F o - Lo ( voass
)
The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump. is operating and the associated injection valve is not l j fully open. The minimum flow line valve is opened when low { flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump. The LPCI and CS Pump Discharge Flow-Low Functions are assumed to be OPERABLE and capable of closing the minimum flow valves to ensure that the low pressure ECCS flows assumed during the transients and accidents analyzed in References 1. 2. and 3 are met. The core cooling function of the ECCS along with the scram action of the RPS. ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. . One flow switch per ECCS division is used to detect the associated division flow rates. The logic is arranged such that each switch causes its associated minimum flow valve to open. The logic will close the minimum flow valve once the closure setpoint is exceeded. The LPCI minimum flow valves are time delayed such that the valves will not open for 15 seconds after the switches detect low flow. The time delay is provided to limit reactor vessel inventory loss Q during the startup of the RfiR shutdown cooling mode. The Pump Discharge Flow-Low Allowable Values are established d and controlled administratively. The value is chosen high enough to ensure that the pump flow rate is sufficient to protect the pump. yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. Each channel of Pump Discharge Flow-Low Function (two CS channels and two LPCI channels) is only required to be OPERABLE when the associated ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude the l FERMI UNIT 2 B 3.3.5.1 - 11 Revision 6. 05/28/99 ;
1 ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES. LCO, and APPLICABILITY (continued) ECCS function. Refer to LC0 3.5.1 and LC0 3.5.2 for Applicability Bases for the low pressure ECCS subsystems. 2.d Reactor Vessel Water Level-Low Low Level 2 (Looo Selection Looic) LPCI Loop selection logic is initiated on decreasing RPV water level at level 2. This gives the logic time to detect the broken recirculation loop and select the unbroken recirculation loop for'LPCI injection. The LPCI pumps are , initiated at level 1. I Reactor Vessel Water Level-Low Low. Level 2 signals are inifiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. The transmitter signals feed trip units whose outputs drive relays. Output contacts of the relays are configured in a one out-of two taken twice initiation logic. The same instrumentation and relay logic is used for HPCI initiation (Function 3a). That system's design basis establishes the, Allowable Value while accounting for measurement uncertainties. LPCI loop selection initiation is not directly assumed by any safety or transient analysis, but is required to function to su) port the LPCI system. which is assumed to function in t1e accident analysis (Ref. 1) . Four channels are required to be OPERABLE whene er LPCI is required to be OPERABLE to ensure that no singh instrument failure can preclude LPCI initiation. 2.e. Reactor Steam Dome Pressure-Low (Break Detection Looic) This function is provided in the LPCI break detection logic. If only.one recirculation pump is running, the logic trips that pump in order to obtain a meaningful measurement of recirculation riser differential pressure (Function 2.f). Reactor Steam Dome Pressure-Low inhibits the break detection logic from acting on the value of riser , differential pressure until reactor pressure has fallen ! below the set point due to the pump trip. This allows the logic to identify the broken recirculation loop. Although .s* l FERMI '- UNIT 2 B 3.3.5.1 - 12 Revision 6. 05/28/99 9
I l l ECCS Instrumentation B 3.3.5.1 j 1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) this function is not directly assumed by the safety analysis, it is required for the LPCI loop selection logic. and LPCI to be OPERABLE, and is therefore a supporting function for that assumed by the analysis of Reference 1. Reactor Steam Dome Pressure-Low . :gnals are initiated from four pressure transmitters that sense reactor steam dome pressure. The Allowable Value was selected, allowing for measurement uncertainties, to give adequate time, based on reactor pressure decrease following RPT, for an accurate riser differential pressure measurement to be made. The logic for this Function is one out of two taken twice. Four channels of Reactor Steam Dome Pressure-Low are required to be OPERABLE when LPCI is required to be OPERABLE to ensure that no single instrument failure can preclude LPCI injection.
- 2. f. Riser Differential Pressure-Hiah (Break Detection)
The LPCI break detection logic determines which recirculation loop is broken by comparing the pressure of the two recirculation loops. The broken loop will indicate a lower pressure than the unbroken loop. The loop with the higher pressure is then used for LPCI injection. If both pressures are the same, loop B is selected by default. Riser Differential Pressure-High signals are initiated from four differential pressure transmitters that sense the difference between corresponding recirculation loop riser pipes. Logic is one out of two taken twice. The Riser Differential Pressure-High Allowable Value is selected, allowing for measurement uncertainties, based on . the analytical limit of 1.0 psid between corresponding l risers. Four channels of Riser Differential Pressure-High are , required to be OPERABLE to ensure that no single instrument ' failure prevents LPCI injection into the unbroken riser loop and support the LPCI function. 1 FERMI UNIT 2 B 3.3.5.1 - 13 Revision 6. 05/28/ l 1
ECCS Instrumentation , B 3.3.5.1 ' BASES APPLICABLE SAFETY ANALYSES. LC0. and APPLICABILITY (continued) l Two channels of Suppression Pool Water Level-High Function are required to be OPERABLE only when HPCI is required to be OPERABLE to ensure that no sir.gle instrument failure can preclude HPCI swap to suppression pool source. Refer to LC0 3.5.1 for HPCI Applicability Bases.
- 3. f. Hiah Pressure Coolant In.iection Pumo Discharae Flow-Low (BYDass)
The minimum flow instruments are arovided to protect the HPCI pump from overheating when tie pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed. < and the valve is automatically closed when the flow rate is adequate to protect the pump. The High Pressure Coolant 1 Injection Pump Discharge Flow-Low Function is assumed to be OPERABLE and capable of closing the minimum f. low valve to ensure that the ECCS flow assumed during the transients and i accidents analyzed in References 1, 2, and 3 are met. The l core cooling function of the ECCS, along with the scram l action of the RPS, ensures that the fuel peak cladding i temperature remains below the limits of 10 CFR 50.46. One flow switch.is used to detect the HPCI System's flow rate. The logic is arranged such that the switch causes the minimum flow valve to open. The logic will close the minimum flow valve once the closure setpoint is exceeded. eq The High Pressure Coolant Injection Pump Discharge Flow-Low .
- 1. Allowable Value is established and controlled l 5 administratively. The value is chosen high enough to ensure X that pump flow rate is sufficient to protect the pump. yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core.
One channel is required to be OPERABLE when the HPCI is I required to be OPERABLE. Refer to LC0 3.5.1 for HPCI j Applicability Bases. j i Automatic Deoressurization System ! 4.a. 5.a. Reactor Vessel Water Level-Low Low Low. Level 1 l Low RPV water level indicates that the capability to cool ' the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, ADS receives l FERMI UNIT 2 B 3.3.5.1 - 18 Revision 6. 05/28/99
ECCS Instrumentation ' B 3.3.5.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) one of the signals necessary for initiation from this I Function. The Reactor Vessel Water Level-Low Low Low. Level 1 is one of the functions assumed to be OPERABLE and capable of initiating the ADS during the accident analyzed in Reference 1. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of ] 10 CFR 50.46. l 4 Reactor Vessel Water Level-Low Low Low, Level 1 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual , water level (variable leg) in the vessel. Four channels of
~
i Reactor Vessel Water Level-Low Low Low, Level 1 Function are required to be OPERABLE only when ADS is required to be OPERABLE to ensure that no single instrument failure can preclude ADS initiation. Two channels input to ADS trip l system A, while the other two channels input to ADS trip system B. Refer to LC0 3.5.1 for ADS Applicability Bases. The Reactor Vessel Water Level-Low Low Low, Level 1 Allowable Value is chosen to allow time for the low pressure core flooding systems to initiate and provide adequate cooling. 4.b. 5.b. Drywell Pressure-Hiah High pressure in the drywell could. indicate a break in the RCPB. Therefore, ADS receives one of the signals necessary for initiation from this Function in order to minimize the possibility of fuel damage. The Drywell Pressure-High is assumed to be OPERABLE and capable of initiating the ADS during the accidents analized in Reference 1. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. Drywell Pressure-High signals are initiated from four pressure transrot'ers that sense drywell pressure. The . Allowable Va h 5 selected to be as low as possible and be l indicative of a c0CA inside primary containment. I l i
]
i J j B 3.3.5.1 - 19 Revision 6. 05/28/99 hlFERMIUNIT-i
ECCS Instrumentation , B 3.3.5.1 l BASES ACTIONS (continued) changes from 96 hours to 8 days. the " time zero" for beginning the 8 day " clock" begins upon discovery of the ! inoperable channel. If the ino)erable channel cannot be i
, restored to OPERABLE status wit 11n the allowable out of service time. Condition H must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events.
IL1 With any Required Action and associated Completion Time not met, the associated feature (s) may be incapable of performing the intended function. and the supported feature (s) associated with inoperable untripped channels must be declared inoperable immediately. i SURVEILLANCE As noted in the beginning of the SRs. the SRs for each ECCS REQUIREMENTS instrumentation Function are found in the SRs column of Table 3.3.5.1 1. l The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated te) Conditions and Required Actions may be delayed for up to T 6 hours as follows: (a) for Functions 3.c and 3.f: and g (b) for Functions other than 3.c and 3.f provided the q associated Function or redundant Function maintains ECCS initiation capability. Upon completion of the Surveillance, or expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Ref. 4) assumption of the average time required to perform channel surveillance. That analysis demonstrated that the 6 hour testing allowance does not significantly reduce the probability that the ECCS will initiate when necessary. SR 3.3.5.1.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other V l FERMI UNIT 2 B 3.3.5.1-33 Revision 6 05/28/99
l l ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited to I 12 hours; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, i including indication and readability. If a channel is l outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequency is based upon ope'ating ex)erience that demonstrates channel failure is rare. T1e CHANNEL CHECK supplements less formal, but more frequent, checks of . channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.5.1.2 . A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A suc'cessful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL @ FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Soecifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of 92 days is based on the reliability analyses of Reference 4. l FERMI UNIT 2 B 3.3.5.1 - 34 Revision 6. 05/28/99 I
f l l ECCS Instrumentation l B 3.3.5.1 1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.5.1.3 ! This surveillance provides a check of the actual trip . setpoints. The channel must be declared inoperable if the j trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.11. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint meth dology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analyses. Under these conditions. the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in _the appropriate setpoint methodology. The Frequency of 92 days is based on the reliability analysis of Reference 4. SR 3.3.5.1.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL' CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. The Frequency of SR 3.3.5.1.4 is based upon the assumption of a = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. 1 I a." m p l FERMI. UNIT 2 B 3.3.5.1 - 35 Revision 6 05/28/99 j i
ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.5.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.1. LC0 3.5.2. LC0 3.8.1, and LC0 3.8.2 overlaps this Surveillance to complete testing of the assumed safety function. l The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant ) outage and the potential for an un)lanned transient if the ' Surye111ance were performed with t1e reactor at power. Operating experience has shown that these components usually , pass the Surveillance when performed at the 18 month i Frequency. I REFERENCES 1. UFSAR Section G.3.
- 2. UFSAR, Chapter 15. I
- 3. NEDC 31982 P.. " SAFER /GESTR LOCA, Loss of '.olant Accident Analysis, including Errata and A0denda No.1."
April 1992.
- 4. NEDC 30936 P A. "BWR Owners' Group Technical Specification Improvement Analyses for ECCS Actuation Instrumentation, Part 2." December 1988.
l FERMI UNIT 2 8 3.3.5.1 - 36 Revision 6 05/28/99
I 1 Sfec tncAvoM 3.5.5.1 \ [dI2 su S*ecificd% 3.3.F.J) 7.3 5.H TABLE 3.3.3-1 (Continued) ENERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION ACTION STATEMENTS With the number of OPERABLE channels less than recuired by the A ON 30 - { g' M m OPERABLE Channels per tTrip)A05 fripsys4(m oy"am requirement: ID F or one trip system. niace that trip s in h ripped /' gCN g'b O % a. condition e associated ECCS within(24 hourslor de(lare (kmm A CTION N "j,'[i'- t,3 ,. TAN.ii D M 1.g dsa.1Asom do J.,
,b. [Forbothtr Rd Act e '. ."..
" *2ip ds Qclare th_e associated ho *W WD \
8 2 f 'WiththenumberofOPERABLEchannelslessbanrequiredbythei ECCS' G& ACTION 31 - 10 Minimum OPERABLE Channels per Trip System recuirement, declare l Ma Acr F.7.* 6.1 associated ADS Trip System inoperable within 24 hours. .1 ACT100 W Ag o geg A,6. d.# s7- the ACTION 32 - With the number of OPERABLE channels less than recuired N nimum g RABy_Channe}, s per Tr Sys{ey nou _ pys J g,l kEd ACT Ce7.- _ _ hours.(gde.ca e, f,6ggg gg g ACTION 33 - Restore the manual initiation and/or manual inhibit function to iI p'p
#E4 4cr 4,2 OPERABLE status within 24 hours or declare the associated ECCS M Ti w g or ADS Trtp System inop(rable.
0,1 d G . ' . 660 RETA With ACT ber of OPEP/BLE channels less than required by the the num ACTION 34 - System recuirement, place at RE A4c.T D.Ll 0,1.'2least Minimum OPERABLE one inoperable channel Channels in t per Tri$e tripped condition within 3 24 hours, align the HPCI system to take suction from the '! suppression pool, or declare the HPCI system inoperable. A CT10M S , ACTION 35 M the number of OPERABLE channels:
- a. One less than the Total Number of Channels, restore the
, inoperable channel to OPERABLE status within 72 hours or declare the associated emeroency ciesel oenerator inoperable and take the ACTION reoutred 6y Specification (Ed 3.8.1.1 or 3.8.1.2, as appropriate, f,
ihI(atf07) b. Less than the Minimum Channels OPERABLE recuirement, declare the associated diesel generator inoperable and J'g*p* / take the ACTION required by Specification 3.8.1.1 or 3.8.1.2, as appropriate. 3/4 3 26 Amendment No. J3, /J, 83 FERMI - UNIT 2 PAGE_ d 0F O'8 hv(s . 1
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DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 . ECCS INSTRUMENTATION ADMINISTRATIE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1. A.2 ITS LC0 3.3.5.1 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LCO. ;
" Separate Condition entry is allowed for each channel." This is
{ acceptable because the Required Actions for each Condition provide j appropriate compensatory actions for each inoperable ECCS channel. j Complying with the Required Actions will allow for continued l operation: with subsequent inoperable ECCS channels governed by l subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on safety because the clarifications provided by the Note are consistent with the existing interpretation of the CTS. A.3 CTS 3.3.3 specifies Actions for ECCS channels with setpoints not within allowable values. These Actions state " declare the channel l7 i inoperable until the channel ts restored to Operable status." ITS 3.3.5.1 contains all the requirements and Actions for ECCS y ' channels, including the allowable values and Actions when it is not met. The usage rules of Technical Specifications adequately f i dictate that channels be declared inoperable and Actions taken until restored to Operable, without a specific statement to that effect. Therefore, elimination of this statement is an administrative presentation preference only. A.4 CTS 4.3.3.2 requires an LSFT "and simulated automatic operation" g of all channels. The " simulated automatic operation" is i interpreted to be included in the LSFT. This additional detailing lQ of the required test is unnecessary. Therefore its elimination is an administrative change. y g =r* FERMI UNIT 2 1 REVISION 6 05/28/99l
l 1 l i DISCUSSION OF CHANGES . ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION ) A.5 CTS 3.3.3 footnote
- permits the extension of EDG output breaker j logic system functional testing until the first outage after 9/29/95. This allowance will no longer be applicable and is removed. This is an administrative change because it deletes an ;
allowance that is no longer applicable and has no impact on j safety. l I A.6 CTS Table 3.3.31 identifies the minimum Operable channels "per Trip System." ITS Table 3.3.5.1-1 specifies the minimum required channels based on "per function." This causes the number of ; required channels in the ITS columns to be doubled from that specified in the CTS for Functions having two trip systems. This new categorization is used for all ECCS. except the ADS. For the l ADS. each of the two trip systems are listed in the ITS Table. ) thus, the channels per Function do not change. Additionally. CTS j Function 2.g (Recirculation Pump Differential Pressure) number of ) channels is stated as 2 per trip system: however this Function is ! further interpreted to apply to each recirculation pump. l Therefore, the equivalent ITS Function 2.9 is stated as 4/ pump. These are administrative changes in presentation format with no change in the requirements. A.7 CTS Table 3.3.3-1. Note (a), allows required surveillance testing "without placing the trip system in the tripped condition." ITS SR Note 2 provides this allowance, but is stated as " entry into the associated Conditions and Required Actions may be delayed." This represents a clarification of the intent and as such is considered an administrative change. A.8 CTS Table 3.3.3-1 Action 30.b requires that on discovery of inoperable channels in both trip systems, declare the associated ECCS inoperable. This level of inoperability may reflect a loss of initiation capability in both divisions. In this case, g ITS 3.3.5.1 Required Actions B.1. B.2. C.1 and F.1 address the \ same requirement. In this conversion. Required Actions B.1. B.2 g and C.1 are modified by a Note (Note 2 for B.1 and C.1). These g Notes clarify the appropriate Functions which are required to - comply with these particular actions. Except as addressed in d other changes (e.g., refer to DOC L.4 for actions when loss of function has not occurred), these ITS Required Actions and associated Notes reflect requirements consistent with this CTS action for the loss of function inoperability. FERMI UNIT 2 2 REVISION 6. 05/28/99l
l i DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 - ECCS INSTRUMENTATION A.9 CTS 4.3.3.3 requires ECCS Response Time testing however, the details of the testing acceptance criteria are located in the Technical Requirements Manual (TRM): outside of Technical Specifications. Since the ECCS response time acceptance criteria includes testing only the ECCS system response (and utilizing assumed values for the ECCS instrumentation response), the required Surveillance is more appropriately required in the ECCS Sp'ecification, ITS 3.5.1. This change is a presentation preference only with no technical change or change in intent. Refer to Section 3.5 for further discussion of any changes from the CTS presentation. A.10 CTS Table 3.3.3 1 Actions 30.a. 31. and 33, as they apply to inoperable ADS actuation channels, result in options to declare associated ADS Trip System inoperable. (Note: refer to DOC L.1 for discussion of CTS change from declaring ECCS inoperable to declaring ADS trip system inoperable for CTS Action 30.a.). The CTS actions would then transfer to Action c of CTS 3.3.3. and provide additional time for restoration. ITS 3.3.5.1 Actions F and G combine these restoration times for clarity. Any technical e changes are addressed in other discussions of change. The revised i presentation preference is an administrative change with no impact on safety. {NotealsothatCTSAction30.b(convertedtoITS g Required Action F.1) does not transfer to CTS Action c for additional time: it declares the ADS valves inoperable and transfers Actions to LC0 3.5.1. The ITS 1-hour Completion Time of Required Action F.1 matches the CTS Action 30.b time. and the ITS RequiredActionH.1matchesthetransferofActionstoLC03.5.1.} A.11 CTS 4.3.3.2 requires an 18 month LSFT of all ECCS Instrumentation channels (which would include ADS Manual Inhibit function). CTS Table 4.3.3.1 1. Item 4.1. also required an 18-month Channel Functional Test of the ADS manual Inhibit function. ITS Table 3.3.5.1 1 only requires the LSFT (SR 3.3.5.1.5) for this o function. The Channel Functional Test for this function is i adequately encompassed by the LSFT performance. Eliminating a E reference to performing a Channel Functional Test is therefore an administrative change that eliminates a duplicative test. s) FERMI - UNIT 2 3 REVISION 6. 05/28/99l
-DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION l e4 M.4 Not used. 1 M.5 CTS Table 3.3.3-1 for Function 4.e specifies the number of lk Operable RHR pump discharge pressure permissive channels for ADS as "1/ pump." ITS increases the required number of channels to )
"2/ pump." This change is made to accurately reflect the plant l design, which provides for and requires 2 channels for each RHR i pump to provide the necessary ADS permissive. This added l restriction ensures that the necessary number of permissive !
channels is required. -Therefore, this change will not have a negative impact on safety. TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" -
LA.1 CTS 3.3.3 requires that ECCS actuation instrumentation trip setpoints to be within Trip Setpoint column values of CTS Table 3.3.3-2. Additionally. CTS 3.3.3 Action a requires that an inoperable ECCS actuation instrument channel setpoint be restored consistent with the trip setpoint value. However, Actions only apply if the allowable value is exceeded. ITS 3.3.5.1 requires
.only that instrumentation setpoints be within the allowable value.
Trip setpoints reflect operational ' details while the allowable K value reflects channel Operability. Requirements for trip i setpoints are relocated to the Technical Requirements Manual g (TRM), which requires revisions be controlled by 10 CFR 50.59. 4 The trip setpoint is established based on a combination of y instrument design factors, environmental factors. and the , allowable value (which is what is conservatively derived from the value assumed in the safety analyses). This continues to provide g adequate protection of the public health and safety since the requirement for instrument channel Operability and the allowable g value setpoint continues to be required by the Technical Specifications. LA.2 CTS Table 3.3.3 1 footnotes (c). (d), and (e), and various setpoint details (and associated footnotes) of Table 3.3.3 2, provide design details and descriptive details for various ECCS actuation functions. ITS 3.3.5.1 addresses this information in the Bases and plant. design documents, and does not include these details in the Technical Specifications. This change is consistent with NUREG 1433. The information moved to the Bases requires changes to be controlled in accordance with the ITS .j 5.5.10. Bases Control Program. Information contained within plant design documents requires changes to be controlled in accordance FERMI UNIT 2 5 REVISION 6. 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 - ECCS INSTRUMENTATION with 10 CFR 50.59. This relocation continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability continues to be required by the Technical Specifications. l LA.3 CTS Tables 3.3.3-1. 3.3.3-2 and 4.3.3.1 1 Manual initiation Functions (1.d. 2.h 3.f. and 4.9) are relocated from Technical Specifications to the Technical Requirements Manual (TRM) (Surveillance testing and inoperability actions). The Technical Requirements Manual (TRM), which requires revisions be controlled by 10 CFR 50.59, assure that adequate protection of the public health and safety is maintained. These manual functions are lh ' simply the individual valve and pump control switches. NUREG-1433 Table 3.3.5.11 Manual Functions (as described in the ITS Bases) address plant designs that incorporate system-level initiation
" push buttons." The Fermi design does not incorporate any system-level initiation (e.g., a single " push button" that would result in HPCI initiation and injection). Therefore, relocation of these individual component controls is consistent with the non-Technical Specification nature of all other individual component controls.
LC.1 CTS Table 3.3.31. footnote (a), allows required surveillance testing which causes channels to be inoperable without taking Actions for inoperable channels "provided at least one OPERABLE channel in the same trip system is monitoring that parameter." ITS SR Note 2 addresses this allbwance, but includes a less restrictive change for HPCI Functions 3.c and 3.f. The ITS allowance to delay entering Action applies to these functions even hm though that individual trip function may not have an Operable i channel in the same trip system. For these Functions, the logic Q either: 1) does not contain more than one channel in the trip T system (HPCI Flow-Low), or 2) for HPCI Level 8 Function, is such ld that one inoperable channel results in the individual trip function not being maintained even with another Operable channel. For the HPCI Level 8 Function, the logic is 2 out-of 2 (i.e., one i Operable channel will not perform the function). Since NEDC-30936P A, "BWR Owner's Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation)," December 1988, approved the allowance for delay in entering Actions for these channels, this change has a , negligible impact on safety. This is acceptable based on the ! remainihg capabilities, the low probability of extensive numbers l 's of inoperabilities affecting all diverse Functions, and the low { probability of an event requiring ECCS. I FERMI UNIT 2 6 REVISION 6. 05/28/99l l
DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION LR.1 CTS Table 3.3.3-2 specifies the allowable values for each Function. However, only for 5 Functions in the ECCS actuation Table (and not in any other instrumentation Table) do these values also include the descriptive method of calibration testing " increasing" or
" decreasing." ITS Table 3.3.5.1-1 specifies these allowable values N but eliminates the descriptive method of calibration' testing. This I detail can be removed from the Technical Specifications without affecting the required allowable value or the required Channel Calibration. Therefore, regulatory control of changes to this requirement (e.g., Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and safety.
TECHNICAL CHANGES - LESS RESTRICTIVE "Speci fic" L.1 CTS 3.3.3 Action c provides actions for inoperable ADS actuation instrument trip systems that requires restoration to Operable status within either 7 days or 72 hours (depending on the status of HPCI and RCIC), otherwise a plant shutdown is required. CTS Table 3.3.3-1 Action 30.a. as they apply to certain inoperable ADS actuation channels, allows 24 hours prior to declaring the
" associated ECCS inoperable" (which in this case would be all ADS valves). This declaration is being relaxed to more appropriately declare the affected ADS trip system inoperable, allowing 7 application of the additional time of CTS Action c. This g
relaxation will result in total restoration times of 8 days or w 3 96 hours (depending on the status of HPCI and RCIC). k ITS 3.3.5.1 Required Action F.2 provides these Completion Times, however, it also provides an option to trip certain inoperable ADS actuation instrument channels, allowing continued operation. Furthermore, the "otherwise" action (ITS 3.3.5.1 Action H), rather than require'a plant shutdown, requires " declare the associated support feature (s) inoperable." This allows the Actions of ITS 3.5.1 "ECCS." to direct further Actions, which may include a plant shutdown. However, if the actuation instrument inoperability is known to affect only a single ADS valve, the transition of actions to ITS 3.5.1 would provide additional time to restore the inoperability prior to requiring a plant shutdown. These relaxations do not introduce a significant impact on safety e; since the ADS function would be maintained during these action 5>> , extensions. These Completion Times are consistent with those p' proposed in NUREG 1433. R FERMI - UNIT 2 7 REVISION 6 05/28/99l ;
I i l l ! 1 1 DISCUSSION OF CHANGES l ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION l
- l l L.2 CTS 3.3.3 Tables contain no explicit Functions for ECCS pump minimum flow instrumentation. On discovery of inoperable minimum flow instrumentation the associated ECCS pump would be considered inoperable with the associated subsystem actions applied. ITS Table 3.3.5.11 includes the following Functions, including associated Actions. Surveillance Requirements, and reference to Q the administratively controlled allowable values: 1 1.d Core Spray Pump Discharge Flow Low:
2.h Low Pressure Coolant Injection Pump discharge Flow Low; and 3.f High Pressure Coolant Injection Pump Discharge Flow-Low. ITS 3.3.5.1 Action E is included to address inoperability of any minimum flow instrument channel, and provides up to 7 days (after confirming that both divisions have not lost initiation capability) prior to entering actions for an inoperable ECCS 1 subsystem. This additional time is justified based on the limited I degradation caused by inoperable minimum flow instrumentation. With instrumentation inoperable such that pump minimum flow protection is lost, manual pump operation would remain to provide core cooling. With instrumentation. inoperable such that pump minimum flow valve remains open, only a portion of coolant injection to the core *is diverted: with a majority of coolant flow capability remaining for core cooling. Furthermore. based on the redundancy in the ECCS design and the low probability of an event requiring the ECCS function, this change represents minimal impact on safety. This relaxation in action requirements is consistent with NUREG 1433. The values at which the minimum flow function is designed to tr> operate are not based on analytical assumptions, and therefore do A not fit the ITS use of " allowable value." These values are administratively controlled based on nominal settings. This is k reflected in ITS fcotnote (c) consistent with CTS requirements. L.3 CTS Table 3.3.3-1 Action 30.b applies an immediate transfer of actions to associated actions for ECCS inoperability, when both trip systems have inoperable channels (potentially both divisions of ECCS lost initiation capability). This CTS action applies to , several Functions with applicability in Modes 1. 2. 3. 4. and 5. ITS 3.3.5.1 Required Actions B.1 and C.1 are modified by a Note 1 l that limits the immediate (i.e.. I hour prior to transfer; j
,. discussed in a separate justification) transfer of actions in the FERMI - UNIT 2 8 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 - ECCS INSTRUMENTATION 4 event of loss of initiation capability to apply only while in Modes 1. 2. and 3. This change will increase the allowed l restoration time for a total loss of initiation capability from one or more Functions while in Modes 4 and 5 to 24 hours (as j limited by Required Action B.3). This is acceptable because the actuation of ECCS flow to the core at a specified time is not assumed in any Mode 4 or 5 accident analysis. Events initiated i while in these lower Modes result in significantly reduced l consequences and significantly increased margins of safety. ITS l 3.5.2 continues to assure that sufficient ECCS is available in l Modes 4 and 5. and ITS 3.3.5.1 continues to require Operable ' actuation instrumentation. Therefore, this change will have a minimal impact on safety. L.4 {Bothmorerestrictiveandlessrestrictivechangesareproposed andcombinedinthisdiscussionforclarityandcompleteness.} For Functions referencing CTS Table 3.3.3-1 Action 30.a and 30.b. Other than ADS initiation (refer to DOC L.1 for changes associated with the ADS Function), the logic is 1 out of 2 taken twice (each of two trip systems with 1 out of 2 logic). As such CTS Action 30.a (inoperable channel (s) in one trip system - allowing 24 hour restoration time) could reflect a loss of initiation function if both channels in one trip system are inoperable. ITS Required Actions B.1, B.2, and C.1 would limit Completion Times to 1 hour for loss of initiation function (a more restrictive chdnge), while ITS Required Actions B.3 and C.2 retain this 24 hour Completion Time. In the case of CTS Action 30.b (inoperable channel (s) in both trip systems - requiring an immediate transfer of actions to associated h actions for ECCS inoperability) the inoperabilities may or may i not reflect a loss of initiation function (e.g., in the event only one inoperable channel is in each trip system, initiation function would be available). ITS Required Actions B.1. B.2, and C.1 would extend the Completion Time to I hour for loss of initiation function, while ITS Required Actions B.3 and C.2 extend the Completion Time to 24 hours when initiation function is retained. These changes are acceptable based the expectation that manual or other automatic (e.g., initiation on low level if high drywell pressure is also inoperable) initiation capability would remain, and base'd on the low probability of an event that would require j these automatic initiations. Furthermore, these changes correct deficiencies in the CTS that would allow inappropriate restoration FERMI UNIT 2 9 REVISION 6 05/28/99l
i I DISCUSSION OF CHANGES ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION j l times for some inoperabilities that reflect a loss of initiation function. The proposed ITS Actions are consistent with NUREG-hi l 1433. In the case of Mode 4 or 5 operation, the actuation of ECCS ! flow to the core at a specified time is not assumed in any Mode 4 k ' or 5 accident analysis. Events initiated while in these lower Modes result in significantly reduced consequences and significantly increased margins of safety. ITS 3.5.2 continues to as'sure that sufficient ECCS is available in Modes 4 and 5 and ITS 3.3.5.1 continues to require Operable actuation instrumentation. Therefore, this change will have a minimal impact on safety. 1 RELOCATED SPECIFICATIONS None-TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.3.5.1 consistent with the BWR STS. NUREG-1433. Rev. 1. I ( J l FERMI - UNIT 2 10 REVISION 6. 05/28/99l J
1 ECCS Instrumentation 3.3.5.1 ACTIONS (continued) CONDITION REQUIRED ACTION CONPLETION TIME G. As required by G.1 ------- NOT E--------- l Required Action A.1 Only applicable for and referenced in Functions 4.c, 4.e, ODC # h - Table 3.3.5.1-1. 4.f. 4.g. 5.c, 5.e, ! 5.f, and 5.g. 1 Declare ADS valves I hour from inoperable. discovery of loss of ADS initiation capability in { both trip systems
- S G.2 Restore channel to 96 hours from at 3 3 3 -1, OPERABLE status. discovery of A cte 31,75 inoperable 4 !
~ channel '
concurrent with I' 3 ' 3 ' HPCI or RCIC A '" "' inoperable ! E 8 days d H. Required Action and H.1 Declare associated Imediately associated Completion 78L34,3-l supported feature (s) 2 Time of Condition B, inoperable. Ac.fio* M.^ D, E, F, or G not . g Ac}/m 3V BWR/4 STS 3.3-40 Rev 1, 04/07/95
ECCS Instrumentation i 3.3.5.1 1 1 SURVEILLANCE REQUIREMENTS (C75)
...-------.-----------.-----..-------NOTES--------- --- - ---------=- -==---
- 1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function. j
- 2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Rcquired Actions may be delayed as follows: (a) for up to 6 hours for ' to Functions 3.c .f. and (b) for up to 6 hours for Functions other T than 3.c provided the associated Function or the redundant Function aint ECCS initiation capability.
SURVEILLANCE FREQUENCY SR 3.3.5.1.1 Perform CHANNEL CHECK. 12 hours (933l) SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. 2pdays (433.1) _ _ et 4. n l f.) 3.3.5.1.3 ...,c.ts the trip uni . %h " p2gdays
/
SR .5.1.4 Perfo , ANNEL CALIB ON. 92 day SR .3.3.5.1. Perform CHANNEL CALIBRATION.
$8(months h '$ bi )
,4 SR 3.3.5.1 Perform LOGIC SYSTEM FUNCTIONAL TEST. gl8 months (y . 3,3,2.)
l SR 3.3.5.1.7 Ve ify the ECCS RESPONSE T E is within {18) onths on mits, a GGERED OOC 00) T BASIS l
/ .
l ll BWR/4 STS 3.3-41 Rev 1, 04/07/95 S 1 l
ECCS Instrumentation 3.3.5.1
.s m \
table 3.3.5.1 1 (pose 1 of 6) Emergency Core Cooline system Instrsmentation gg 3,J,3-/
- 1. 5 3 L APPL!Casta TUBES REQUIRED Concificus REFERENCED
\-
V33I-l Da OTER ChAmutts FacM \pggg SPECIFIED pea REeulaED suave!LLANCE ALLOWAsLE RasCTION CDuelT10ms FnAfCTION ACTION A.1 AEGulREMENTS VALUE
- 1. Core sprey system
- e. asester Vessel Water 1,2,3, g4K(b) e sa 3.3.5.1.1 t (=ttSP /
Levet -Low Lev Low, sa 3.3.5.1.2 Inches N l* g (/ Level 1 4(e),$(s) yta 3.3.5.1 sa 3.3.5.1 sa !~ !.!..!.._,
- b. Drywell 1,2,3 sa 3.3.5.1.1 Pressure - Nish 44kb) e sa 3.3.5.1.2 s pois
,Q Wsa 3.3.5.1.3 sa 3.3.5.1
!!.!.1._,
yq,
- s. Reactor stese Dame 1,2,3 Pressure - Low f4( C sa 3.3.5.1.1 sa 3.3.5.1.2 [
e ' sit J.C (Injection Permisolve) Wst 3.3.5.1. M gJ sa 3.3.5.1 i sa 3.3.5.1
= :.:.: .
g y
# " A'k ' "
i:!:!::1 Q ( f.c')J
.xsa 3.3.5.1.3 d
': i:!:!:1.fQp
- en -
- d. Co,e 5,,ey -
Discherse Flow-Low
'i,2,3, a
- !? p -
E &- n.:.r / sa 3.3.5.1.2 / (s - .> 4(o, 5(a - 30cc L. 2. N, , sa 3 3.;.gg's (c) A, n nittett 1,2, C23 C sa 3.3.5.1.6 mA (1 per T N14enue (*), 5(*) C :d
- 2. Low Freasure Coolant injection (LPCI) system fil
- e. Reector Wessel Water 1,2,3, (4 e sa 3.3.5.1.1 .t -f r Level-Low Low Low, sa 3.3.5.1.2 Irste tevet 1 4(*), 5(*) Wt 3.3.5.1.3 [
sa 3.3.5.1 (2,4
- !???,
(continued) fLt D 3. Q.2-to) When essectated shystem(s) %re respJired te_ be_0PfaAaLE. _ [t meee ew (b) Also recpJfred to inittete the associated (Kaissen ..f) tor ( eitt"twh ": Z:x'.6 enern
--.a.__ _ m- ...aan, w _ . , ai., ; ;.. L .
BWR/4 STS 3.3-42 Rev 1, 04/07/95 ,9 k'I (() Ad Wn'idY'4bWh Dnbkh led
ECCS Instrumentation 3.3.5.1
.N Table 3.3.5.1 1 (psee 2 of 6) CT$
Emergency Core Cooling system Instrumentation 'Ib6(E! J.~3,3 -l M.5-APPt: caste CON 0ltict4s Y'33I stats AEGulaED BEFEalWCED ca OTNER CNANNELs F'40N gg SPECIflED PER H WlaED suaVEILLANCE ALLOW 4 ALE FUNCTION COWill0Ns PUNCTION AC180N A.1 AEGUtaEMENis VALUE
- 2. LPCI system (continued) ,1
.t
- 6. Devu.it 1,2,3 g4 e sa 3.3.5.1.1 s is Pressure - mish sa 3.3.5.1.2 ab
.wnt 3.3.5.1.
OR 3.3.3.1.
" !!5-
.5% d.d.cu
- c. Reactor steen Does 1,2,3 sa 3.3.5.1.1 Pressure - Low 4 C sa 3.3.5.1.2 a male 2*g, (Injection Permissive) .>tsa 3.3.5.1.
Sa 3.3.5.1 sa 3.3.5.1
?" ?.? ' *
- P 4(*I, 5(e) e se 3.3.5.1.1 a l
de. ', sa 3.3.5.1.2 2C < v4st 3.3.5.1. _1 f sa 3.3.5.1 IN58W --* ;l g, asp l!. p 3.3s.H .. . _ .., ..e _ i ,2 ~ , su Pressure-Lou sa 3 .5.1.2 (socirculation 3(c) (sa .3.5.1.31 - Discheroe vet Permissive) sa .3.5.1.5 3.3.5.1.6 WI
- e. neector t shroud 1,2,3 [23 e sa 3.3.5.1.1 t ( 2pd Level L0 sa 3.3.5.1.2 I
. Esa 3.3.5.1.31 sa 3.3.5.1.5 sa 3.3.5.1.6
- f. La/ Pressure tootent ji,2,3, (4) s' sa 3.3.5.1.5 djectionPump (1 per sa 3.3.5.1.6 start -Time Detey 'II83,5(e) py,p) aster Puups A,5,0 ;
t9 secondls !
. 5 11 Pump C s1 and (continued)
[L C4_3.f. L (a) When associaied sibeystem(s)'ere regaired to be OPERABLE. h Atee reded to initiate the associa(ed (DC and laatste termisoci.i rn styrisoletion wetQ v~._.w.== = . . . . . . . 1 BWR/4 STS 3.3-43 Rev 1, 04/07/95 kBv'b
ECCS Instrumentation 3.3.5.1 CTS k' Tebte 3.3.5.1 1 (pose 3 of 6) Emergency Care Coeling system Instrumentellen NT I'3'.3 ~! 333-2. APPLICA8LE tele!TIONS
%.h.)-)
IISEs OR aEGUIRED REFEU NCED hyAJC,TIO Af OTNER CHAMMELs FEB6 - BPECIFIED PER ateUIRED suRWEILLANJ ALLOW 4sLE FWWCTION CoelTIOus FUNCTION Action A.1 esculatsENTS VALW
- 2. LPCI system (sentinued) [d) '
Lou Pressure 1,2,3, -vet- E 8 - :.3 3. ; . ;' a h Cootent Injectien pump -ft pr- sa 3.3.5.1.2 and [g l, T Discharge Fleu-Lew 4(e),5(83 % sa 3.3.5.1 's \ T (typass) b5 L .0.1 ~ t
- h. Initteti ,3, sa 3.5.1.6 L1 pe 4(e),3 )
6
- 3. Nish Pressure Coolant Injection (NPCT) system
- 8. teacter Weseet Water 1, e sa 3.3.5.1.1 a Lovet - Lev Lou, \
sa 3.3.5.1.2 inches .3,4. J Level 2 2M ,3(8) f 4sa 3.3.5.1.3 sa 3.3.5.1 _" 3's'.
,g
- b. Dryvett Pressure - Nish 1, g a sa 3.3.5.1.1 sa 3.3.5.1.2 s . pois ,h 2(8),3(d) yssa 3.3.5.1.
Sa 3.3.5.1 sa 3.3.5.1
'l l
- c. teacter vessei Water Levet - utsh, Level 8
, 1, g C sa 3.3.5.1.1 sa 3.3.5.1.2 s.
inches [3,g T 2(83, 3(d) .ytsa 3.3.5.1. sa 3.3.5.1
- HH.
- d. Condersete storspe 1, 2- L-i-L-e use 3 c
, ,3 G ov. .s.~i.37g;;;;;;2 j:.3.5.1.1y a f,0(inches sa 3.3.5.1 5 C.
- e. g Swession Poot Water
\/3.d) 1, a sa 3.3.5.1.1 s Level - Nish 34 3.3.5.1.2 inches 2M,3M psa 3.3.5.1.
sa 3.3.5.1 sa 3.3.5.1 (continued) (8) .an t.,e ess-inte s.yst-e) are ire, to .eN.PER u. (d) With reacter steen eene pressure e 50 pois.
)I m
ig (c) Mmws/rahnly confag L BWR/4 STS 3.3-44 Rev 1, 04/07/95
ECCS Instrumentation 3.3.5.1 n.\ X febte 3.3.5.1 1 (pose 4 of 6) CT5 Emergency Core Cootins system snstnmentation TA GLE : J.3,3 JM-APPLICA8LE CosCIf!ONs '1'\ * ' IEEEs OR REallRED 07NER CMANNELs REFERENCED FROM p Qg sPECIFIED PER REGUIRED suRVE!LLANCE ALLOW 48L FWCTION t M lfl0Ms FWCTION ACT!QN A.1 REQUIREMENTS ALUE
- 3. MPCI System
(.ent itsand)
, _(() .,,
f,I
- f. unsh Pressure Cootent Injection Pup 1,
fig E - ;.;.;.;.i sa 3.3.5.1.2
's
/gg Discharge Flow-Law 2(d), 3(d) ,
T (Dypass) $ sa 3.3.5.1
?.5. .; # N 3 meF L_InItie en 1, (1) C 3.3.5.1. NA ,
24 , Id) ( l
- 4. Automatic Depressurization System (ads) Trip system A
,o 14,{
.. t., ...ei -t.r ,a '
} L*"
i, 2(83, 3(d) F
;; :3::::; L., 44.4
>;sa 3.3.5.1.
se 3.3.5.1 sa 3.3.5.1 g,g
.. .-i t P'*"""
i, ,a -
- :::::::; = a
2(d)* 3(d) (4. E A st 3.3.5.1. sa 3.3.5.1 sa 3.3.5.1. re.=, ,e, , . y-
- a e % 3.3.5.1,o - 3.3.5.1 sv
-- Lj,(
syste,a initletten 2,,,, 3,,,
- d. Reector vesset Water dik tgpMM ,(
sal.... 1 F
- gg __,,
, I ory) 2 ,3 #
W,, f,'l,*f,' '3 sa 3.3.5.1 C.,e 5, rey ru., a i .~.e i, =
;; :::::::: A '" <44 j
Pressure - Nlsh ,id),3 4 w*e y 3.3.5.,
- gg 3,3,$ ,g Qsde a, N_
sa 3.3.5.1. j (. nti - ) (d) withreactersteemdamepressure>p50(psis.
~ t n k (c)MWnis{yakveh conhatted w u h )I BWR/4 STS 3.3-45 Rev 1, 04/07/95 O
i i 4 ! I
ECCS Instrumentation 3.3.5.1 (\h CT 5 T Tabte 3.3.5.1-1 (pese 5 of 6) Emergency Core Cooline systen Instrumentation gg 3,p ,7 33.3-2.
". L3.I- /
APPLICABLE CONDITION $ stBES OR RfoulatD REFERENCED bMW OTNER CNAndELs FROM SPECIFIED PER RfeUltfD SURytlLLANCE ALLOW 4sLE FUNCTION Coelflous RAICTION ACTION A.1 REQUIREMENTS VALUE Y
- 4. ADS Trip system A (continued) ;
2/ pen I 1
- f. Law Pressure Cootent 1, & G sa 3.3.5.1.1 a psis Injection Pimp Discherpe 2Id),3(d) WR st 3.3.5.1.2 3.3.5.1.
/ .6 NN (/
Pressure - Mish st 3.3.5.1. -- i ff.T.3.f.L2 BR 3.3.5.1 1 0/ WdIU"33}s. Mase . 1, s R t 'GLC'\'3 3.3.5.1 sfW fQ,h) - { h @ypef1 Depr urisati 3.3.5.1
~
s as Low r Level 2@,Itd) p tuntien T r
- b. Manuet 444c 1, G sa 3.3.5.1 RA
[ Aos Trip system a 2(8), 3("I) I 5.
- e. Seector vessel Water Level-Low Low Low, 1,
4 F sa 3.3.5.1.1 SR 3.3.5.1.2 m inches ( j ,4 /\ Levet 1 2(d),5 td> )gge 3,3,$,g,3 SR 3.3.5.1 sa 3.3.5.1.
- b. Drywott 1, g F sa 3.3.5.1.1 s pais / t\ /
Pressure - u tsh 20,3d) SR 3.3.5.1.2 %q*D Stst 3.3.5.1.1 st 3.3.5.1 4_ sa 3.3.5.1
- F
- c. Automatic Depressurisetton 1,
g G_ dst 3.3.5.1.' N 3,3,g,p at 3.3.5.1 s seconds
/q,g N
\
/
system initletion 2N,3W.
- d. a or vessel Water tevet - Law, Level 3 1, g F sa 3.3.5.1.1 a nches (Q, sa 3.3.5.1.2 (Confirmatory) 2@, 3(d) )(se 3.3.5.1.3 sa 3.3.5.1 sa 3.3.5.1
- e. Core sprey Pump 1, G sa 3.3.5.1.1 a psis
%:::';;' . . 2m,3m I/eme Jiiiii)<($80 sa 3.3.5.1 y;})
sa 3.3.5.1.h'yg , (continued) (d, U,t,r
- t. ret a _ p,.s_.. ,,g ts.n N 3 .!.
t
'T BWR/4 STS 3.3-46 Rev 1, 04/07/95
ECCS Instrumentation 3.3.5.1 C7 5
- Table 3.3.5.1 1 (page 6 of 6) TR6II;3.%$-l Emergerry Core Coollag system Instruesntetion 4 3.1.I -I APPLICABLE CONDITIONS IRBEs OR REGUIRED REFERENCED Fv p N ofet CmAmmEts PRON SPECIFIED PER REGUIRED SURVEILLANCE ALLoh&BLE RAICflou COWITIOus MafCTION ACTION A.1 REGUIRDENTs VALUE
- 5. Aos trip system a Y 2/pufgp g
- f. Law Pressure Coolant 1, G st 3.3.5.1.1 t . pets injectlen Pimp sa 3.3.5.1.2 2(d), 3(8 ( l}'C, Discharge Pressure - ulgh
,)OR 3.3.5.1.
at 3.3.5.1. (m. s et 3.3.5.1. kjistM fR550/C . Aut t 1, R N 3.3.5.1 6 q, i= 0a ayus ' rLm 2 ., 3al 1 sasa.su = sssi (a,,$i[,7 r gg 3,7g,g, g g ggg,f$
- h. Herman! 4 1, G st 3.3.5.1. NA I ANib b '
]4 2(d), 3M) y (d) With reacter eteen dose pressur e 15
~
# 9 1
BWR/4 STS 3.3-47 Rev 1, 04/07/95
\
1
)
ECCS Instrumentation B 3.3.5.1 BASES APPLICABLE 1.c. 2.c. Ree-tor Steam Dome Pressure-Low (Injection SAFETY ANALYSES, Permissive) (continued) LCO, and APPLICABILITY LCO 3.5.2 for Applicability Bases for the low pressure ECCS subsystems. 1.d. 2. . Core Sorav and Low Pressure Coolant Iniection Pume Di'scharae Flow-Low fBycassi The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the l pump is operating and the associated injection Yhlve is not ^ fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump. The LPCI and
~
CS Pump Discharge Flow-Low Functions are assumed to be p OPERABLE and capable of closing the minimum flow valves to ' ensure that the low pressure ECCS flows assumed during the transients and accidents analyzed in References 1, 2, and 3 are met. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of ; 10 CFR 50.46 D tvisipJ le2 Ogg One flow .. _ ._. .... per ECCS is u to detect the associated 7 L,2_-- T flow rates. The logic is arranged MN such that each l o r i . causes its associated minimum l flow valve to open. The logic will close the minimum flow ' valve onc'e the closure setpoint is exceeded. The LPCI ; minimum flow valve: are time delayed such that the valves ' q willnotopenfoq seconds after the switches detect low
, flow. The time de ay is provided to limit reactor vessel inventory loss during the startup of the RHR shutdown 154 85W cooling mode. The Pump Discharge Flow-Low Allowable Values cswd Crnb Nd ; arethigh enough to ensure that the pump flow rate is
' M) adWB-[qhve(y. sufficient to protect the pump, yet low enough to ensure
-g i that the closure of the minimum flow valve is initiated to allow full flow i the core.
Each channel Discharge Flow-Low Function '(two CS ) channels and LPCI channels) is only required to be OPERABLE when the associated ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude the ECCS function. Refer to LCO 3.5.1 and LCO 3.5.2 for Applicability Bases for the low pressure ECCS subsystems. (continued) BWR/4 STS B 3.3-111 Rev 1, 04/07/95 j
)
)
[EYb 1
ECCS Instrumentation B 3.3.5.1 l BASES APPLICABLE 3.f. Hioh Pressure Coolant in_iection Pumo Discharae SAFETY ANALYSES, Flow-tow (Bvoassi (continued) LCO, and APPLICAB11ITY The High Pressure Coolant Injection Pump Discharge Flow-Low (SMk6h
~~
Wd
~ X Allowable Value isthigh enough to ensure that pump flow rate s sufficient to protect the pump, yet low enough to ensure gbited admWMul[1 ! hat the closure of the minimum flow valve is initiated to Q g gg h cip tilow full flow into the core.
One channel is required to be OPERABLE when the HPCI is e, required to be OPERABLE. Refer to LCO 3.5.1 for HPCI fel Applicability Bases. l Manual Initiation i The Man Initiation push button channel intro s signals I into the H logic to provide manual initia capability I
~fandisredun t to the automatic protect i instrumentation. There is one push b n for the HPCI i System.
The Manual Initiation Fu io s not assumed in any [M accident or transient anal in the FSAR. However, the Function is retained for vera redundancy and diversity of l the HPCI function as uired by NRC in the plant licensing basis. There is no Ap wable Val'ue for this Funct qincethe channel is pechanically actuated based solely o he , position pf'the push button. One channel of the 1 Initia '6n Function is required to be OPERABLE only wh HPCI stem is required to be OPERABLE. Refer to LCO 3.5.1 the ) or' PCI Applicability Bases, f Automatic Deoressurization System 4.a. 5.a. Reactor Vessel Water Level-Low Low tow. Level 1 Low RPV water level indicates that the capability'to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, ADS receives one of the signals necessary for initiation from this Function. The Reactor Vessel Water Level-Low Low Low, Level 1 is one of the Functions assumed to be OPERABLE and capable of initiating the ADS during the accident analyzed (continued) BWR/4 STS B 3.3-119 Rev 1, 04/07/95
L ECCS Instrumentation B 3.3.5.1 BASES ACTIONS 1.,1 and G.2 (continued) inoperable channel. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition H must be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this action would not necessarily result in a safe state for the channel in all events. IL1 With any Required Action and associated Completion Time not met, the associated feature (s) may be . incapable of performing the intended function, and the supported _ feature (s) associated with inoperable untrippd channels must be declared inoperable immediately. SURVEILLANCE Rev - Certain Frequencies are'basari - .,,,n[ REQUIREMENTS topical reports. = ' h;....e to use these Frequencies, the ' t ..e.. ust e uencies as y"'.e. iijrTEe~ staff SER for the topical repor . , As noted in the beginning of the SRs, the SRs for each ECCS instrumentation Function are found in the SRs column of Table 3.3,5.1-1. The Surveillances are modified by a Note to indicate that-when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated 'm Conditions and Required Actions may be delayed for up to 7 6 hours as follows: (a) for Functions 3.c, 3.f and 3.g: - and (b) for Functions other than 3.c, 3.f. and 3.g provided theassociatedFunctionorredundantFunctionmaintainsEC initiation capability. Upon completion of the Surveillance, or expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition Q 4 entered and Required Actions taken. This Note is' based on the reliability analysis (Ref. M assumption of the average time required to perform channel surveillance. That analysis demonstrated that the 6 hour testing allowance does not significantly reduce the probability that the ECCS will initiate when necessary. (continued) BWR/4 STS B 3.3-135 Rev 1, 04/07/95
~ i I ECCS Instrumentation B 3.3.5.1 BASES SURVEILLANCE SR 3.3.5.1.1 REQUIREMENTS l (continued) Performance of the CHANNEL CHECK once every 12 hours ensures i that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other l channels. It is based on the assumption that instrument channels monitoring the same parameter should read ! l approximately the same value. Significant deviations l between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited to ' I2 hours; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. ! Agreement criteria are determined by the plant staff, based l' on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indicat-ion that the instrument has drifted outside its limit. l The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.5.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required 1 l g 21)5 channel to ensure that the entire cha, nel will perform the 4 intended function.fi Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of 92 days based on the reliability analyses of Reference {} . 4 (continued) BWR/4 STS B 3.3-136 Rev 1, 04/07/95
. EV 1
I
I y ECCS Instrumentation B 3.3.5.1 INSERT: TSTF-205 , I
-INSERT A A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is.an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at
. least once per refueling interval with applicable extensions.
1 i FERMI UNIT 2 Page B 3.3-136 (Insert) REVISION 6, 05/28/99l a
1 l l JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 I ITS: SECTION 3.3.5.1 - ECCS INSTRUMENTATION NON BRACKETED PLANT SPECIFIC CHANGES ; P.1 These changes are made to NUREG-1433 to reflect Fermi 2 current licensing basis: including design features, existing license i requirements and commitments. Additional rewording, reformatting, ) and revised numbering is made to incorporate these changes consistent l with Writer's Guide conventions. Refer to CTS Discussion Of Changes l 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. Specifically some of the changes are discussed i below: l
- a. Manual initiation Function is removed. CTS Discussion of Change "LA.3" provides detailed discussion of this change, and is repeated below for reference:
LA.3 CTS Tables 3.3.3-1. 3.3.3-2. and 4.3.3.1-1 Manual initiation Functions (1.d. 2.h. 3.f. and 4.9) are relocated from Technical Specifications to UFSAR (system design) and the Technical Requirements Manual (TRM) (Surveillance testing and inoperability actions). The UFSAR design description. which requires change control in accordance with 10 CFR 50.59, and the Technical Requirements Manual (TRM), which requires revisions be co'ntrolled by 10 CFR 50.59. together assure that adequate protection of the public health and safety is maintained. These manual functions are simply the individual valve and pump control switches. NUREG-1433 Table 3.3.5.1-1 Manual Functions (as described in the ITS Bases) address plant designs that incorporate system-level initiation " push buttons." The Fermi design does not incorporate any system-level initiation (e.g. a single " push-button" that would result in HPCI initiation and injection). Therefore, relocation of these individual component controls is consistent with the non-Technical Specification nature of all other individual component controls.
- b. The setpoint values at which the minimum flow function is designed to operate are not based on analytical assumptions, and therefore do not fit the ITS use of " allowable value."
These values are administratively controlled based on nominal @ settings. This is reflected in ITS footnote (c), and is consistent with CTS requirements, which currently provide no explicit Technical Specification control of these setpoints.. I FERMI - UNIT 2 1 REVISION 6 05/28/99l
i l t JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.3.5.1 - ECCS INSTRUMENTATION l l l P.2 Bases changes are made to reflect plant specific design details. equipment terminology, and analyses. 1 P.3 Bases changes are made to reflect changes made to the Specification. l Refer to the Specification, and associated JFD if applicable, for additional detail. P.4 Change made for editorial preference or clarity. P.5 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG-1433. . e e FERMI UNIT 2 2 REVISION 6 05/28/99l
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE l _(.50ecification 3.3.5.1 "L.4" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. 1 The bases for the determination that the proposed change does not involve a , significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change provides an additional hour prior to transfer of actions to the actions for ECCS inoperability, when both divisions of ECCS have lost initiation function capabilities, and provides an increase to 24 hours when inoperabilities do not result in a loss of hi function. The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the f allowed outage time for operation with inoperable ECCS is not an initiator of an analyzed event. The proposed change does not involve a signiftcant increase in the consequences of an accident previously evaluated because this change does not further degrade the capability of the instrumentation to perform its required function under these circumstances (only the out of service time is affected by this change). Additionally, the increased time allowed will not adversely affect the performance of any other credited equipment. As such, the consequences remain unchanged from those that would apply utilizing the existing CTS requirements.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant operation. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously , evaluated. FERMI UNIT 2 7 REVISION 6 05/28/99l
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.5.1 ECCS INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.3.5.1 "L.4" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not involve a significant reduction in a margin of safety because the expectation that manual or other automatic (e.g., initiation on low level if high drywell pressure is also inoperable) initiation capability would remain, and based on the low probability of an event that would require these automatic initiations. Furthermore, these changes correct deficiencies in the CTS that would allow inappropriate restoration times for some inoperabilities that reflect a y loss of initiation function. Additionally, the increased time allowed $ will not adversely affect the performance of any other credited i equipment. In the case of Mode 4 or 5 operation, the actuation of ECCS flow to the core at a specified time is not assumed in any Mode 4 or 5 accident analysis. Events initiated while in these lower Modes result in significantly reduced consequences and significantly increased margins of safety. ITS 3.5.2 continues to assure that sufficient ECCS is available in Modes 4 and 5. and ITS 3.3.5.1 continues to require Operable actuation instrumentation. Therefore, this change will not involve a significant reduction is a margin of safety. l l l 1 FERMI UNIT 2 8 REVISION 6 05/28/99l l
RCIC System Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation ! BASES BACKGROUND The purpose of the RCIC System instrumentation is to initiate actions to ensure adequate core cooling when the i reactor vessel is isolated from its primary heat sink (the main condenser) and normal coolant makeup flow from the Reactor Feedwater System is unavailable. such that initiation of the low pressure Emergency Core Cooling Systems (ECCS) pumps does not occur. A more complete discussion of RCIC System operation is provided in the Bases I of_LC0 3.5.3, "RCIC System." The RCIC System may be initiated by either automatic or . manual means. Automatic initiation occurs for conditions of I reactor vessel Low Low water level. 'The var.iable is monitored by four transmitters that are connected to four trip units. The outputs of the trip units are connected to ]j relays whose contacts are arranged in a one out of two taken twice logic arrangement. Once initiated, the RCIC logic seals in and can be reset by the operator only when the reactor vessel water level signals have cleared. l The RCIC test iine isolation valve is closed on a RCIC initiation signal to allow full system flow and maintain primary containment isolated in the event RCIC is not operating. The RCIC System also monitors the water level in the condensate storage tank (CST) since this is the normal source of water for RCIC operation. Upon receipt of a RCIC initiation signal, the CST suction valve is automatically signaled to open (it is normally in the open position) unless the Jump suction from the suppression pool valves is open. If t1e water level in the CST falls below a preselected level, first the suppression pool suction valves automatically open, and then the CST suction valve automatically closes. Two channels of transmitter / trip unit in the HPCI system are used to detect low water level in the CST. Either channel can cause the suppression pool suction valves to open and the CST suction valve to close. To prevent losing suction % the pump, the suction valves are interlocked so that one suction path must be open before the other automatically closes. l FERMI UNIT 2 B 3.3.5.2-1 Revision 6. 05/28/99
RCIC System Instrumentation B 3.3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.5.2.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A , CHANNEL CHECK is normally a comparison of the parameter I indicated on one channel to a parameter on other similar channels. It is based on the assumption that instrument ! channels monitoring the same parameter should read ! approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or i something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the , instrumentation continues to operate properly between each ! CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based i on a combination of the channel instrument uncertainties, ' including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequency is based upon operating exaerience that demonstrates channel failure is rare. T1e CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.5.2.2 I A CHANNEL FUNCTIONAL TEST is performe 2ach required channel to ensure that the entire chtna will perform the l intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL f FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. er l FERMI UNIT 2 B 3.3.5.2 - 9 Revision 6 05/28/99
l I RCIC System Instrumentation B 3.3.5.2 j BASES SURVEILLANCE REQUIREMENTS (continued) The Frequency of 92 days is based on the reliability analysis of Reference 1. SR 3.3.5.2.3 This surveillance provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.21. If the trip setting is discovered to be less conservative than the l setting accounted for in the appropriate setpoint l methodology. but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than ; accounted for in the appropriate setpoint methodology. ' The Frequency of 92 days is based on the re' liability analysis of Reference 1. SR 3.3.5.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. The Frequency of SR 3.3.5.2.4 is based upon the assumption of a a 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. G l FERMI UNIT 2 B 3.3.5.2 - 10 Revision 6 05/28/99
o RCIC System Instrumentation B 3.3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.5.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LC0 3.5.3 overlaps this Surveillance to provide complete testing of the safety function. j The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an un31anned transient if the Surveillance were performed with t1e reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month . Frequency, i REFERENCES 1. GENE 770-06 2. " Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out of-Service Times for Selected Instrumentation Technical Specifications." February 1991. l l l i
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$' FERMI UNIT 2 B 3.3.5.2 - 11 Revision 6. 05/28/99
F f S PEC \ Fe t AT70M E* 3' 5 >'2-- ) 1 L. Co 3. ~6. S a'l- -
--TA0LE 3.3.5-HContinued)
REACTOR CORE ISOLATION COOLING SYSTEM ACTION STATEMENTS l ACT:= ",C . With the number of OPERABLE channels less than required by the g-- Minimum OPERABLE Channels per Trip System reautrement: M'l 6 ACTION)W,C. a. -.<Re3k4)ip For one tr system 4fplace tne inoperacle enannel(s)-
- -- - --- knd/or tnat t rip system in the tripped condition y g 4CT7ord 6 ,, (rmursgr declare tne KLiv system inoperacte. in @ od . -
Reo.Ac.netJ 8.I b. For both trip systems, declare the RCIC system inoperable, thove L.l k 1 ACT;Cn i- With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System reoutrement, place at ' hjoy nu least one inoperable channel in the tripped condition within 24 hours or ali n RCIC to take suction from the suppression pool !
.il r declare t e RCIC system inoperable. [ ADO REa ticTied b,1 M,7_
ACT10td E J i
=:= & n::: r: in = = e init ut un : = t w. t. r: = a.
w;th" '" t=r; Or d::i;r; in; RC:0 ;y; terr. ;nc;;r:bi j LAS ! l l l l FERMI - UNIT 2 3/4 3-38 Amen ment No. 73, 83 I l l PAGE 3 0F 05 Rev6 l
f i DISCUSSION OF CHANGES ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION l 6DMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions . are adopted which do not result in technical changes (either ! actual or interpretational). Editorial changes. reformatting, and j revised numbering are adopted to make the ITS consistent with the j Boiling Water Reactor (BWR) Standard Technical Specifications
]
NUREG-1433. Rev. 1. A.2 ITS LC0 3.3.5.2 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LCO. j
" Separate Condition entry is allowed for each channel." This is !
acceptable because the Required Actions for each Condition provide j appropriate compensatory actions for each inoperable RCIC channel. ! Complying with the Required Actions will allow for continued l operation: with subsequent inoperable RCIC channels governed by ! subsequent Condition entry and application of associated Required l Actions. This is an administrative change with no impact on safety because the clarifications provided by the Note are consistent with the existing interpretation of the CTS. A.3 CTS 3.3.5 specifies Actions for RCIC channels with setpoints not within allowable values. These Actions state " declare the channel inoperable until the channel is restored to Operable status." lT9 ITS 3.3.5.2 contains all the requirements and Actions for RCIC
- channels. including the allowable values and Actions when it is not met. The usage rules of Technical Specifications adequately dictate that channels be declared inoperable and Actions taken
( until restored to Operable, without a specific statement to that effect. Therefore, elimination of this statement is an administrative presentation preference only. A.4 CTS 4.3.5.2 requires an LSFT "and simulated automatic operation" y of all channels. The simulated automatic operation" is n) interpreted to be included in the LSFT. This additional detailing lM of the required test is unnecessary. Therefore its elimination is E an administrative change. C .s FERMI UNIT 2 1 REVISION 6 05/28/99l
DISCUSSION OF CHANGES ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION 4 M.2 CTS Table 3.3.5 1 Actions 51 allows 24 hours to complete compensatory actions for inoperable channels, regardless of whether the RCIC suction swap function (on CST low level) is inoperable resulting in a loss of the RCIC function. For inoperabilities that result in a loss of initiation function, ITS 3.3.5.2 Required Action D.1 provides a more restrictive time of "I hour from discovery of loss of RCIC initiation capability" to restore or declare RCIC inoperable. TECHNICAL CHANGES LESS RESTRICTIVE
Generic" LA.1 CTS 3.3.5 requires that RCIC actuation instrumentation trip setpoints to be within Trip Setpoint column values of CTS Table 3.3.5 2. Additionally, CTS 3.3.5 Action a requires that an inoperable RCIC actuation instrument channel setpoint be restored consistent with the trip setpoint value. However, Actions only apply if the allowable value is exceeded. ITS 3.3.5.2 requires only that instrumentation setpoints be within the allowable value.
Trip setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip b setpoints are relocated to the Technical Requirements Manual , (TRM), which requires revisions be controlled by 10 CFR 50.59. The trip setpoint is established based on a combination of Y instrument design factors, environmental factors, and the M allowable value (which is what is conservatively derived from the N value assumed in the safety analyses). Therefore, these details can be adequately defined and controlled in the TRM, consistent with the NUREG 1433. This relocation continues to provide I adequate protection of the public health and safety since the requirement for instrument channel Operability and the allowable q value setpoint continues to be required by the Technical Specifications. LA.2 CTS Table 3.3.5 1 footnotes (b) and (c). and various setpoint details of Table 3.3.5-2, provide design details and descriptive details for various RCIC actuation functions. ITS 3.3.5.2 addresses this information in the Bases and plant design documents, and does not include these details in the Technical Specifications. This change is consistent with NUREG 1433. The information moved to the Bases requires changes to be controlled in accordance with the ITS 5.5.10, Bases Control Program. Information contained within plant design documents requires FERMI UNIT 2 - 3 REVISION 6, 05/28/99l
m 1 l l l DISCUSSION OF CHANGES ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION l changes to be controlled in accordance with 10 CFR 50.59. This continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability continues to be required by the Technical Specifications. LA.3 CTS Tables 3.3.51, 3.3.5 2, and 4.3.5.1 1 Manual initiation Function d are relocated from Technical Specifications to the Technical Requirements Manual (TRM) (Surveillance testing and inoperLbility actions). The TRM, which requires revisions be lh controlled by 10 CFR 50.59, assure that adequate protection of the public health and safety is maintained. These manual functions are simply the individual valve and pump control switches. NUREG-1433 Table 3.3.5.2-1 Manual Functions (as described in the ITS Bases) address plant designs that incorporate system level initiation " push buttons." The Fermi design does not incorporate system level initiation. Therefore, relocation of the individual j component controls is consistent with the non Technical Specification nature of all other individual component controls. LC.1 CTS Table 3.3.5-1. Note (a), allows required surveillance testing which causes channels to be inoperable without taking Actions for inoperable channels "provided at lea'st one OPERABLE channel in the same trip system is monitoring that parameter." ITS SR Note 2 l addresses this allowance, but includes a less restrictive change I for RCIC Function 2. The ITS allowance to delay entering Actions applies to this Function even th6 ugh the function may not have an Operable channel in the same trip system, since for the RCIC Level 8 Function, one inoperable channel results in the individual trip function not being maintained even with another Operable channel. (the logic is 2 out of-2 i.e., one Operable channel will not perform the function). GENE 770-06 1. " Addendum to Bases for Changes to Surveillance Test ' Intervals and Allowed Out of-Service I Times for Selected Instrumentation Technical Specifications." February 1991, approved the allowance for delay in entering Actions for these channels. Therefore, this change has no significant impact on safety. FERMI - UNIT 2 4 REVISION 6, 05/28/99l I
1 1 DISCUSSION OF CHANGES ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION { l TECHNICAL CHANGES LESS RESTRICTIVE >
"Speci fic" L.1 {Bothmorerestrictiveandlessrestrictivechangesareproposed and combined in this discussion for clarity and completeness.} l For the RCIC low level initiation function. CTS Table 3.3.51 Action 50.a and 50.b apply. The associated logic for this function is 1 out-of 2 taken twice (each of two trip systems with 1 out-of-2 logic). As such. CTS Action 50.a (inoperable channel (s) in one trip system - allowing 24 hour restoration time) could reflect a loss of initiation function if both channels in one trip system are inoperable. ITS Required Action B.1 would limit the Completion Time to I hour for loss of initiation function (a more restrictive change), while ITS Required Actions B.2 retains this 24 hour Completion Time.
In the case of CTS Action 50.b (inoperable channells) in both trip systems - requiring an immediate transfer of actions to associated di actions for ECCS inoperability) the inoperabilities may or may l not reflect-a loss of initiation function (e.g. in the event only J one inoperable channel is in each trip system initiation function would be available). ITS Required Action B.1 would extend the
\{
Completion Time to 1 hour for loss of initiation function while ITS Required Actions B.2 extends the Completion Time to 24 hours when initiation function is retained.. These changes are acceptable based the expectation that manual initiation capability would remain, other injection systems (e.g.. HPCI) would likely be available, and based on the low probability of an event that would require these automatic initiations. Furthermore, these changes correct deficiencies in the CTS that would allow inappropriate restoration times for some inoperabilities that reflect a loss of initiation function. The proposed ITS Actions are consistent with NUREG-1433. RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for*this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.3.5.2 consistent with the BWR STS. NUREG 1433. Rev. 1. FERMI - UNIT 2 5 REVISION 6 05/28/99l
RCIC System Instrumentation 8 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation I BASES BACKGROUND The purpose of the RCIC System instrumentation is to initiate actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser) and nomal coolant makeup flow from the Reactor Feedwater System is unavailable, such that initiation of the low pressure Emergency Core Cooling Systems (ECCS) pumps does not occur. A more complete discussion of RCIC System operation is provided in the Bases of LCO 3.5.3, *RCIC System." i l The RCIC System may be initiated by either automatic or
~
manual means. Automatic initiation occurs for conditions of reactor vessel Low Low water level. The variable is monitored by four transmitters that are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic arrangement. Once initiated, the RCIC logic seals in and can be reset by the operator only when the reactor vessel water level signals have cleared. The RCIC test line isolation valve i d i;t S & c e --in.g l ac-trinxt inutin. .;1;;;) is closed on a RCIC initiation y signal to allow full system flow and maintain primary containment isolated in the event RCIC is not operating,
-%The RCIC System also monitors the water level in the co u.ndensate storage tank (CST) x4 ^.M ..,,,,..u(in m;xi since fbis is- fb6 Nh 50VfCL .e 2 th in n x x ; of water for RCIC o amtar neu n+e- u +u crT .. _.,_ .... . . perations ___.... Upon
=-)
receipt of a RCIC initiation signal, the CST suction valve is automaticall open position)unless y signaled to open (it is normally in the the pump suction from the suppression c49uls of fro %Stn;h/ pool valves is open.below If the water level in the CST fallslevel, first the su a preselected M p m if m tkc Hf61 suction valves automatically open, and then the CST suction ep W vaive automatically cioses, iwo 'h=1 =thh: are used to u. qg detect low water level in the CST. Either sw44eMcan cause the suppression pool suction valves to open and the CST P.2 !Y!F?".58 !! !ii]!!b 3.UU!b"N "N" " ax an, i.xa.x.;.m; m xrrar..a..-" " (continued) BWR/4 STS B 3.3-139 Rev 1, 04/07/95
RCIC System Instrumentation B 3.3.5.2 BASES s SURVEILLANCE SR 3.3.5.2.1 (continued) REQUIREMENTS something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of _ channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required r r channel to ensure that the entire channel will perform the T6TF & r intended function.se 6
, /NSM b Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
1 The Frequency of 92 days is based on the reliability ' analysis of Reference 1. 3.3.5.2.3
.3 SR
{ Th: ;;1ikeu;;, :f tri; =!t provides a check of the actual l trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.2-1. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the ; plant safety analysis. Under these conditions, the setpoint i (continued) BWR/4 STS B 3.3-149 Rev 1, 04/07/95 ) s Rwlo
l l RCIC System Instrumentation B 3.3.5.2 1 INSERT: TSTF 205 1 INSERT A I A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single h contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the i other required coritacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at , least once per refueling interval with applicable extensions. FERMI UNIT 2 B 3.3 149 (Insert) REVISION 6. 05/28/99l i
l JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG 1433. l l l 1
./
l FERMI - UNIT 2 2 REVISION 6. 05/28/99l
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.5.2 RCIC SYSTEM INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.5.2 "L.1" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evP1ation of these changes against each of the criteria in 10 CFR 50.92. Th( iteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change provides an additional hour prior to transfer of actions to the actions for RCIC inoperability when initiation capability is lost for RCIC. and provides an increase to 24 hours when d inoperabilities do not result in a loss of function. The proposed 1 change does not involve a significant increase in the probability of an @ accident previously evaluated because the allowed outage time for operation with inoperable RCIC is not an initiator of an analyzed event. The proposed change does not involve a significant increase in the consequences of an accident previously evaluated because this change does not further degrade the capability of the instrumentation to perform its required function under these circumstances (only the out of service time is affected by this change). Additionally, the increased time allowed will not adversely affect the performance of any other credited equipment. As such, the consequences remain unchanged from those that would apply utilizing the existing CTS requirements.
- 2. Does the change create the possibility of a new or different kind of ,
accident from any accident previously evaluated? ' This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant l operation. Therefore, this change will not create the possibility of a ! new or different kind of accident from any accident previously l evaluated. - l J ! FERMI UNIT 2 - 1 REVISION 6 05/28/99l
N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.5.2 - RCIC SYSTEM INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.3.5.2 "L.1" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not involve a significant reduction in a margin of safety because the expectation that manual initiation capability would remain, and based on the low probability of an event that would require these automatic initiations. Furthermore, these changes correct deficiencies in the CTS that would allow inappropriate restoration times d for some inoperabilities that reflect a loss of initiation function. d. Additionally, the increased time allowed will not adversely affect the performance of any other credited equipment. Therefore, this change k will not involve a significant reduction is a margin of safety. 4 FERMI UNIT 2 2 REVISION 6. 05/28/99l
l l Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS
.....................................N0TES - ----------- - - -- - --- -
- 1. Refer to Table 3.3.6.11 to determine which SRs apply for each Primary j Containment Isolation Function.
i
- 2. When a channel is placed in an inoperable status solely .for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to:
- a. 2 hours for Function 5.a when testing non redundant circuitry that results in loss of isolation ca) ability associated with this Function provided Functions 5.). 5.c. and 5.e are OPERABLE:
- b. 6 hours for Functions 1. 2. 5 (other than non redundant circuitry of OAl 5.a), and 6. provided the associated Function maintains isolation capability: a_nd
- c. 8 hours for Functions 3 and 4. provided the associated Function maintains isolation capability.
SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Verify the trip unit setpoint. 92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months (continued)
. i l FERMI UNIT 2 3.3 55 Revision 6 05/28/99
Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1 1 (page 1 of 4) Primary Containment Isolation Instrumer.tation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SLRVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE 1.' Main Steam Line Isolation
- a. Reactor Vessel Water 1.2.3 2 D SR 3.3.6.1.1 e 24.8 inches Level - Low Low Low. SR 3.3.6.1.2 Level 1 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.6
- b. Main Steam Line 1 2 E SR. 3.3.6.1.1 = 736 psig Pressure - Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- r. Main Steam Line- 1.2.3 2 per D SR 3.3.6.1.1 s 118.4 psid Flow - High MSL SR' 3.3.6.1.2 SR 3.3.6 1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.6
- d. Condenser 1. 2 0 SR 3.3,6.1.1 s 7.05 psia Pressure - High rA 3.3.6.1.2 2(a),3(a) SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- e. Main Steam Tunnel 1.2,3 ' 2/ logic 0 SR 3.3.6.1.1 s 206*F Tenperature - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- f. Main Steam Line 1.2.3 2 0 SR 3.3.6.1.1 s 3.6 x full Radiation - High SR 3.3.6.1.2 power SR 3.3.6.1.4 background g SR 3.3.6.1.5 1l g. Turbine Building Area
. Temperature - High 1.2.3 4 D SR 3.3.6.1.1 s 206*F
%g SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 (continued)
.g T l (a) Except when bypassed during reactor shutdown or for reactor startup under administrative control.
j' FERMI UNIT 2 3.3 57 Revision 6. 05/28/99 i
f~ l l l l l i ! , Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1 1 (page 2 of 4) Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS l MODES OR REQUIRED REFERENCED OTER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SlRVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE
- 2. Primary Containment Isolation
- a. Reactor Vessel Water 1.2,3 2 G SR 3.3.6.1.1 m 171.9 inches Level - Low. Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- b. Reactor Vessel Water 1.2.3 2 G SR .3.3.6.1.1 = 103.8 inches Level - Low. Level 2 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- c. Drywell Pressure-High 1.2.3 2 G SR 3.3.6.1.1 s 1.88 psig SR 3.3.6.1.2 SR 3.3.6.1.3 I SR 3.3.6.1.4 SR 3.3.6.1.5 High Pressure Coolant l 3.
Injection (WCI) System Isolation
- a. HPCI Steam Line 1.2.3 1 F SR 3.3.6.1.1 s 410 inches Flow - High SR 3.3.6.1.2 of water with
- SR 3.3.6.1.3 time delay SR 3.3.6.1.4 m i second, and SR 3.3.6.1.5 s 5 seconds
- b. HPCI Steam Supply Line 1.2.3 2 F SR 3.3.6.1.1 m 90 psig Pressure - Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- c. HPCI Turbine 1.2.3 2 F SR 3.3.6.1.1 s 20 psig Exhaust Diaphrage SR 3.3.6.1.2 Pressure -High SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 "
- d. HPCI Equipment Room 1.2.3 1 F SR 3.3.6.1.1 s 162'F Temperature - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 j e. Drywell Pressure - High 1.2.3 1 F SR 3.3.6.1.1 s 1.88 psig SR 3.3.6.1.2 d SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 (continued) l l
l i-l FERMI - UNIT 2 3.3 58 Revision 6. 05/28/99 r
Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1 1 (page 3 of 4) l Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED 4 OTKR CHANNELS FROM SPECIFIED PSR TRIP REQUIRED SLRVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTLM ACTION C.1 REQUIREMENTS VALUE
- 4. Reactor Core Isolation Cooling (RCIC) System Isolation '
- a. RCIC Steam Line 1.2.3 1 F SR 3.3.6.1.1 s 95.0 inches Flow - High SR 3.3.6.1.2 of water with SR 3.3.6.1.3 time delay SR 3.3.6.1.4 m I second and SR 3.3.6.1.5 s 5 seconds
- b. RCIC Steam Supply 1.2.3 2 F SR 3.3.6.1.1 a 53 psig Line Pressure- Low SR 3.3.6.1.2
- SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- c. RCIC Turbine 1.2.3 2 F SR 3.3.6.1.1 s 20 psig Exhaust Diaphragn SR 3.3.6.1.2 Pressure - High SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
- d. RCIC Equipment Room 1,2,3 1 F SR 3.3.6.1.1 s 162*F l Temperature - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 Q e. Drywell 1.2.3 -
1 F SR 3.3.6.1.1 s 1.88 psig J Pressure - High SR 3.3.6.1.2 (1 SR 3.3,6.1.3
< SR 3.3.6.1.4 ClC SR 3.3.6.1.5
- 5. Reactor Water Cleanup (RWCU) System Isolation
- a. Differential 1.2.3 1 F SR 3.3.6.1.1 s 63.4 gpm Flow - High SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 '
- b. Area 1.2.3 1 per F SR 3.3.6.1.1 s 183*F Temperature - High area SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5
- c. Area Ventilation 1.2.3 1 per F SR 3.3.6.1.1 s 53*F
-Differential area SR 3.3.6.1.2 Tenperature - High SR 3.3.6.1.4 1 SR 3.3.6.1.5 j
- d. SLC System Initiation 1.2 2(b) H SR 3.3.6.1.5 NA
- e. Reactor Vessel Water 1.2.3 2 F SR 3.3.6.1.1 a 103.8 inches Level - Low Low, SR 3.3.6.1.2 i Level 2 SR 3.3.6.1.3 i SR 3.3.6.1.4 I SR 3.3.6.1.5 I
s (continued) l FERMI UNIT 2 3.3 59 Revision 6 05/28/99 l
l Primary Containment Isolation Instrumentation . B 3.3.6.1 l BASES l BACKGROUND (continued) , 1 l MSL Isolation Functions isolate the MSL and MSL drain ! isolation valves. The MSL Radiation-High Function also ! isolates the Reactor Water Sample System.
- 2. Primary Containment Isolation Primary Containment Isolation Functions receive inputs from i four channels. The outputs from these channels are arranged into two two out-of two logic trip systems. One trip system initiates isolation of all inboard primary containment isolation valves, while the other trip system initiates isolation of all outboard primary containment isolation valyes. Each logic closes one of the two valves on each penetration, so that operation of either logic isolates the penetration.
Primary Containment Isolation Drywell Pressure-High and Reactor Vessel Water Level-Low. Level 3 Functions isolate lines in the drywell sumps and traversing in core probe i systems. Primary Containment Isolation Drywell Pressure-High and Reactor Vessel Water Level-Low Low. Level 2 Functions isolate lines in the Reactor Water Samale. Torus Water Management. Standby Gas Treatment. Com)ustible Gas Control. Nitrogen Inerting, and Primary Containment Monitoring Systems. Primary Containment Isolation Drywell Pressure-High also affects isolation of lines in the RHR. CS. HPCI and RCIC systems. Primary Containment Isolation Reactor Vessel Water Level-Low Low. Level 2 Function also affects isolation of the Recirculation Pump Seal System and the Primary Containment Pneumatic Supply System.
- 3. and 4. Hiah Pressure Coolant In.iection System Isolation and Reactor Core Isolation Coolina System Isolation Most Functions that isolate HPCI and RCIC receive input from two channels, with each channel in one trip system using a one-out of one logic. Each of the two trip systems in each isolation group is connected to one of the two valves on g each associated penetration.
L The exceptions are the HPCI and RCIC Turbine Exhaust {l Diaphragm Pressure-High. Steam Supply Line Pressure-Low. s l FERMI UNIT 2 B 3.3.6.1- 3 Revision 6 05/28/99
i l Primary Containment Isolation Instrumentation B 3.3.6.1 , 1 l l l EASES ' 1 BACKGROUND (continued) 1 o 7l and Drywell Pressure-High Functions. These Functions receive inputs from four turbine exhaust diaphragm pressure E l and four steam sup)1y pressure channels for each system. The outputs from t1e turbine exhaust diaphragm pressure and steam supply pressure channels are each connected to two two-out of-two trip systems. Each trip system isolates one l valve per associated penetration. HPCI and RCIC Functions isolate the HPCI and RCIC isolation valves.
- 5. Reactor Water Cleanuo System Isolation !
~
The Reactor Vessel Water Level-Low Low. Level 2 Isolation i Function receives input from four reactor vessel water level
- channels. The outputs from the reactor vessel water level channels are connected into two two-out-of two trip systems.
The Differential Flow-High function is derived from three non-redundant flow transmitters and a non redundant flow summer. The out)ut of the summer is fed to two trip units. the outputs of w11ch are channeled through relays into two trip systems. One trip system isolates the inboard isolation valve while the other trip system isolates the two outboard isolation valves. l SLC System Initiation Functions receive input from two channels, with each chantiel in one trip system using a one out-of-one logic. Both channels are only input to the trip systems that isolates the outboard isolation valves. l The Area Temperature-High Function receives input from l twelve temperature monitors. six to each trip sys' tem. The i Area Ventilation Differential Temperature- High Function i receives input from four differential temperature monitors. l two in each trip system. These are configured so that any one input will trip the associated trip system. One of the two trip systems is connected to the inboard valve and the other trip system is connected to the two outboard valves on each RWCU penetration. l RWCU Functions isolate the RWCU isolation valv7s. I l l FERMI UNIT 2 B 3.3.6.1 - 4 Revision 6 05/28/99
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES. LCO. and APPLICABILITY (continued) l l Main Steam Line Isolation LA, Reactor Vessel Water Level-Low Low Low. Level 1 , l l Low reactor pressure vessel (RPV) water level indicates that ] l the capability to cool the fuel may be threatened. Should l RPV water level decrease too far, fuel damage could result. l Therefore, isolation of the MS1Vs and other interfaces with the reactor vessel occurs to prevent offsite dose limits from being exceeded. The Reactor Vessel Water Level-Low Low Low. Level 1 Function is one of the many Functions assumed to be OPERABLE and capable of providing isolation signals. The Reactor Vessel Water Level-Low Low Low. Level 1 l Function associated with isolation is assumed in the l analysis of the recirculation line break (Ref.1). The isolation of the HSLs on Level 1 supports actions to ensure that offsite dose limits are not exceeded for a DBA. Reactor vessel water level signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels of Reactor Vessel Water Level-Low Low Low. Level 1 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Reactor Vessel Water' Level-Low Low Low, Level 1 Allowable Value is chosen to be the same as the ECCS Level 1 Allowable Value (LC0 3.3.5.1) to ensure that the MSLs isolate on a potential loss of coolant accident (LCCA) to l prevent offsite doses from exceeding 10 CFR 100 limits. i This Function isolates the MSL and MSL drains isolation valves. I 1.b. Main Steam Line Pressure-Low l Low MSL pressure indicates that there may be a problem with the turbine pressure regulation, which could result in a low l reactor vessel water level condition and the RPV cooling down more than 100"F/hr if the pressure loss is allowed to continue. The Main Steam Line Pressure-Low Function, although not credited in the analysis of the )ressure l regulator failure (Ref. 2), is a back up to t1e maximum steam flow. limiter, which is credited by this analysis. For l l FERMI UNIT 2 B 3.3.6.1 - 7 Revision 6 05/28/99 L-
l Primary Containment Isolation Instrumentation B 3.3.6.1 1 1 BATS kPLICABLESAFETYANALYSES.LCO,andAPPLICABILITY(continued) this event, the closure of the MSIVs ensures that the RPV l temperature change limit (100 F/hr) is not reached. l The MSL low pressure signals are initiated from four i transmitters that are connected to the HSL header. The l transmitters are arranged such that, even though physically I separated from each other, each transmitter is able to l detect low MSL pressure. Four channels of Main Steam Line i Pressure-Low Function are available and are required to be
- OPERABLE to ensure that no single instrument failure can l preclude the isolation function. l 1
l l The_ Allowable Value was selected to be high enough to i prevent excessive RPV depressurization. 1 The Main Steam Line Pressure-Low Function is only required to be OPERABLE in MODE 1 since this is when.the assumed transient can occur (Ref. 2). This Function isolates the MSL and MSL drains isolation valves. I 1.c. Main Steam Line Flow-Hiah i Main Steam Line Flow-High is provided to detect a break of the MSL and to initiate closure of the MSIVs. If the steam were allowed to contir.ue flowing out of the break, the reactor would depressurite and the core could uncover. If the RPV water level decreases too far, fuel damage could occur. Therefore, the isolation is initiated on high flow to prevent or minimize core damage. The Main Steam Line Flow-High Function is directly assumed in the analysis of the main steam line break (MSLB) (Ref. 2). The isolation action, along with the scram function of the Reactor Protection System (RPS), ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46 and offsite doses do r.ot exceed the 10 CFR 100 limits. The MSL flow signals are initiated from 16 transmitters that are connected to the four MSLs. The transmitters are l arranged such that, even though physic Cly separated from I each cther, all four connected to one 4L would be able to detect the high flow. Four channels of Main Steam Line l Flow-High Function for each unisolated MSL (two channels l per trip system) are available and are required to be B 3.3.6.1- 8 Revision 6 05/28/99 hl FERMI-UNIT 2 i
l Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES. LCO. and APPLICABILITY (continued) OPERABLE so that no single instrument failure will preclude detecting a break in any individual MSL. j l The Allowable Value is chosen to ensure.that offsite dose l l limits are not exceeded due to the break. This Function isolates the MSL and MSL drains isolation valves. 1.d. Condenser Pressure-Hiah The Condenser Pressure-High Function is provided to prevent overpressurization of the main condenser in the event of a loss of the main condenser vacuum. Since the integrity of the condenser is an assumption in offsite dose calculations, the Condenser Pressure-High Function is assumed to be OPERABLE and capable of initiating closure of the MSIVs. The closure of the MSIVs is initiated to prevent the l addition of steam that would lead to additional condenser l pressurization and possible rupture of the diaphragm ] installed to protect the turbine exhaust hood, thereby j preventing a potential radiation leakage path following an accident. This function is credited with closing the MSIV's by the analysis of the " Loss of Condenser Vacuum" event (Ref. 2). Condenser vacuum pressure signals are derived from four pressure transmitters that sense the pressure in the condenser. Four channels of Condenser Pressure-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. l The Allowable Value is chosen to prevent damage to the condenser due to pressurization, thereby ensuring its integrity for offsite dose analysis. As noted (footnote (a) to Table 3.3.6.1 1), the channels are not required to be OPERABLE in MODES 2 and 3 during reator shutdown or for reactor startup when bypassed under administrative control, since the potential for condenser overpressurization is minimized. Keylocked switches are provided to manually bypass the channels in this condition. This function is provided primarily as a backup to the closure of the turbine stop valves on Condenser Pressure-l FERMI - UNIT 2 B 3.3.6.1 - 9 Revision 6 05/28/99
l i Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES LCO, and APPLICABILITY (continued) without isolation. offsite dose limits may be reached. These Functions are not assumed in any UFSAR transient or accident analysis, since bounding analyses are performed for large breaks such as recirculation or MSL breaks. HPCI and RCIC Equipment Room Temperature-High signals are initiated from thermocouples that are appropriately located , to protect the system that is being monitored. Two I instruments monitor each area. Two channels for each HPCI and RCIC Equipment Room Temperature-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Allowable Values are set low enc agh to detect a leak equivalent to 25 gpm. These Functions isolate the HPCI and RCIC s'ystem isolation valves, as appropriate. 3.e. 4.e. Drywell Pressure-Hiah High drywell pressure can indicate a break in the RCPB. The HPCI and RCIC isolation of the turbine exhaust is provided to prevent conimunication with the drywell when high drywell pressure exists. A potential leakage path exists via the turbine exhaust. The isolation is delayed until the system becomes unavailable for -injection (i.e., low steam line pressure). The isolation of the HPCI and RCIC turbine exhaust by Drywell Pressure-High is indirectly assumed in the FSAR accident analysis because the turbine exhaust leakage path is not assumed to contribute to offsite doses. g High drywell pressure signals are initiated frorii pressure transmitters that sense the pressure in the drywell. Two k channels of both HPCI and RCIC Drywell Pressure-High Functions are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Allowable Value was selected to be the same as the ECCS Drywell Pressure-High Allowable Value (LC0 3.3.5.1). since this is indicative of a LOCA inside primary containment. .w'- l FERMI - UNIT 2 B 3.3.6.1 - 16 Revision 6 05/28/99
)
l l l Primary Containment Isolation Instrumentation B 3.3.6.1 l BASES l APPLICABLE SAFETY ANALYSES. LCO. and APPLICABILITY (continued) h This Function is combined with the HPCI and RCIC steam supply line pressure-low signals to isolate the HPCI and l 4 RCIC turbine exhaust line vacuum breaker. Reactor Water Cleanuo System Isolation 5.a. Differential Flow-Hiah The high differential flow signal is provided to detect a break in the RWCU System. This will detect leaks in the l RWCU System when area or differential temperature would not l provide detection (i.e.. a cold leg break). Should the l reactor coolant continue to flow out of the break. offsite I dose limits may be exceeded. Therefore. isolation of the l RWCU System is initiated when high differential flow is sensed to prevent exceedg offsite doses. A time delay is provided to prevent spurious trips during m.ost RWCU ' operational transients. This Function is not assumed in any UFSAR transient or accident analysis, since bounding j analyses are performed for large breaks such as MSLBs. l The high differential flow signals are initiated from l transmitters that are connected to the RWCU pump outlet and l RWCU system di.scharge to condenser and feedwater. The i outputs of the transmitters are compared (in a common I summer) and the resulting output is sent to two high flow l trip units. If the difference between the inlet and outlet flow is too large. each tri) unit generates an isolation signal. Inoperability of t1e non-redundant circuitry causes the channels in both trip systems to be inoperable. The remainder of the circuit is redundant and can be considered on a per trip system basis. The Differential Flow-High Allowable Value ens 6res that a break of the RWCU piping is detected. This Function isolates the RWCU isolation valves. 5.b. 5.c. Area and Area Ventilation Differential Temoerature- Hiah RWCU area and area ventilation differential temperatures are l orovided to detect a leak from the RWCU System. The t isolation occurs even when very small leaks have occurred and is diverse to the high differential flow instrumentation for the hot portions of the RWCU System. If the small leak 1 v l FERMI - UNIT 2 B 3.3.6.1 - 17 Revision 6. 05/28/99
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES. LCO. and APPLICABILITY (continued) continues without isolation offsite dose limits may be reached. Credit for these instruments is not taken in any l transient or accident analysis in the UFSAR. since bounding j analyses are performed for large breaks such as i recirculation or MSL breaks. Area and area ventilation differential temperature signals are initiated from temperature elements that are located in j the room that is being monitored. Twelve thermocouples T provide input to the Area Temperature-High Function (two per area). Two channels per area are required to be 4l OPERABLE to ensure that no single instrument failure can l preclude the isolation function. Eight thernoccuples provide input to the Area Ventilation Differential Temperature-High Function. The output of these thermocouples is used to determine the differential l temperature in four areas containing RWCU piping and l equipment. Each channel consists of a differential temperature instrument that receives inputs from thermocouples that are located in the inlet and outlet of ' the area cooling system and for a total of four available channels (one per area). The Area and A'rea Ventilation Differential Temperature-High Allowable Values are set low enough to detect a leak equivalent to 25 gpm. These Functions isolate the RWCU isolation valves, as appropriate. 5.d. SLC System Initiation The isolation of the RWCU System is required when the SLC System has been initiated to prevent dilution and removal of the boron solution by the RWCU System (Ref. 4). SLC System initiation signals are initiated from the two SLC pump start signals. There is no Allowable Value associated with this Function since the channels are mechanically actuated based solely on the position of the SLC System initiation switch. l J l FERMI - UNIT 2 B 3.3.6.1 - 18 Revision 6. 05/28/99 l
i 1 ! Primary Containment Isolation Instrumentation l B 3.3.6.1 l l BASES l APPLICABLE SAFETY ANALYSES. LCO, and APPLICABILITY (continued) l Two channels (one from each pump) of the SLC System Initiation Function are available and are required to be OPERABLE only in MODES 1 and 2. since these are the only MODES where the reactor can be critical. and these MODES are consistent with the Applicability for the SLC System (LCO 3.1.7). As noted (footnote (b) to Table 3.3.6.1-1). this Function is only required to close one of the RWCU isolation valves since the signals only provide input into one of the two trip systems. 5.e. Reactor Vessel Water Level-Low Low. Level 2 Low RPV water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far fuel damage could result. Therefore, isolation of some interfaces with the reactor vessel occurs to isolate the potential sources of a break. The isolation of the RWCU System on Level 2 supports actions to ensure that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. The Reactor Vessel Water Level-Low Low. Level 2 Function associated with RWCU isolation is not directly assumed in the UFSAR safety analyses because the RWCU System line break is bounded by breaks of larger systems (recirculation and MSL breaks are more limiting). Reactor Vessel Water Level-Low Low. Level 2 signals are initiated from four level transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water 1rvel (variable leg) in the vessel. Four channels of Reactor Vessel Water Level-Low Low. Level 2 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Reactor Vessel Water Level-Low Low. Level 2 Allowat le Value was chosen to be the same as the ECCS Reactor Vessel Water Level-Low Low. Level 2 Allowable Value (LC0 3.3.5.1). since the capability to cool the fuel may be threatened. This Function isolates the RWCU isolation valves. l s l FERMI UNIT 2 B 3.3.6.1 - 19 Revision 6. 05/28/99
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) Shutdown Coolina System Isolation 6.a. Reactor Steam Dome Pressure-Hiah The Reactor Steam Dome Pressure-High Function is provided to isolate the shutdown cooling portion of the Residual Heat Removal (RHR) System. This interlock is provided only for equipment protection to prevent an intersystem LOCA scenario, and credit for the interlock is not assumed in the accident or transient analysis in the UFSAR. The Reactor Steam Dome Pressure-High signals are initiated from two transmitters that are connected to different taps ) on'the RPV. Two channels of Reactor Steam Dome Pressure-High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Function is only required to be OPERABLE in MODES 1, 2, and 3 since these i are the only MODES in which the reactor can be pressurized: ! thus, equipment protection is needed. The Allowable Value was chosen to be low enough to protect the system equipment from overpressurization. This Function. shares common instrumentation with the RPS. This Function isolates the RHR shutdown cooling valves, as appropriate. 6.b. Reactor Vessel Water Level-Low. Level 3 Low RPV water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, isolation of some reactor vessel interfaces occurs to begin isolating the
)otential sources of a break. The Reactor Vessel Water
_evel-Low, Level 3 Function associated with RHR Shutdown Cooling System isolation is not directly assumed in safety analyses because a break of the RHR Shutdown Cooling System is bounded by breaks of the recirculation and MSL. The RHR Shutdown Cooling System isolation on Level 3 supports actions to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event caused by a leak (e.g., pipe break or inadvertent valve opening) in the RHR Shutdown Cooling System. Ng' l FERMI - UNIT 2 B 3.3.6.1- 20 Revision 6 05/28/99
3 Primary Containment Isolation Instrumentation B 3.3.6.1 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) Reactor Vessel Water Level-Low, Level 3 signals are initiated from four level transmitters that sense the l differeice between the pressure due to a constant column of ! water (reference leg) and the pressure due to the actual " water level (variable leg) in the vessel. Four channels (two channels per trip system) of the Reactor Vessel Water Level-Low. Level 3 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. As noted (footnote (c) to Table 3.3.6.11), only two channels of the Reactor Vessel Water Level-Low, Level 3 Function are required to be OPERABLE in H00ES 4 and 5 (and must input into the same trip sys_ tem), provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the
)iping is intact and no maintenance is being performed that 1as the potential for draining the reactor vessel through the system.
The Reactor Vessel Water Level-Low, Level 3 Allowable Value was chosen to be the same as the RPS Reactor Vessel Water j Level-Low, Level 3 Allowable Value (LC0 3.3.1.1), since the capability to cool the fuel may be threatened. The Reactor Vessel Water Level-Low. Level 3 Function is only required to be OPERABLE in H00ES 3, 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel. In MODES 1 and 2. another isolation (i.e., Reactor
- Steam Dome Pressure-High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.
This Function isolates the RHR shutdown cooling isolation valves, as appropriate. ACTIONS A Note has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels. Section 1.3, Completion Times, specifies that once a l Condition has been entered, subsequent divisions, l subsystems, components, or variables expressed in the l Condition, discovered to be inoperable or not within limits. will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, l h l FERMIUNIT 2 B 3.3.6.1 - 21 Revision 6 05/28/99 L
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued) with Completion Times based on initial entry into the-Condition. However, the Required Actions for inoperable primary containment isolation instrument uion channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment isolation instrumentation channel. Ad Because of the diversity of sensors available t* Novide isolation signals and the redundancy of the is e >on l design, an allowable out of service time of IT s for Functions 1.f, 2.a. 2.c. and 6.b and 24 hours for Functions other than Functions 1.f. 2.a. 2.c. and 6.b has been shown to be acceptable (Refs. 5 and 6) to permit restoration of any inoperable channel to OPERABLE status, This out of service time is only acceptable provided the associated , Function is still maintaining isolation capability (refer to Required Action B.1 Bases). If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time.- the channel must be placed in the i tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue with no further restrictions. Alternately, if it is not desired to place the channel in tri) (e.g. as in the case where placing the inoperable clannel in trip would result in an isolation), Condition C must be entered and its Required Action taken. Ed Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped l channels within the same Function result in redundant automatic isolation ca l penetration flow paths). (pability The MSt.being lost forFunctions Isolation the associated are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip, such that both trip systems will generate a trip signal from the given Function on a valid signal. The other isolation functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip, such that one trip system will generate a trip signal from the given l FERMI UNIT 2 B 3.3.6.1-22 Revision 6. 05/28/99
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued) Function on a valid signal. This ensures that one of the two PCIVs in the associated penetration flow path can receive an isolation signal from the given Function. For Functions 1.a.1.b.1.d. and 1.f. this would require both l trip systems to have one channel OPERABLE or in trip. For Function 1.c, this would require both trip systems to have one channel, associated with each MSL. OPERABLE or in trip. j For Functions 1.e and 1.g. each Function consists of channels that monitor several locations within a given area (e.g., different locations within the main steam tunnel area). Therefore, this would require both trip, systems to have one channel per location OPERABLE or in trip. For Functions 2.a. 2.b 2.c, 3.b, 3.c. 4.b. 4.c. 5.e. and 6.b. ! this' would require one trip system to have two channels. each OPERABLE or in trip. For Functions 3.a. 3.d. 4.a. 4.d. 5.a. 5.d. and 6.a. this would require one trip system to have one channel 0PERABLE or in trip. For Functions 5.b and 5.c, each Function consists of channels that monitor several different locations. Therefore, this would require one channel per location to be OPERABLE or in trip (the channels are not required to be in the same trip system). The Completion Time is intended to allow the operator time to evaluate and. repair any discovered inoperabilities. The ! I hour Completion Time is acceptable because it minimizes r_isk while allowing time for restoration or tripping of channels. C.d Required Action C.1 directs entry into the appropriate Condition referenced in Table 3.3.6.11. The applicable Condition specified in Table 3.3.6.11 is Function and MODE or other specified condition dependent and may change as the ! Required Action of a previous Condition is completed. Each time an inoperable channel has not met any Required Action of Condition A or B and the associated Com)letion Time has expired, Condition C will be entered for tlat channel and provides for transfer to the appropriate subsequent Condition.
/
l FERMI UNIT 2 B 3.3.6.1-23 Revision 6. 05/28/99
[ Primary Containment Isolation Instrumentation B 3.3.6.1 l BASES ACTIONS (continued) l D.1. D.2.1. and 0.2.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LCO does not apply. This is done by placing the plant in at least MODE 3 within 12 hours and in MODE 4 within 36 hours (Required Actions D.2.1 and D.2.2). Alternately, the associated MSLs may be isolated (Required Action 0.1), and, if allowed (i.e., plant safety analysis allows operation with an MSL isolated), operation with that MSL i isolated may continue. Isolating the affected MSL l accomplishes the safety function of the inoperable channel. The Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. E.1 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, the plant must be placed in a MODE or other specified condition in which the LC0.does not apply. This is done by placing the plant in at least MODE 2 within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems. L.1 If the channel is not restored to OPERABLE status or placed ) in trip within the allowed Completion Time, plant operations may continue if the affected penetration flow path (s) is isolated. Isolating the affected penetration flow path (s) accesiplishes the safety function of the inoperable channels. For the RWCU Area and Area Ventilation Differential ' Tem >erature-High Functions, the affected penetration flow pat 1(s) may be considered isolated by isolating only that portion of the system in the associated room monitored by the inoperable channel. That is, if the RWCU pump room A area channel is inoperable, the pump room A area can be isolated while allowing continued RWCU operation utilizing 3 l FERMI - UNIT 2 B 3.3.6.1 - 24 Revision 6 05/28/99 b
l l Primary Containment Isolation Instrumentation B 3.3.6.1 , i BASES ACTIONS (continued) l the B RWCU pump. For the RWCU Differential Flow-High Function, if the flow element / transmitter monitoring RWCU l flow to radwaste and condensate is the only portion of the channel inoperable, then the affected penetration flow path (s) may be considered isolated by isolating the RWCU return to radwaste and condensate. Alternately. if it is r.ot desired to isolate the affected penetration flow path (s) (e.g., as in the case where i isolating the penetration flow path (s) could result in a I reactor scram). Condition G must be entered and its Required Actions taken. The 1 hour Completion Time is acceptable because it I minimizes risk while allowing sufficient time for plant operations personnel to isolate the affected penetration flow path (s). . G.1 and G.2 If the channel is not restored to OPERABLE status or placed in trip within the allowed Completion Time, or any Required Action of Condition F is not met and the associated Completion Time has expired, the plant must be placed in a MODE or other s,pecified condition in which the LC0 does not apply. This is done by placing the plant in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. H.1 and H.2 If the channel is not restored to OPERABLE status or placed in tri) within the allowed Completion Time, the associated SLC su) system (s) is declared inoperable or the RWCU System is isolated. Since this Function is required to ensure that l the SLC System performs its intended function, sufficient remedial measures are )rovided by declaring the associated l SLC subsystems inoperaale or isolating the RWCU System. The 1 hour Completion Time is acceptable because it minimizes risk while allowing sufficient time for personnel to isolate the RWCU System. l FERMI UNIT 2 B 3.3.6.1 - 25 Revision 6. 05/28/99
i l 1 i Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued) I.1 and I.2 , If the channel is not restored to OPERABLE status or placed i in trip within the allowed Completion Time, the associated l penetration flow path should be closed. However, if the shutdown cooling function is needed to provide core cooling, i these Required Actions allow the penetration flow path to l remain unisolated provided action is immediately initiated to restore the channel to OPERABLE status or to isolate the RHR Shutdown Cooling System (i.e.. provide alternate decay i heat removal capabilities so the penetration flow path can be isolated). Actions must continue until the channel is restored to OPERABLE status or the RHR Shutdown Cooling System is isolated. l SURVEILLANCE As noted at the beginning of the Srs, the Srs for each REQUIREMENTS Primary Containment Isolation instrumentation Function are found in the SRs column of Table 3.3.6.11. The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed. U)on completion of the Surveillance, or expiration of tie allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken. This Note is based on the reliability analysis (Refs. 5 and 6) assumption of the average time required to perform channel surveillance. That analysis demonstrated that the testing allowance does not significantly reduce the probability that the PCIVs will isolate the penetration flow path (s) when necessary. SR 3.3.6.1.1 , Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or of I FERMI - UNIT 2 B 3.3.6.1- 26 Revision 6 05/28/99
)
I Primary Containment Isolation Instrumentation B 3.3.6.1 i BASES SURVEILLANCE REQUIREMENTS (continued) something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties. including indication and readability. If a channel is outside the criteria. it may be an indication that the instrument has drifted ~outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. SR 3.3.6.1.2 A CHANNEL FUNCTIONAL TEST is performed on each required I channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of. the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The 92 day Frequency of SR 3.3.6.1.2 is based on the reliability analysis described in References 5 and 6. SR 3.3.6.1.3 This surveillance provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not s l FERMI UNIT 2 B 3.3.6.1- 27 Revision 6 05/28/99
I l i Primary Containment Isolation Instrumentation B 3.3.6.1 i BASES SURVEILLANCE REQUIREMENTS (continued) l beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than that accounted for in the appropriate setpoint methodology. The Frequency of 92 days is based on the reliability analysis of References 5 and 6. SR 3.3.6.1.4 A CHANNEL CALIBRATION is a complete check of the instrument
- loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive ,
calibrations consistent with the plant specific setpoint ' methodology. The Frequency of SR 3.3.6.1.4 is based on the assumption of a = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. SR 3.3.6.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the I - OPERABILITY of the required isolation logic for a specific channel. The systein functional testing performed on PCIVs i in LC0 3.6.1.3 overlaas this Surveillance to provide complete testing of t1e assumed safety function. The l 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an un)lanned transient if the Surveillance were performed with tie reactor at power 0)erating experience has shown these components usually pass 11e Surveillance when performed at the 18 month Frequency. 1 4
.M l FERMI - UNIT 2 8 3.3.6.1 - 28 Revision 6 05/28/99
i Primary Containment Isolation Instrumentation B 3.3.6.1 BASES l SURVEILLANCE REQUIREMENTS (continued) l l SR 3.3.6.1.6 l This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The instrument response times must be added to the PCIV closure times to obtain the ISOLATION SYSTEM RESPONSE TIME. l ISOLATION SYSTEM RESPONSE TIME acceptance criteria for the instrumentation portion are included in Reference 7. while the acceptance criteria for the PCIV closure times are included in Reference 8. This test may be performed in one measurement, or in overlapping segments, with verification l thaf all components are tested. A Note to the Surveillance states that the radiation detectors may be excluded from ISOLATION SYSTEM RESPONSE TIME testing. This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time. Response times for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel. In addition. Note 2 states the response time of the sensors are excluded from the ISOLATION SYSTEM RESPONSE TIME testing. The sensors for the tested Functions are assumed to operate at the sensor's design response time. This allowance is supported by Reference 10 which determined that significant degradation of the sensor channel response time l can be detected during performance of other Technical Specification SRs and that the sensor response time is a small part of the overall response time testing. ISOLATION SYSTEM RESPONSE TIME tests are conducted on an 18 month STAGGERED TEST BASIS. The 18 month Frequency is i consistent with the typical industry refueling cycle and is {
- based upon plant operating experience that shows that random l failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.
J l l FERMI - UNIT 2 B 3.3.6.1 - 29 Revision 6. 05/28/99 l l
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES REFERENCES 1. UFSAR. Section 6.3.
- 2. UFSAR. Chapter 15.
- 3. NED0 31466. " Technical Specification Screening Criteria Application and Risk Assessment."
November 1987.
- 4. UFSAR. Section 4.5.2.4.
- 5. NEDC-31677P-A " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation."
July 1990.
- 6. NEDC 30851P A Supplement 2. " Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation." March 1989.
~
- 7. UFSAR. Section 7.3.
- 8. UFSAR, Section 6.2.
- 9. NE00-31400. " Safety Evaluation for Eliminati0g the BWR MSIV Closure' Function and Scram Function of the MSL
. Radiation Monitor." Licensing Topical Plant Report for BWROG.
- 10. NE00-32291. " System Analysis for Elimination of Selected' Response Time Testing Requirements." January 1994: and Fermi 2 SER for Amendment 111 dated April 18, 1997.
)
g l FERMI UNIT 2 B 3.3.6.1 -30 Revision 6. 05/28/99
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- l -4+t The isolation actuation instrumentation channels shown in Table 3.3.2-1 shall be OPERABLE fETIT etr trip seu d n u m con [> sons ie 3.3.2 2
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Qhnwn In tha Tr+n (at t column of l APPLICABILITY: As shown in Table 3.3.2-1. O ACTIOM NOT& f pWith an isolation ~ a . actuation instrumentation channel trip setpoint *3 4cT109 A less conservative than the value shown in the Allowable Values column of Table 3.3.2-2, declare the channel inocerable until. the [f De( (OpgtA$pf( channel is restored to OPERABLE statusfwith itprio se}4otntJ_-
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- 2. If placing t inoperable nanneits) in the/ tripped con _diffon would not se an' isolatWn_/the inoperable channel (s)Vnd/cr that trip stem /shall be placed in the tripoed condition within: L'GptAc6 WIM FwM11M ;dh f a) 12 hours for trip functionsfc(ommon to RPS Instrumentatio I and l b) 24 hours for trip functionfot common to RPS Instrumentatio$ ggpt&g wirn ruagnaid ,) '
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_ __ IS0lAT10h ACTbAi104_[NSTRUMENTATION 00 15MM [8W ACTION STATEMENTS ACTION 20 - Be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN lO
$ CT184 D j 6r A mog o ACTION 21 - r.; within. .the - . . next
_ _ 24 hour ds.the associated isolation valves close
=;=
within@ hours or be in at least HOT SHUTDOWN within 12 hours a in COLD SHUTDOWN within tne next 24 nours. % g~ ACT10M E ACTION 22 - Be in at least STARTUP within 6 hours. Close the affected system isolation valves within I hour gpou p ACTION 23 - m i..; p. .cs....a . y. . u .. gt . A.q Su ACTION g 4 Estao613n SECONDARY CONTAINMENT INTEGRITY with the standby gas Mciblim 314.'t- -, operating within I hour.
...,the closeo position the affected system isolation OCTioN F ACTION 25 - 1.......
yams w thin I hour :nd :n'er; t : : u t -- ~ ' ' ; x x : f "" g [,Q,(, QilUM Zb
- H tore t manual intua on tunctic to urtxAutt status unin
' urs or ose the affec o system 1 lation valves wit in
.v, han .nx x rise. , .sso.. ....--.---i-
# c; g \ ACTION, t'oiFeihe manual initiation funett'en to OPiilAU status within 8 hours or establish SECONDARY CONTAINMENT INTEGRITY with the g;p;g A Stan Treatment System operating.
g,g, g TABLE NOTATIONS
- When handling irradiated fuel in the seconoary containment, during CORE Al.TERATIONS. or during operations with a potential for draining the g reactor vessel.
The high condenser pressure input to the isolation actuation d TBL 3 %.l-1, ** thk (a) instrumentatina =2v be bynassed durina r? actor shutdown or for reactor _ g,g g startup nufendenserfressure ganove tne tpG setooinM jS 3 g, Actuates dampers shown in Iable 3.6.5.21.
\ec64mh..
J w.'2. { .( (a) .A channel may be placed in an inocerable status for uo to '-' 6 hours
= -"
for recytred surveillance withoutfM :- :: in m....... i -- ra g,c*; g*g ! IR NOT61 r -" ,--- - --'.oroviceo . ._.. ;In: e ... ... . .addition,
.aM z-- for tne 6 -~ - . ..,..
- 1. . _ m m HPCI system and RCIC system isolation, provided : -_x...' ^
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! "'E"**.i :-f 2" x ":t ut=t t..- .t . _x n ri -- . _. ...-- ..ive is ! ?---'.T."Sne channel may oe placed in an inoperable status for up to 8 hours for required surveillann--ih ,iacina vn. --- - - = gyst: -- it: M __x x i t -- f l et
\ (r I
$"I (* b) Also starts the standby gas treatment system.
f N A channel is ODERARIF if 7 nf a notectnet M that enannel are OPERABLDr M (2.
# S' ::. . -
M L;.a. 3/4 3-14 Amenoment No. /J, 75.102 FERMI - UNIT 2
&l PAGE /p op 73 L
1 Specsm comon 3. 3. C,. l l lSO Set Spcci['ca km 3 3,(,, z ) E L'.' ? ? (Continued) ISOLATION ACTUATION INSTRUMENTATION TABLE NOTATIONS (Continued) IV6CNm (f) is tes with simui neous KLIL Steam suppfy Pressure-Low (150 tio 44 I rumentation) Drywell Pressure Hig6 (ECCS Actuation nstrumentation) f r bCM 'g) I ates wnn sim aneous NFL1 steam 5 ply Pressure-Low (i ntation) and Drywell ressure-High (ECCS ati tuatic;,
\
~
Ke. uation Instr "' nitrumentatin .7 l (h) IhIstri tunction is de ved from three non ecundant flow transm tters and a n-redundant flo sumer, inoperabi ity of the non-redun nt
- irc try causes the annels in both tri systems to be inoper le.
^^
- The emaineder of th ci rr"" 4 e -^d"at: :nd::nbc:-9d-nd trio system ba s,lBoth trip systems may be placed in an inoperable M dot 614 Da status for up to 2 hours for required surveillance of the non-redundant e circuitry without taking the required ACTION provided that the remainder of the Reactor Water Cleanup System isolation channels (except the SLCS Initiation) are OPERABLE.
T #' (i) Secondary Containment isolation Push buttons. l
'h',"
noto+oa _r 4) f h lh time gelay of )& secon @ (U ~ Thes(trio function (s) Ve common to the F S trip funrf h j i FERMI - UNIT 2 3/4 3 14a Amendment No. /J, 75, /A, 102 PAGE 7 _ 0F 13 %b l I
DISCUSSION OF CHANGES ITSi SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION I ADMINISTRATIVE-l A.1 In the converskon of the Fermi 2 current Technical Specifications (CTS)._to the proposed plant specific Improved Technical . Specifications (ITS), certain wording preferences or conventions
.are adopted which do not result in technical changes (either actual _ or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1.
A.2 ITS LC0 3.3.6.1 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LCO.
" Separate Condition entry is allowed for each channel." This is acceptable because.the Required Actions for each Condition provide appropriate comp'nsatory actions for each inoperable primary containment isolation channel. Complying with the F,tequired Actions will allow for continued operation; with subsequent inoperable primary containment isolation channels governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with nc impact on safety because the clarifi:ations provided by the Note are consistent with the existing interpretation of the CTS. ' A.3 CTS 3.3.2 specifies Actions for primary containment isolation channels with setpoints n_ot within allowable values. These ly ,
Actions state " declare the channel inoperable until the channel is 9 m restored to Operable status." ITS 3.3.6.1 contains all the requirements and Actions for primary containment isolation channels, including the allowable values and Actions when it is not met. The usage rules of Technical Specifications adequately dictate that channels be declared inoperable and Actions taken until restored to Oper'able, without a primary containment isolation specific statement to that effect. Therefore. elimination of this statement is an administrative presentation preference only. A.4- CTS 3.3.2,' Actions b.1 and b.2 as well as footnote
- provide
' directions on options for compliance with Technical Specifications (1.e., optional direction for not trip 91ng channels if it would jk
'cause an isolation, and optional directien to restore the inoperable channels to Operable status when tripping would cause
~ an isolation). ITS 3.3.6.1 Actions do not include detailed direction for these options; rather the optional Actions presented
. FERMI' UNIT 2 -
1 REVISION 6, 05/28/99l
I I DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION rely upon the guidance nf LC0 3.0.2. The LC0 3.0.2 guidance allows defaulting to other Actions if one can not, or is desired l not to be complied with, and also allows that restoration within- I the time limits of the specified Required Actions. The CTS has i been revised to delete these Actions since these options always ! exist, and are inherent in the ITS. During this presentation reformatting, no technical changes (either actual or , interpretational) were made to the TS. The change is consistent I with NUREG-1433. A.5 CTS 4.3.2.2 requires an LSFT "and simulated automatic operation" g of all channels. The " simulated automatic operation" is A interpreted to be included in the LSFT. This additional detailing led of the requ-ired test is unnecessary. Therefore its elimination is - an administrative change. I A.6 CTS 4.3.2.3 details the staggered testing frequency.for Isolation System Response Time testing. These details are incorporated in the ITS definition of Staggered Test Basis: therefore, ITS presents the testing Frequency utilizing the definition in lieu of the explicit details found in the CTS. This change is a presentation preference only with no' technical change or change in intent. A.7 CTS Table 3.3.2 1 Functions 3.a (RCIC Steam Line Flow - High) and 4.a (HPCI Steam Line Flow High) are subdivided in to a
" differential pressure" channel and a " time delay" channel. ITS Table 3.3.6.1-1 Functions 4.a and 3.a respectively address these Functions, but maintain the differential pressure and time delay features as portions of the same required channel. This is a presentation preference only, consistent with the design of the system and the intent of the NUREG 1433 presentation.
A.8 CTS Table 3.3.2-1, Action 21, requires this MSIV closure in 6 hours, but also provides an option to be in Mode 3 in 12 hours. Since the option is an acceptable alternative for compliance with the Action, the 12 hours is implicitly allowed for either option (close MSIVs or be in Mode 3). For example, if the option to shutdown was initially chosen, but at hour ll, the alternative action to close MSIVs was completed, the CTS Action would be satisfied without a. Technical Specification violation. Therefore, to clarify the presentation, both actions are presented in ITS 3.3.6.1 Action D with a 12 hour Completion Time. Since no technical changes are introduced, this change is considered FERMI - UNIT 2 2 REVISIUN 6. 05/28/99l
DISCUSSION OF-CHANGES. ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION administrative. A.9 CTS Table 3.3.21 ' Actions 23 and 25. require the affected system isolation valves be closed and the affected system declared-inoperable. ITS Table 3.3 6.1' Action F require that the affected system isolation valves be closed, but does not provide dire'ction
- s. to declare the affected system inoperable. The assessment of the Operability status of systems is an ongoing function of the licensed. operator and therefore the explicit statement is considered an unnecessary informational reminder. Elimination of this reminder is presentation preference which represents no change in intent. Therefore, it is an administrative change with -
no impact on safety. A.10 CTS Table 3 3.2-1. footnote (a). allows required surveillance testing without " placing the trip system in the tripped condition." ITS SR Note 2 (part b) provides the same allowance. stated as " entry into the associated Conditions and Required h Actions may be delayed." Furthermore, for the HPCI and RCIC
-Isolation Functions the CTS footnote provides details that are consistent with the ITS Note 2 (part c) allowance of " provided the associated Function maintains isolation capability." These represent a clarification of the intent, and as such are considered administrative changes.
A.11 CTS' Table 4.3.2.11 requires a Channel Functional Test on the SLC initiation Function for the RWCU isolation actuation. Additionally. CTS 4.3.2.2 requires a Logic System Functional Test (LSFT). ITS Table 3.3.6.1-1 requires only the performance of an LSFT for the SLC initiated RWCU isolation Function. This is considered an administrative change since the requirements for a Channel Functional Test of a manual actuation channel is completely met by the requirement 5 for an LSFT. Therefore. ! elimination of duplicate testing is an administrative change with no impact on safety. 1 i FERMI UNIT 2 3 REVISION 6, 05/28/99l
l l DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION A.12 CTS Table 3.3.2.1 1 Function 1.c.3 (MSL Flow - High) number of channels is stated as 2 per trip system: however this Function is I further interpreted to apply to each main steam line. Therefore, the equivalent ITS Function 1.c is stated as 2/MSL. Additionally, J CTS Table 3.3.6.1-1 Function 1.d (MSL Tunnel Temperature - High) j lists the number of channels as 2 per trip system. with footnote ] (c) clarifying that 2-of 4 detectors are required for a " channel" J to be Operable. Since typically, channels are defined from the sensors, the presentation is reformatted to present the minimum channels consisting of the 2 of 4 detectors as "2/ logic" (implied 2 channels per logic) where each " logic" contains input from 4 detectors. Furthermore, the CTS Function 1.f (Turbine Building Area Temperature - High) requirement of 2 channels per trip is presented .as ITS Function 1.9 with minimum channels of "4." The & CTS presentation had been interpreted to require 2 " logics." each 1 with 2 channels (similar to the presentation of CTS Function 1.d d described above). The revised presentation is more consistent with the ITS presentation listing the total number of channels, l These are administrative changes in presentation format with no change in the requirements. A.13 CTS Table 3.3.2-1 Functions 2.b and 2.c are RWCU isolation , Functions on various area temperatures and area ventiiation l differential temperatures. The Function names do not adequately convey the area monitored, and the required number of channels are specified without regard to the requirements in each area. ITS Table 3.3.6.11 list these Functions as 5.b and 5.c, and specify the number of channels as "1/ area" for each trip system. Furthermore, the Function names are simplified to " Area Temperature High" and " Area Ventilation Differential Temperature High." These are administrative changes in presentation format with no change in the requirements. D A.14 Not used. lI l E l , \ ,- FERMI - UNIT 2 4 REVISION 6 05/28/99l
7 i DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL CHANGES HORE RESTRICTIVE M.1- CTS Tables 3.3.2 1 and 4.3.2.1 1, Function 5.a. requires RHR isolation on low reactor vessel water level to be Operable in Modes 1, 2, and 3. ITS Table 3.3.6.1 1 Function 6.b requires that this Function be Operable in Modes 3, 4, and 5. The addition of Modes 4 and 5 is a more restrictive change adopted to provided added assurance that inadvertent reactor vessel draindown through the RHR System would be terminated on low reactor vessel water level. (The deletion of Modes 1 and 2 is addressed in a less restrictive change discussion below.) With the added Mode 4 and 5 Applicability, the minimum number of channels is required only for one trip system (ITS Table 3.3.6.1-1 Note (c)). The single trip system requirement is more restrictive than CTS requirements, and provides added assurance that inadvertent reactor vessel draindown through the RHR System would be terminated on low reactor vessel water level. - M.2 CTS Table 3.3.21, footnote (a), allows required surveillance testing that causes channels to be inoperable without taking Actions for inoperable channels "provided at least one OPERABLE channel in the same trip system is monitoring that parameter." ITS SR Note 2 (parts b and c) provides the same intended allowance by stating " entry into the associated Conditions and Required Actions may be delayed provided the associated Function maintains isolation capability."' In the case of some trip Functions literal compliance with the CTS allowance may not en.sure isolation capability remains (i.e., a single channel that is monitoring the parameter will not produce an initiation signal: since the logic is 2 out of 2). This represents a more restrictive change which has no significant impact on safety. M.3 CTS Table 3.3.21 Function 2.d. SLCS Initiation, specifies the required number of channels as "NA." ITS Table 3.3.6.1 1 Function 5.d for this same signal adds a requirement for the E Opercbility of ~2 channels," with a Note that these channels only .1 input to one trip system. Since this reflects the intent, and the design of the Fermi RWCU isolation logic, this change will have no $ j adverse impact on safety. FERMI UNIT 2 5 REVISION 6 05/28/99l
l l l l DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION l M.4 CTS Table 3.3.2-1 footnotes (f) and (g) require a Drywell Pressure
- High signal as part of the isolation from RCIC and HPCI Steam Supply Pressure - Low signals. ITS 3.3.6.1 includes these o requirements as separate line items: Functions 4.e and 3.e P respectively. (Note this is an administrative presentation 2.
preference discussed here for completeness.) However, CTS does % , not specify Surveillance Requirements for these Functions. ITS T has added appropriate SP.s. which are consistent with those l required for these same instruments in ITS 3.3.5.1. As such. l these changes will have no negative impact on safety. l TECHNICAL CHANGES LESS RESTRICTIVE
" Generic" -
LA.1 CTS 3.3.2 requires that isolation actuation instrumentation trip setpoints to be within the Trip Setpoint column va)ues of Table 3.3.2 2. Additionally, CTS 3.3.2 Action a requires that an inoperable isolation actuation instrument be restored consistent I with the trip setpoint value. However, Actions only apply if the l allowable value is exceeded. ITS 3.3.6.1 requires only that m l instrumentation setpoints be within the allowable value. Trip 6 setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip setpoints in CTS 3.3.2 and CTS Table 3.3.2 2 are relocated to the Technical Q ' Requirements Manual (TRM), which requires revisions be controlled by 10 CFR 50.59. The trip setpoint is established based on a combination of instrument design factors, environmental factors, and the allowable value (which is what is conservatively derived from the value assumed in the safety analyses). Additionally CTS Table 3.3.21 Function 2.a. RWCU Differential Flow High, is presented with footnote # stating a Function time delay of 45 seconds. The associated allowable value in the Fermi-specific setpoint calculations is specified as 48 seconds. Therefore, the specific 45-second value is considered a nominal trip setpoint, and is also relocated to the TRM. Therefore, these details can be relocated consistent with the g NUREG 1433. This relocation continues to provide adequate i protection of the public health and safety since the requirement "'- I for instrument channel Operability and the allowable value
- setpoint continues to be required by the Technical Specifications, j FERMI UNIT 2 6 REVISION 6. 05/28/99l
d DISCUSSION OF' CHANGES ITS:'SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION 1- LA.2 CTS 4.3.2.3 requires Isolation System Response Time testing of l **each isolation trip function": however, the details of the l
' testing acceptance criteria are currently located in the Technical Requirements Manual'(TRM). which requires revisions be controlled by 10 CFR 50.59. ITS 3.3.6.1 provides the Isolation System l)
Response Time Surveillance (SR 3.3.6.1.6) and each Function on Table 3.3.6.11. as appropriate references the applicability of - l this test to'that Function. Since'the majority of isolation d Functions have no specific acceptance criteria detailed in the TRM.' these Functions will not have ITS SR 3.3.6.1.6 listed as a
-Technical Specification required Surveillance. This previously w approved placement continues to provide adequate protection of the public health and safety since the requirement for instrument
, channel Operability continues to be required by the Technical l Specifications.
- LA.3' CTS Table 3'3.21 footnotes (h) and ## provide design details and l
descriptive details for various isolation actuation functions. j ITS 3.3.6.1 addresses this information in the Bases and does not , include these details in Technical Specifications, consistent with l NUREG 1433. The information is being moved to the Bases, which j requires changes to be controlled in accordance with the ITS l 5.5.10.' Bases Control Program. This relocation continues to provide adequate protection of the public health and safety since ! j the requirement for instrument channel Operability continues to be j required by the Technical Specifications. i
- ' LA.4 CTS Table 3.3.2 2 footnote ** provides a calibration setpoint I detail. ITS Ta' b le 3.3.6.11 addresses only the allowable value.
snd does not retain this calibration information.(consistent with i NUREG 1433). This detail is relocated to the Technical Requirements Manual (TRM), which requires revisions be controlled by 10 CFR 50.59. This continue ~s to provide adequate protection of the public health and safety since the requirement for instrument channel Operability continues to be required by the Technical Specifications. LA.5 , Not'used.
. ,/
FERMI UNIT 2. 7 REVISION 6, 05/28/99l
1 DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION
- LA.6 CTS Tables 3.3.21, 3.3.2 2. and 4.3.2.1 1 Manual initiation 1 Functions (1.h. 2.g. 3.e. 4.e. and 5.c) are relocated from l Technical Specifications .to the Technical Requirements Manual l
(TRM) (Surveillance testing and inoperability actions). The TRM. which requires revisions be controlled by 10 CFR 50.59, assure that adequate protection of the public health and safety is l maintained. These manual functions are simply the individual L valve and pump control switches. NUREG-1433 Table 3.3.6.1-1
- l. Manual Functions (as described in the ITS Bases) address plant designs that incorporate system level initiation ** push buttons.**
The Fermi design does not incorporate any system level initiation. Therefore, relocation of these individual component controls is ! l
. consistent' with the non-Technical Specification nature of all i other individual component controls, i l LA.7 CTS 4.3.2.3 note
- allows the sensors for Reactor Vessel Water Level 1 and Main Steam Line Flow to be exempted from being tested (acceptable values are assumed and applied to overall channel response acceptance). For these two Functions ITS SR 3.3.6.1.6 includes Note 2 to specifically detail this allowance, however, the specific alternate option of assuming the response to be the design sensor. response is relocated t'o the Bases. This detail of l performance can be adequately controlled in accordance with ITS l l 5.5.10. Bases Control Program. The relocation continues to '
provide adequate protection of the public health and safety since the' requirement for isolation system response time testing remains l l a Technical Specification requirement, l 1 LC.1
- CTS 3.3.2 Action b.1 requires compensatory action be completed I in 6 hours with inoperable channel (s) in one trip system, when tripping that channel would cause an isolation, while Action b.2 requires compensatory action be completed in 12 or 24 hours with inoperable channel (s) in one trip system, when tripping that channel would not cause an isolation. ITS 3.3.6.1 Action ,
A allows either 12 or 24 hours for one inoperable channel in ' one trip system regardless of the.effect of tripping that channel. J l . CTS 3.3.2 Action c requires placing on_e trip system in trip within 1 hour when both trip systems have inoperable channel (s): and furthermore, requires commencing the actions speciYied in CTS Table 3.3.21 within the same hour. ITS y j 3.3.6.1 Action B addresses the same condition of inoperable l FERMI . UNIT 2 8 REVISION 6. 05/28/99l l
l I DISCUSSION OF CHANGES ITS: SECTION 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION channels in both trip systems (i.e., this would result in a loss of automatic isolation capability) allows restoration of I isolation capability, without requiring additional actions. Furthermore, after restoring isolation capability (e.g.. tripping one trip system with inoperable channel (s)). ITS 3.3.6.1 Action A would continue to apply to any remaining untripped channels: thereby allowing 12 or 24 hours prior to commencing additional actions.
. CTS Table 3.3.21 footnote (a) allows required surveillance testing that causes channels to be inoperable without taking Actions for inoperable channels "provided at least one OPERABLE channel in the same trip system is monitoring that parameter."
ITS SR-Note 2 (parts b and c) addresses this allowance, but includes a less restrictive change for many Functions. The ITS allowance to delay entering Action applies to functions even though that individual trip function may not have an Operable channel in the same trip system. The ITS simply requires isolation capability, which can be met by an Operable valve and isolation logic on the other trip system (for a typical 2-out-of-2 per trip system logic). These increased allowed Completion Times and testing times are consistent with the allowed outage times and testing allowances reviewed and approved in NED0 30851-P A. Supplement 2. " Technical Specification Improvement Analyses for BWR Isolation Instrumentation Common To RPS And ECCS Instrumentation." and are l considered appropriate based on the remaining capability to trip, the diversity of the sensors available to provide the trip l signals the low probability of extensive numbers of ' inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 Y ' hour) restoration (ITS Action B). this extension to 12 or 24 hours lg for inoperabilities that still retain trip capability will not adversely affect safety. LR.1 Not used. 1 l tio at W ,, / FERMI - UNIT 2 9 REVISION 6. 05/28/99l
b DISCUSSION OF CHANGES
.ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE " Specific" L.1 CTS Table 3.3.2-1 and Table 4.3.2.1 1. Item 2.d. requires that the SLCS Initiation to be Operable in Modes 1. 2. and 3. ITS Table 3.3.6.1 1 requires the SLCS Initiation to be Operable in Modes 1 and 2 only. In Mode 3. the reactor mode switch is maintained in the shutdown position, which initially inserts a reactor scram and lh enforces a control rod block such that no control rods can be withdrawn. This is consistent with the ITS Applicability requirements for the SLC System (ITS 3.1.7). .Therefore this is a less restrictive change with no impact on safety.
L.2 CTS Table 3.3.21. Item 2.d. requires that if there is a loss of RWCU isolation on a SLCS initiation, close the affected system (RWCU). isolation valve's within 1 hour. ITS Table 3.3.6.1-1. Item
. 5.d. Action H. requires that if there is a loss of RWCU isolation on a SLCS initiation either declare associated standby liquid i control (SLC) subsystem inoperable, or isolate the Reactor Water l
Cleanup System. This is' acceptable because either action will ensure the necessary actions are performed (i.e.. either isolate
-the RWCU system-to ensure SLCS is capable of performing its safety function, or declaring the SLCS inoperable because of the loss of the RWCU isolation may hinder the SLC Function). Therefore, this less restrictive change will have no impact on safety.
L.3 CTS Tables 3.3.2 1 and 4.3.2.1 1. Function 5.a. require RHR shutdown cooling isolation on reactor vessel low water level in Modes 1. 2. and 3. ITS Table 3.3.6.1 1. Function 6.b. does not l retain the Applicability of Mode 1 and 2 for this isolation l Function (see more restrictive discussion of change for inclusion l of Modes 4 and 5 in the ITS). In Modes 1 and 2. the RHR System is l required to be Operable for the ECCS function. RHR alignment in I shutdown cooling mode of operation would render ECCS inoperable, which in turn would preclude a plant startup into Mode 2. and would require a plant shutdown if ECCS was not restored to Operable status. Furthermore, above the setpoint for the reactor vessel (shutdown cooling cut in permissive interlock) pressure - high Function the RHR shutdown cooling valves would also have an automatic isolation signal applied to assure their closure. ! Therefore, elimination of the Operability requirements for reactor vessel Grater level low isolation of RHR while in Modes 1 and 2, will not negatively impact safety. 1 FERMI - UNIT 2 -10 REVISION 6, 05/28/99l l l t
DISCUSSION OF CHANu.., ITS: SECTION 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION l l L.7 CTS Table 3.3.2 1 Action 21, contains the requirement to "be in l at least STARTUP" in addition tc "he requirement to close the l associated isolation valves (i.e.. MSIVs). In the event that 3 or more HSIVs are affected, closure of MSIVs in Mode 1 would result in an immediate automatic scram. In this case, the need to "be in startup" to close the MSIVs is simply an operational design detail that is implicit in the requirement to close the MSIVs. In the j event that 1 or 2 MSIVs are affected. they could be closed and operation could continue above Mode 2. Therefore the specific restriction u be in startup is eliminated. This relaxation is acceptable since the affected valves are assured of being placed in their isolated position: accomplishing the safety function of the inoperable instrumentation.
~
i L.8 CTS Table 3.3.2 1 and footnote ** for Function 1.e. MSIV isolation on condenser high pressure, allows bypassing "during reactor shutdown or for reactor startup when condenser pressure is above the trip setpoint." CTS Table 4.3.2.1 1 and footnote ** for the ' same Function allows bypassing "under administrative control." ITS Table 3.3.6.11 Note (a) for Function 1.d resolves this inconsistency by allowing bypassing the Function "during reactor shutdown or for reactor startup under administrative control": eliminating "when condenser pressure is above the trip setpoint." % ; Operationally, the bypass must be in effect prior to reaching the y l trip setpoint, and must remain in effect until sometime after the trip setpoint is assured of remaining cleared, since the manual %q bypass can not be made exactly at the trip setpoint transition. Ck:" l The change will allow reasonable efforts to minimize the time the i bypass is in effect, while allowing sufficient flexibility to conduct the startup or shutdown evolution without jeopardizing an unplanned trip, and without requiring routine entry into the Actions. Since this is the intent of the existing allowance. , l there is no significant impact on safety with this change. l l RELOCATED SPECIFICATIONS l None l TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect l the format and applicable content of ITS 3.3.6.1 consistent with the BWR STS, NUREG 1433, Rev. 1. 1 FERMI UNIT 2 12 REVISION 6. 05/28/99l l
Primary Containment Isolation Instrumentation l 3.3.6.1 l i INSERT 3.3.6.1-1 i a'. 2 hours for Function 5.a when testing non redundant circuitry that results in loss of isolation capability associated with this Function, provided Functions 5.b, 5.c. and 5.e are OPERABLE:
- b. 6 hours for Functions 1. 2, 5 (other than non redundant circuitry of 5.a), and 6, provided the associated Function maintains isolation capability: and I c. 8 hours for Functions 3 and 4, provided the associated Function maintains isolation capability. -
l l l) 1
]
FERMI - UNIT 2 Page 3.3 55 (INSERT) REVISION 6, 05/28/99l L t
1 l Primary Containment Isolation Instrumentation l 1 3.3.6.1 { 0,\ Tenie 3.3.6.i i cease i e4 6> (cts) l Priesey Centelruent isoletten Instrumentation Tu t.s 3.3.2.-i y,3, , 4 3 1.,1-l l APPL 1CABLt. COW ITIONS \ fgg gp IEEES Ca REGUIRED REFERENCED \ , OTWR CMANNELS FACM l MalCTION sPECIFIED CG DITIONS PER TRIP STsTEM REsUIRED ACTION C.1 SURVEILLANCE REeUIREBENTS ALLOW 4sLE VALUE
)
- 1. heln stems Line teetetten
- e. Reactor vessel Water 1,2,3 D sa 3.3.6.1.1 t =t-9451-Level- Lou Lou Law, sa 3.3.6.1.2 inches Level 1 )pa 3.3.6.1.3 ' !*#'3 i sa 3.3.6.1 4 t
- 3.3.6.1.7 $~ I sa 3.3.6.1 c. !
- b. main stems Line 1 g E_ ,pa 3.3.6.1.1M t psis l G B. w . P : !:! i l:P (i,ec25 {
\
- c. Main Steen Line 1,2,3 r$ per D e
ett+r @ g,,3.o ,;a sa 3.3.6.1.1 s j
/l*C*q\
F teu - NIsh pst sa 3.3.6.1.2 +eted-eeeen. i
)$sa 3.3.6.1.3 \ -d / l sa 3.3.6.1. !
_ sa 3.3.6.1.75 i Oo "'s- ,.osp3 1
- d. - er -pussA-3n; u 1 _D . 3.3.6.i.1 m-- l 8e>, ve) g ( e_ n_-.isa&3.3.6.1.
" i:!il: h (14 1 i
- e. Mein steen Twnet 1,2,3 D sa 3.3.6.1.1 s F Temperature - Nish . 3.3.6.1.2 /
N{,d 2k,tc. \ssa 3.3.6.1.31t sa 3.3.6.1 9,1 e_e._et.1.0_ [tini Rad 2Q
- f. Main ste
~~
1,2,3 g D
.sa3.3.6.
3.3.6.,1.1 3 5
- 3. s Nish - ' ' ' *: M I*C I
~<
X i:!iiffbXf ot j se ' g to l'
- s. Turbine sullding Aree 1,2,3 D j4sa 3.3.6.1.1 K s F // \
Twroture - Nish g,g, 2 g (, /
. 3.3.6.1. p f,i p i in y. tion / i,2,3/ p . 3.3.6.y -
/], g
./
(contirsaed) ce>.e rc:_.-r=:- ,tm - ' - - x _ M WiAjCN D
~
l Shd6t4/h ov- N (letM QQ tmde admin 1Mra+sa conbet. BWR/4 STS 3.3-57 Rev 1, 04/07/95
l t Primary Containment Isolation Instrumentation 3.3.6.1 l g.\ ( cts ) tabte 3.3.6.1 1 cpag 2 of 6> 7et5 1 3.2.-l \ Primary Conteirament teoletten 3rstrumentation 3.), 2 - 2 j 4.3.2..l-l , APPLICASLE Coe IfIONS l IIODEs On ateUlaED REFEnfMCED Fum rt o u ; OTIIEa CWUINEks FRON - I SPECIFIED Pfa TalP afeUlaED SURVEILLANCE ALLOhm4LE FUNCTION COW Ifl0Ns SYSTEM ACTION C.1 REGUIREM NTs VALUE
- 2. Primary Contelrvesnt teolation
- e. aeector Yessel Water level-Low, Level 3 1,2,3 g sa 3.3.4.1.1 sa 3.3.6.1.2 a 1101'Tnchee
[f,o, . l l Vsa 3.3.6.1.3A \ l [ /Nsarl-+(6. os 2) li'i
- 33i'-
[ 3.3.6./-1 Drywlt Pressure-High 1,2,3 hc, l8 l A9 sa 3.3.6.1.1 pais l sa 3.3.6.1.2 l.h !
)fsa 3.3.6.1.3f' sa 3.3.6.1
- " r
- H... +....
- c. Drywell 1,2,3 (1) F su 3.3.6.1.1 aedletion- Nish sa 3.3.6.1.2 s userJ R/hr }
sa 3.3.6.1.6 se . 3J.6.1.7
- d. aeector ileiris 1 ,3 [2] sa 3.3.4.1.1 3 ma/hr l
' sa 3.3.6.1.2 '
and tien- Nish sa 3.3.6.1.6 sa 3.3.4.1.7 sa 3.3.6.1.8
- e. Refueling Floor . 1,2,3 a sa 3.3.6. 1 3 (2 01 r Exhauet sa 3.3. 1.2 mediation- Ni sa 3. .1.6 sa 3 .6.1.7 sa .3.6.1.8 P
g .' Marust i etion 1,2,3 r s sa 3.3.6.1.7 NA
- 3. alsh Pressure Coolant Injection (NPCI) system teoletten 4 g ;gpg j g
- e. WPCI steen Line 1,2,3 1 7 sa 3.3.6.1.1 s , M ..... l/,
Fleu- mish sa 3.3.6.1.2 -
-"M -
psa3.3.6.1.3)< 3.3.6.1 gjfg ggL J, a
]
sa 3.3.6.1. h h I 5dCo o d ,A
-c ::i'..:z g m gg (cont BWR/4 STS 3.3-58 Rev 1, 04/07/95 A' I _
Primary Containment Isolation Instrumentation (crs6.1 > 3.3. Table 3.3.6.1 1 (page 3 of 6) ThL 3 3, .3.1 - l
, Prisery Centairment Isolation Instnmentation 33'1 O 4 . 3 .*L .1 - }
APPLICABLE Coholflous MtBEs OR RERJ1 RED REFERENCED F V M C T10 Aj OTNER CHAMMELs FROM SPECIFIED PER TRIP REGutRED SURVE!LLANCE ALLOWAS
~-
FUNCTION Com !TIONs SYSTEM ACTION C.1 REQUIREMENTS VALUE 3.NPCI system lootation (continued)
- b. NPCI steen swty Line 1,2,3 F sa 3.3.6.1.1 t pois i Pressure - Lou sa 3.3.6.1.2 #D Jesa 3.3.6.1.3 sa 3.3.6.1 y
" ' ' H,ww. S p ww-w-
- c. NPCI Turbine 1,2,3 F st 3.3.6.1.1 s pois Enhenst t,isphrees h st 3.3.6.1.2 'd Pressure -Nish Xst 3.3.6.1.3 st 3.3.6.1.1'[
sa 3.3.6.1. 5 g D - u ,, - -.i. i,2,3 p , 3 Cis ouu) sa 3.3.6.1 - g -; _ g NPCI C '_ 7--- w.-w.-_c.; 1,2,3 fr J11, 7 sa 3.3.6.1.1 s 'F ' Reem temperature - Nish 5% sa 3.3.6.1.2
- i hst 3.3.6.1.3 l sa 3.3.6.1.
SR 3.3.6.1.
. s w ession Poot 1,2,3 (13 F sa 3.3.6.i.1 /spop Aree Ambient {
iesperoture - N sa 3.3.6.1.2/ ' tsa 3.3.6.1.3 sa 3.3.6.1.6 sa 3.3.6.1.7
- s. seppe len Poet Aree 1,2,3 (1) F st 3 . 6.1.5 t (NAJ Temperature - Time SR 3.3.6.1.6
' Delay Reteys
!ainutes]
sa 3.3.6.1.7 f,I h saepression Pool Aree 1,2,3 til F st 3.3.6.1.1 5 1423 *F Differential sa 3.3.6.1.2 Temperature - Nish ist 3.3.6.1.33 sa 3.3.6.1.6 SR 3.3.6.1.7
- l. Emergency Area Cooler 1,2,3 (1) F sa 3.3.6.1.1 (1693'F Temperature - Nish sa 3.3.6.1.2 1st 3.3.6.1.3 st 3.3.6.1.6 3.3.6.1.7 N
- j. L Inittetten 1,2,3 e sa 3.3.6. MA (contirued) g BWR/4 STS 3.3-59 Rev 1, 04/07/95 Rev(o
i Primary Containment Isolation Instrumentation 3.3.6.1 (CTS) Table 3.3.6.1 1 (pose 6 of 6) T8l$ *>. 31 'I Primary Cantelrusent isolation Instruentation 332-1
- 9. $ . 7. . l - l APPLICAsLE Ca m!TIONS MODES OR REQUIRED REFERENCID N gggy OTHER CMANNELs FR(M FUNCTION SPECIFIED Co m ifl0Ns PER TRIP STsTEM REGUIRED ACTION C.1 SURVEILLANCE REGU!REMENTs ALLOWASLE VALUE T*
r
- 6. Reactor Core Isoletten Cooling (RCIC) system Isoletten 6.D irNS oG WaW
- e. RCIC Steen Line 1,2,3 ftp F sa 3.3.6.1.1 s Flow - Nigh % sa 3.3.6.1.2 :- _ _. V - [, R , \ (/
Vst 3.3.6.1.3X Mg 3.' . . 3 'b 2 I S&J
; .I .i ' - 4nd i f5tcond$
- b. RCIC Steen s w ty 1,2,3 g F st 3.3.6.1.1 Line Pressure-Low st 3.3.6.1.2 Mst 3.3.6.1.3r
~> f 3 Psi 9 /3 'g 5/
\
st 3.3.6.1.
. BR 3.3.6.1. --!:
- c. RCIC furbine 1,2,3 F st 3.3.6.1.1 s pD is Exhaust Diophro p st 3.3.6.1.2 m' Pressure - Nish ha 3.3.6.1.5 ' C (/
sa 3.3.6.1 q sa 3.3.6,1.f g Drywell 1,2,3 st 3.3.6.1.1 s- psig 0 J1g F sa 3.3.6.1.2 Pressure - Nish A 3.3.6.1. g,g 4 1 sa 3.3.6.1. 1 sa 3.3.6. , H2 3.3.0.
- 3. RCIC spion 1,2,3 1] F se 3.3.6.1.1 s (169]'F j Poot lent Aree sa 3.3.6.1.
T reture - Nigh [sa 3.3.6.1.3) sa 3.3.6.1.6 sa .3.4.1.7 P.\ s w ession Pool Area ,3 st 3.3.6.1.5 1 (11 F t tuA) 3
. Yesperature -Time at 3.3.6.1.6 talrutes) !
Detey asleys sa 3.3.6.1.7
- s. RCIC sweeston Poot 1,2,3 (Il F sa 3.3.6.1.1 s [423'F i Aree Differentist SP. 3.3.6.1.2 Temperature - u t sh Ist 3.3.6.1.33 sa 3.3.6.1.6 SR 3.3.6.1.7
- h. Emersency A se Cooter 1,2,3 (1) F st 3.3.6.1.1 s (1693'F j f supereture - Nish sa 3.3.6.1.2 tst 3.3.6.t.3]
/ st 3.3.6.1.6 st 3.3.6.1.7
\
(t.ont trued) i BWR/4 STS 3.3-60 Rev 1, 04/07/95 l
\
key & 4
E l l l Primary Containment Isolation Instrumentation 3.3.6.1 Gro 0A rehie 3.3.6 i i ( ese 5 o< 6) Primary Contalrment Isolation Instrsmentation
*5 -'
1 3 d 2 - 2 4.3,2 1 - l APPLICA8tE CoelT10NS Is0 des OR REQUIRED REFERENCD fWfDWJ CTNER CMANNELS FROM - sPECIFIED PER TRIP REGUltG SURVEILLANCE ALLOWAsLE 7 FUNCTION Com !TIONS SYSTEM ACTION C.1 REQUIREM NTS VALUE
- 6. RCIC system lootation (cent trued)
RCIC Epipment toem J fespersture-mish 1,2,3 g F W 3.3.6.1.16 s st 3.3.6.1.2
*F
)lsa 3.3.6.1. 3 3, SR 3.3.6.1 l
sa 3.3.6.1. p J. RCIC Ewipment Room # i 1,2,3 [1] F tst 3 3.6.1.11 s ( )*F l 1fferentieL sa 3.3.6.1.2 l Temperature - u t sh Ist 3.3.6.1.3) l SR 3.3.6.1.4 1 l - st 3.3.6.1.7 q menuet initiation 1,2,3 (1 / C SR 3.3.6.1.7 NA
- 5. seeetor Weter Cleerop (RWCU) system footetton
- e. Differential 1,2,3 sa 3.3.6.1.1 FIou - Mish pttg F s sus sa 3.3.6.1.2 2,a i st 3.3.6.1 I
. Ht!
- b. Aree 1,2,3 EP P sa 3.3.6.1.1 s *F r -
per rature - mish _,se 3.3.6.1.2 _ 2.b ) . I sa 3.3.6.1 1 _ . " H+1
- c. Aree ventitetton 1,2,3 .536 sa 3.3.6.1.1 s DifferentieL F *F /7, Temperoture - Nish p1 per rQq _sa 3.3.6.1.2, \
st 3.3.6.1 st 3.3.6.1.Tr
- d. sLC systaa Initiation 1,2 g(b) 3 gg Q,d
- e. aeoctor vessel Water Levet - Low Low, 1,2,3 g F sa 3.3.6.1.1 SR 3.3.6.1.2 t nches Level 2 Msa 3.3.6.1.
2,g sa 3.3.6.1
- 3 3 '.d -
menuet Initletion 1,2,3 per 3.3.6.1 NA I G / 54 i
,( row) .
./ ' ~ '
(continued) (b) SLC system Initletion only loputs into one of the two trip systems. BWR/4 STS 3.3-61 Rev 1, 04/07/95
- h. s kEl/h
i j Primary Containment Isolation Instrumentation B 3.3.6.1 I BASES
}
BACKGROUND 2. Primary Containment Isolation (continued) { arranged into two two-out-of-two logic trip systems. One trip system initiates isolation of all inboard primary containment isolation valves, while the other trip system l initiates isolation of all outboard primary containment isolation valves. Each logic closes one of the two valves on each penetration, so that operation of either logic ( isolates the penetration. v= - The to this arrangement is the Dr Radiation-Hig This Fu s two' channels, whose outputs are arran - ut-of-on logic trip systems. Eac s en isolates one ssociated pen , similar to the two-out-of two logic des ve = e - - t
'~__ Primary Containment Isolation Drywell Pressure-High and ;
Reactor Vessel Water Level-Low, Level 3 Functions isolate u s4 la 7HE r#yWGLLD- - * " " - - " - * ' ' " - - ' " " " " - -
":.;;;r ".i'. din; =d-i i
yvmP5 A A>D 74A vsESWQ ".:f=1':; Fl= Erh=t ".:dht h: "igh T.netien; isehte
/g co4F F4066 SyS7 EMS, th; 2:e S.10 : d 12 CIC - "ri :r; C :t^i a nt- f h 2iM #i s 5 R E= J R.'= "= "*" * ** !
f2 3. 4 Hich Pressure Coolant Iniection System Isolation and Reactor Core Isolation Coolino System Isolation
/dSE/27 Most Functions that isolate HPCI and RCIC receive input from g :3.g,f,j g two channels, with each channel in one trip system using a one-out-of-one logic. Each of the two trip systems in each isolation group is connected to one of the two valves on g
each a'sociated penetration.
# ag @dl ,
jO The exceptions are th and RCIC Turbine Ex ssut.- A'3h I Diaphragm Pressure- Steam Supply Line Pressure-Low Functions. These Fu receive inputs from four turbine exhaust diaphragm pressure and four steam supply pressure channels for each system. The outputs from the turbine exhaust diaphragm pressure and steam supply pressure channels are each connected to two two-out-of-two trip systems. Each trip system isolates one valve per associated penetration. (continued) BWR/4 STS B 3.3-154 Rev 1, 04/07/95
\.
Rev(o s
l l Primary Containment Isolation Instrumentation B 3.3.6.1 1 s BASES APPLICABLE 1.a. Reactor Vessel Water Level-Low low tow. Level 1 SAFETY ANALYSES, (continued) LCO, and APPLICABILITY . pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable ) leg) in the vessel. Four channels of Reactor Vessel Water Level-Low Low Low, Level 1 Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function. The Reactor Vessel Water Level-Low Low Low, Level 1 Allowable Value is chosen to be the same as the ECCS Level 1 Allowable Value (LCO 3.3.5.1) to ensure that the MSLs isolate on a potential loss of coolant accident (LOCA) to prevent offsite doses from exceeding 10 CFR_100 lim V M5L Aup MSL PRAWS his Function isolates the Malves. SouTiod 1.b. Main Steam Line Pressure-Low p,p on Low MSL pressure indicates that there may be a problem with [.L. the turbine pressure regulation, which could result in a low reactor vessel water level condition and the RPV cooling down more than 100*F/hr if the pressure loss is allowed to l ALTHoS4 florck.E0iTED continue. The Main Steam Line Pressure-Low Function:ds=. 9 C;;Py 9 in the analysis of the pressure regulator !
'7 failure (Ref. 2h. For this event, the closure of the MSIVs 3(5 A BACGt4' TO WlE
( ensures Inst the RPV temperature change limit (100*F/hr) is } not reached, fin addiiivn Liiis Fundivn uvyw is.au ions MAilMOM 6TEAAA LIMITER, WICH.15 FL4W)I ensure t at safety Limi .l.1.1 is not xceeded. (This ' Funct closes the MS s prior to pr sure decreasing elow CEDITED BY THIS 785 sig, which resu s in a scram d to MSIV closur . th h/A LYSIS.
- r ucing reactor o r to < 25% RTP.) f
& The MSL low pressure signals are initiated from four transmitters that are connected to the MSL header. The transmitters are arranged such that, even though physically separated from each other, each transmitter is able to detect low MSL pressure. Four channels of Main Steam Line Pressure-Low Function are available and are required to be ;
OPERABLE to ensure that no single instrument failure can l preclude the isolation function. i The Allowable Value was selected to be high enough to ' prevent excessive RPV depressurization. l l (continued) BWR/4 STS B 3.3-158 Rev 1, 04/07/g5 Rev(o
1 1 i l l l l Primary Containment Isolation Instrumentation B 3.3.6.1 l l BASES r .M PC c.5lW.C - H IQH 1.d. Condenser bx _ _- L (continued) 82 ' APPLICABLE SAFETY ANALYSES,
-LCO, and and capable of initiating closure of the MSIVs. The closure f APPLICABILITY of the MSIVs is initiated to prevent the addition of steam
( .1 that would lead to additional condenser pressurization and possible rupture of the diaphragm installed to protect the
% turbine exhaust hood, thereby preventing a potential !
g (ggggg fj radiationleakagepathfollowinganaccident.4 I CdCS/TCB W/TN C M5/h% Condenser vacuum pressure signals are derived from four TE M5I1/'s By 7h6 pressure transmitters that sense the pressure in th Pt.E55 v40"H Ihr ANAL.ySIS 4/ n/6 s condenser. Four channels of Condenser "-- ' unction g "L055 of Co/ J 4ENfff aresingle available and are required to1"de be OPERABLE n i strument failure can pres +hQsolation to ensure that. VACvuM " 6VEA/Tfunction. (RMZ).h durug reuk .shn > fcereuhe s% hp h d
%ga1 sed ander ad6Wskak<- con tre f.
. The Allowapie i.lue ir en.nTo prevent ~BilratJe g condenser due i to pressurization, thereby ensuring its d.
Op,ltointegrity for'offsite dose analysis. As noted (footnote (a) Table 3.3.6. - , the channels are not required to be Q OPERABLE in MODES 2 an ., hn':11:rbin:.:t:; :hcr KD/LocKE1) = = :hnd, since the potential for condenser 'g a verpressurization is minimized. TSwitches are provided to d V manually bypass the channels Jn -tk'(ken '11 T% S conct ; +ys) are civ>eu.~ This Function isolates the-ermrp-F vaTv'es. G M6L AAJO MSL DKAIAl.5 ISoLADO IISER3 33.f.l 1.e.-[o k M 1.o. Area ead Differerti:1 Temoerature-Hio7 Area nd $"a-aa+4=_1 temperature is provided to detect a P.4 leak in the RCPB and provides diversity to the high flow instrumentation eThe- hn1=+ 4nn nernre when a "ery ::: W 4+n 6 r~rr d If the-waM-leak is allowed to continue [-[ without isolation, offsite dose limits may be reached. However, credit for these instruments is not taken in any - g transient or accident analysis in the FFSAR, since bounding # analyses are performed for large breaks, such as MSLBs. f65tSTANCE 7ENEAA TvA 6 Area temperature signals are initiated fromtra sumpin D6T6CfogJ(tTDh located in the area being monitored. Sixteen channels of
~
Main Steam Tunnel Temperature-High Function and channels
$ 672.,p- 3 of Turbine Building Area Temperature-High Function'are available end are required to be OPERABLE to ensure that no d$
single instrument failure can preclude the isolation (3 3.3,(p.l (o8)l function. h.hr_:ti= hn n: t =;;r:tur: :h at.
/
(continued) BWR/4 STS B 3.3-160 Rev 1, 04/07/95 l l -
1 Primary Containe.cr.? Isolation Instrumentatit.n B 3.3.6.1 BASES APPLICABLE 24 4.c. HPCI and RCIC Turbin P ,aust Dia & w SAFETY ANALYSES, Pres sure-Hiah (continued) . LCO, and Hfc120 MTt* 404 isola rtos! APPLICABILITY These Functions isolate the (_.__, c.i i vaives, as I appro r ate. 3 #. # Drywell Pressure-Hioh l High drywell pressure can indicate a break in the RCPB. The HPCI and RCIC isolation of the turbine exhaust is provided to prevent comunication with the drywell when high drywell pressure exists. A potential leakage path exists via the turbine exhaust. The isolation is delayed until the system becomes unavailable for injection (i.e., low steam line pressure). The isolation of the HPCI and RCIC turbine [O 'I exhaust by Drywell Pressure-High is indirectly assumed in l
- the FSAR accident analysis because the turbine exhaust l 1eakage path is not assumed to contribute to offsite doses.
High drywell pressure signals are initiated from pressure transmitters that sense the pressure in the drywell. Two i 9, channels of both HPCI and RCIC Drywell Pressure-High Functions are available and are required to be OPERABLE to 5 6 hb. ru) Wd4k ensure that no single instrument failure can preclude the QC l# C( A uJ A C E 5 h m 5vf(IV isolation function.
' hncpossurc -bu sg nalf g ,. g g g g The Allowable Value was selected to be the same as the ECCS M Drywell Pressure-High Allowable Value (LCO 3.3.5.1), since
(( this is indicative of a LOCA inside primary containment. g This Function +schthe C ^ =" " @m. 99C7. AND FMo gviPMNT 3_1 ~ 3,1 3,', 3, - ':, _,;, 2- :, ,, 4g, ,,2 Ro0M TWF6X71/gE-Hic:H --er; = rr., m ... i emoc, m c "% Area W diffe = + b1 temperatures are provided to detect a f.l 1eak from the associated system steam piping. The isolation occurs when a very small leak has occurred and is diverse to the high flow instrumentation. If the small leak is allowed o continue without isolation, offsite dose limits may b reached. These Functions are not assumed in any /SAR s ransient or accident analysis, since bounding analyses are performed for large breaks such as recirculation or MSL breaks. (continued) BWR/4 STS B 3.3 -167 Rev 1, 04/07/95
Primary Containment Isolation Instrumentation B 3.3.6.1 l BASES l APPLICABLE 5.a. Differential Flow-Hiah (continued) SAFETY ANALYSES, LCO, and RWCU System is initiated when high differential flow is ; APPLICABILITY sensed to prevent exceeding offsite doses. A time delay is provided to prevent spurious trips during most RWCU operational transients. This Function is not assumed in any LA FSAR transient or accident analysis, since bounding analyses are_oerformed for_large breaks such as MSLBs g d hshcqscu c_ gne n y. umerennaT e flow signals are init avmP dd @ ed from transmitters that are connected to the ..ht (fr:- +'e
?c u_ ternom,"erre')
e..^--and ettht:ito condenser and feedwater)-ef-The outputs of the transmitters are compared (in a coaraon sunner) and the resulting output is sent to two high flow trip units. If the difference between the inlet and outlet flow is too large, each trip unit 140FEAABILIT'/ DF Wo - generates an isolation signal. T= :h::::h :f Offf:r:.ti:1 Afo4 - E p W BA Mf' dI44"ITA Y I Ti;; l%h Tr-th . : rd ' -M : rd _; 7;@d te L Mv5E3 7#8 C#AMMELS /Al O'C"'O C t: 22:27: th:t Si- ;h ' :t
-- rt f:ihre-coyp 7Ay sy47tMS To 8E d:r:t r- c' +'e -- -
- n :Sd: th: i;;hti;.
IAloNgABL&.1715 /EA44/A10EA s?z:ti: - OP THE QRCUIT e$ LEDvHMMY AA/D CM 86 C605/DE46p d The Differential Flow-High Allowable Value ensures that a o yg 74/g .5y3rrM 6AS/S. break of the RWCU piping is detected. l This Function isolates the 5.b. t..., ; valves.
. L wCQ R Is0LArred k 5.c. Area and Area Ventilation Differential Temperature-Hiah RWCU area and area ventilation differential temperatures are provided to detect a leak from the RWCU System. The isolation occurs even when very small leaks have occurred and is diverse to the high differential ficw instrumentation for the hot portions of the RWCU System. If the small leak continues without isolation, offsite dose limits may be reached. Credit for these instruments is not taken in any transient or accident analysis in the SAR, since bounding analyses are performed for large breaks such as recirculation or MSL breaks. g Area and area ventilation differential temperature signals are initiated from temperature element that are located in the room that is being monitored. thermocouples provide in ut to the Area Temperature-High etion (two per area). ty-.
channels are required to be OP BLE to ensure that no i Tv0 9seoem Wdd (continued) k BWR/4 STS B 3.3-170 Rev 1, 04/07/95
Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE SR 3.3.6.1.1 (continued) REQUIREMENTS CHANNEL CHECK is normally a comparison of the parameter in'dicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO. 3.3.6.1.2 x d d 2.2.5.:.5 f,l A CHANNEL FUNCTIONAL TEST is performed on each required l r - channel to ensure that the entire channel will perform the 75TF-7.A 5' intended function.y Any setpoint adjustment shall be consistent with the L assumptions of the current plant specific setpoint j methodology. (, The 92 day Frequency of SR 3.3.6.1.2 is based on the' i ol re reliability analysis, des,cr,ibed,in , ReferencesNi e 4. u...; and,___._1__
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L e (continued) BWR/4 STS B 3.3-181 Rev 1,'04/07/95 m
Primary Containment Isolation Instrumentation B 3.3.6.1 l INSERT: TSTF 205 INSERT A l A successful test of the required contact (s) of a channel relay may ( be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the j other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. j 1 l l 1 w/ FERMI - UNIT 2 Page B 3.3 181 (Insert) REVISION 6 05/28/99l t
NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL CHANGES - LESS RESTRICTIVE (Specification 3.3.6.1 "L.8" Labeled Comments / Discussions) I 1 Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the ! proposed change does not involve a significant hazards I consideration. The bases for the detennination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? .
l l The proposed change allows bypassing the MSIV isolation on condenser high pressure Function "during reactor shutdown or DC for reactor startup under administrative control"; eliminating "when condenser pressure is above the trip
~[ ;
setpoint." Since an MSIV isolation is an analyzed event,
,g-the CTS requirement to instantaneously bypass and unbypass y this trip at the trip setpoint imposes a significant probability of an unintended *MSIV isolation. The proposed change will allow appropriate flexibility to control the evolution of bypassing and unbypassing this trip as required for plant startup and shutdown. Therefore, the change will not increase the probability of an accident previously evaluated. The consequences of an MSIV closure event are unaffected by this change. Therefore, the proposed change does not contribute to an increase in the consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or , changes in norma) plant operation. Therefore, this change FERMI - UNIT 2 15 REVISION 6, 05/28/99 s
NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.6.1 - PRIMARY CONTAINMENT ISOLATION ' INSTRUMENTATION will not create the possibility of a new or different kind of accident from any accident previously evaluated. TECHNICAL CHANGES - LESS RESTRICTIVE (Specification 3.3.6.1 "L.8" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety?
The proposed change does not involve a significant reduction in a margin of safety. Operationally, the bypass must be in effect prior to reaching the trip setpoint, and must remain in effect until sometime after the trip setpoint is assured of remaining cleared, since the manual bypass can not be made exactly at the trip setpoint transition. The change De will allow reasonable efforts to minimize the time the ~I bypass is in effect, while allowing sufficient flexibility ;~g to conduct the startup or shutdown evolution without gc jeopardizing an unplannad trip, and without requiring routine entry into the Actions. Since this is the intent of the existing allowance, there is not a significant reduction in a margin of safety. A i I I FERMI - UNIT 2 16 REVISION 6, 05/28/99 s
JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.6.1 PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION I
'P.5 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES , C.1 TSTF-205: NRC approved change to NUREG 1433. 1 4 l
/
FERMI - UNIT 2 - 2 REVISION 6 05/28/99l L
Secondary Containment Isolation Instrumentation B 3.3.6.2 l BASES q BACKGROUND (continued) initiates isolation of the other automatic isolation valve in the penetration and starts the other SGT subsystem. Each logic closes one of the two valves on each penetration and starts one SGT subsystem, so that operation of either logic isolates the secondary containment and provides for the necessary filtration of fission products. APPLICABLE The isolation signals generated by the secondary containment SAFETY ANALYSES, isolation instrumentation are implicitly assumed in the LC0. and safety analyses of References 1 and 2 to initiate closure APPLICABILITY of valves and start the SGT System to limit offsite doses. Refer to LC0 3.6.4.2, " Secondary Containment Isolation Valves (SCIVs)," and LC0 3.6.4.3, " Standby Gas Treatment (SGT) System," Applicable Safety Analyses Bases for more detail of the safety analyses. The secondary containment isolation instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). Certain instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion. The OPERABILITY of the secondary containment isolation instrumentation is dependent on the OPERABILITY of the
' individual instrumentation channel Functions. Each Function must have the required nuinber of OPERABLE channels with their setpoints set within the specified Allowable Values, as shown in Table 3.3.6.2 1. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value.
Allowable Values are specified for each automatic Function 04l specified in the Table. -Nominal trip setpoints are specified in the setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS or between successive verifications of trip unit setpoints. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable. 1 FERMI - UNIT 2 B 3.3.6.2-2 Revision 6 05/28/99
Secondary Containment Isolation Instrumentation ( B 3.3.6.2 ' BASES SURVEILLANCE REQUIREMENTS (continued) channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each
)
CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument b1 certainties. l including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequancy is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel status during normal operational use of the displays associated with channels required by the LCO. SR 3.3.6.2.2 , A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel rslay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL h FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the curr.'nt plant specific setpoint methodology. The Frequency of 92 days is based on the reliability analysis of References 4 and 5. l J l FERMI - UNIT 2 8 3.3.6.2 - 10 Revision 6. 05/28/99 L
Secondary Containment Isolation Instrumentation B 3.3.6.2 1 BASES SURVEILLANCE REQUIREMENTS (continued) l SR 3.3.6.2.3 l l This surveillance provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the i l Allowable Value specified in Table 3.3.6.21. If the trip I setting is discovered to be less conservative than accounted I for in the appropriate setpoint methodology, but is not beyond the Allowable Value, performance is still within the l requirements of the plant safety analysis. Under these ! l conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology. , l The Frequency of 92 days is based on the reliability I analysis of References 4 and 5. SR 3.3.6.2.4 l A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL' CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. The Frequency of SR 3.3.6.2.4 is based on the assumption of a a 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. t
/
l FERMI UNIT 2 B 3.3.6.2 - 11 Revision 6 05/28/99
Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.6.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on SCIVs and the SGT System in LC0 3.6.4.2 and LC0 3.6.4.3. l respectively, overlaps this Surveillance to provide complete testing of the assumed safety function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an un)lanned transient if the Surveillance were performed with t1e reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. . REFERENCES 1. UFSAR. Section 6.3.
- 2. UFSAR, Chapter 15.
- 3. UFSAR.'Section 15.7.4.
- 4. NEDC 31677P A. " Technical Specification Improvement Analysis for BWR' Isolation Actuation Instrumentation."
July 1990.
- 5. NEDC 30851P-A Supplement 2. " Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation "' March 1989.
l FERMI UNIT 2 B 3.3.6.2 - 12 Revision 6. 05/28/99
SPEC a rsca parJ s. 3. G. z- [A(5o sez Opihcakn 3.3.c.f) l INSTRUMENTATION 3/4.3.2 ISOLATION ACTUATION INSTRUMENTATION t IMITING CONDITION FOR OPERATION d LLO 3,3.(,.'2 s-i2- The isolation actuation instrumentation channels shown in Table 3.3.2-1 i' shall be OPERABLE ptn sney u ir ..igwifus ses consi ~~nt witn tne vyues) M. / Uliown in tryi irip detpoinycolumn of TaFle 3.3.2-2. l APPLICABillTY: As shown in Table 3.3.2-1. ACTION: ggg gg A'1
- a. With an isolation actuation instrumentation channel trip setpoint A less conservative than the value shown in the Allowable Values e <
ftC, TION g column of Table 3.3.2-2, declare the channel inoperable until the ; l l g 0,(,( Drgjupf)[ channel is~ restored adjugea to OPERABLE consistent with the trip statuslwyth 5etopint valueg its trippetpoiys; A./
- b. With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement 5vi una t r i p~ LU frgruig) y
[rCTOM k l (s=channd inMr) Phuz
. -ii 'ecing tne in erable channe g s) in the trippeo yonottio ;
w cause an is ation, the i(ocerable channelf sVshall ~ ; r tored to OPE BLE status /Within ours or the ACTION A required oy Table 3.3.2-1 for the ffected_ trip function shall a a 2>p nCT16M C be taken. LC.\ . Z. If acing the inoperfuie cn..u ='.ia) n. 6ns 6 pip,neo concit w d not cause an idolation, the inoperable /channells) an _
,46 I at trio system Ahall be placed in the tripped condition within:
. rdEPLAcE WIT 1+ TvwcT2#4 66 5 a) 12hoursfortripfunction([commontoRPSInstrumentation) sf b) 24 hours for trip functionshot common to RPS InstrumentatioM t U L
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- c. With the number of OPERABLE channels less than required by the , '1 Minimum OPERABLE Channels per Trip System requirement";Y b:t' t-id , ' C.) R g
- g5 ^ " ' 251 ON 19; . ; _ ; -- -- -
take the ACTION required by _Iaole_3.3.2-1. within one our _
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[*Placyonetr< (condit.i E l id 17 ;,, ,y a 6cm r.usu out I:::d .. ins u ippsu svuui6 wn wh % W: muid .:::: th: i::1:t '. . . : ::: .. . FERMI - UNIT 2 3/4 3-9 Amendment No. 4 , D , A3, 100 =.J PAGE / OF 08
l DISCUSSION OF CHANGES ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications
-(CTS) to the proposed plant specific Improved Technical Specifications (ITS). certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1.
A.2 ITS LC0 3.3.6.2 Actions are modified by a Note, which provides clarification that. for the purpose of the associated LCO.
" Separate Condition entry is allowed for each channel." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable secondary containment isolation channel. Complying with the Required Actions will allow for continued operation: with subsequent inoperable secondary containment isolation channels governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on safety because the clarifications provided by tne Note are consistent with the existing interpretation of the CTS.
A.3 CTS 3.3.2 specifies Actions for secondary containment isolation chahnels with setpoints not within allowable values. These i Actions state " declare the channel inoperable until the channel is restored to Operable status." ITS 3.3.6.2 contains all the l$, requirements and Actions for secondary containment isolation channels including the allowable values and Actions when it is Q not met. The usage rules of Technical Specifications adequately dictate that channels be declared, inoperable and Actions taken , until restored to Operable, without a secondary containment l isolation specific statement to that effect. Therefore, j elimination of this statement is an administrative presentation ' preference only. A A.4 CTS 3.3.2. Actions b.1 and b.2 as well as footnote *. provide 1 directions on options for compliance with Technical Specifications lk (i.e.. optional direction for not tripping channels if it would cause an isolation, and optional direction to restore the inoperable channels to Operable status when tripping would cause an isolation). ITS 3.3.6.2 Actions do not include detailed direction for these options: rather the optional Actions presented FERMI - UNIT 2 1 REVISION 6 05/28/99l ; i i
l ; i DISCUSSION OF CHANGES l ITS: SECTION 3.3.6.2 - SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION rely upon the guidance of LCO 3.0.2. The LC0 3.0.2 guidance allows defaulting to other Actions if one can not, or is desired not to be complied with, and also allows that restoration within the time limits of the specified Required Actions. The CTS has ! been revised to delete these Actions since these options always i exist. and are inherent in the ITS. During this presentation reformatting, no technical changes (either actual or interpretational) were made to the TS. The change is consistent with NUREG 1433. A.5 CTS 4.3.2.2 requires an LSFT "and simulated automatic operation" % of all channels. The " simulated automatic operation" is 9 l interpreted to be included in the LSFT. This additional detailing l[ l of the required test is unnecessary. Therefore its elimination is Q an administrative change. A.6 CTS Table 3.3.2-1 Action 27 allows an 8 hour restoration allowance which is applied after a 6 hour allowance of CTS 3.3.2 Action b.1), providing an overall 14 hour restoration time. DOC LC.1 provides justification for a 24 hour allowance before taking l actions specified in ITS 3.3.6.2 Action C. ITS 3.3.6.2 Action A I provides this restoration time as a ' single Completion Time. This ; is an administrative presentation preference with no impact on safety. l A.7 CTS Table 3.3.2 1 footnote (a).* allows required surveillance testing without " placing the trip system in the tripped condition." ITS SR Note 2 provides the same allowance. stated as
" entry into the associated Conditions and Required Actions may be delayed." This represents a clarification of the intent and as such are considered administrative changes.
I A.8 CTS Table 4.3.2.1-1 requires a Channel Functional Test for the I secondary containment manual initiation function. Additionally, CTS 4.3.2.2 requires a Logic System Functional Test (LSFT). ITS Table 3.3.6.21 requires only the performance of an LSFT for the manual function. This is considered an administrative change since the requirements for a Channel Functional Test of a manual actuation channel is completely met by the requirements for an LSFT. Therefore, elimination of duplicate testing is an administrative change with no impact on safety. FERMI - UNIT 2 2 REVISION 6. 05/28/99l
E l I l l DISCUSSION OF CHANGES l ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION l IfCHNICAL CHANGES HORE RESTRICTIVE M.1 CTS Table 3.3.21. footnote (a), allows required surveillance testing that causes channels to be inoperable without taking Actions for inoperable channels "provided at least one OPERABLE channel in the same trip system is monitoring that parameter." ; ITS SR Note 2 provides the same intended allowance by stating !
" entry into the associated Conditions and Required Actions may be delayed provided the associated Function maintains isolation I capability." In the case of some trip Functions (i.e. reactor vessel wator level and drywell pressure) literal compliance with j the CTS allowance may not ensure isolation capability remains (i.e., a single channel that is monitoring the parameter will not produce an initiation signal: since the trip system logic is 2- )
out of 2). This represents a more restrictive change which has no ! significant impact on safety. 1 TECHNICAL CHANGES LESS RESTRICTIVE
" Generic" ;
LA.1 CTS 3.3.2 requires that isolation actuation instrumentation trip setpoints to be within the Trip Setpoint column values of Table 3.3.2 2. Additionally. CTS 3.3.2 Action a requires that an inoperable isolation actuation instrument be restored consistent I with the trip setpoint value. However. Actions only apply if the allowable value is exceeded. ITS 3.3.6.2 requires only that instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip setpoints in k) I CTS 3.3.2 and CTS Table 3.3.2-2 are relocated to the Technical Requirements Manual (TRM), which requires revisions be controlled N by 10 CFR 50.59. The trip setpoint is established based on a combination of. Instrument design factors, environmental factors. k Q I and the allowable value (which is what is conservatively derived ! from the value assumed in the safety analyses). Therefore, these details can be adequately defined and controlled in the TRM. consistent with the NUREG-1433. This relocation continues to provide adequate protection of the public health and safety since the requirement for instrument channel Operability and the g ' allowable value setpoint continues to be required by the Technical Specifications. FERMI UNIT 2 3 REVISION 6 05/28/99l
DISCUSSION OF CHANGES l ITS: SECTION 3.3.6.2 - SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION LA.2 CTS 4.3.2.3 requires Isolation System Response Time testing of i "each isolation trip ta ction": however, the details of the testing acceptar.ce criteria are currently located in the Technical
, Requiremen'st Manual (TRM). outside of Technical Specifications. l)
ITS 3.3.6.2 does not include the Isolation System Response Time c9 Surveillance for secondary containment isolation Functions, since I i no specific Technical Specification acceptance criteria are k established by the TRM for the secondary containment isolation < Functions. This previously approved placement continues to l$d provide adequate protection of the public health and safety since the requirement for instrument channel Operability continues to be required by the Technical Specifications. LA.3 CTS Table 3.3.21 footnotes ***. ##. (b). and (i), provide design details and descriptive details for various isolation actuation functions. -ITS 3.3.6.2 addresses this information in the Bases and does not include these details in the Technica} Specifications. This change is consistent with NUREG-1433. The information is being moved to the Bases, which requires changes to be controlled in accordance with the ITS 5.5.10. Bases Control Program. This relocation continues to provide adequate protection of the public health and safety sinc'e the requirement for instrument channel Operability continues to be required by the Technical Specifications. LC.1 e' CTS 3.3.2 Action b.1 requires' compensatory action be completed in 6 hours with inoperable channel (s) in one trip system, when tripping that channel would cause an isolation, while Action b.2 requires compensatory action be completed in 12 or 24 hours with inoperable channel (s) in one trip system, when tripping that channel would not cause an isolatir ITS 3.3.6.2 Action A allows either 12 or 24 hours (the manuoi runction includes a 24 hour allowance: refer to discussion "A.6") for one inoperable channel in one trip system regardlers of the effect j of tripping that channel. i e l FERMI UNIT 2 4 REVISION 6 05/28/99l s
l DISCUSSION OF CHANGES ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION l LC.1 (continued)
- . CTS 3.3.2 Action c requires placing one trip system in trip l within 1 hour when both trip systems have inoperable l channel (s): and furthermore. requires commencing the actions l specified in CTS Table 3.3.2-1 within the same hour. ITS 3.3.6.2 Action B addresses the same condition of inoperable ly-i channels in,both trip systems (i.e.. this would result in a loss of automatic isolation capability) allows restoration of k
isolation capability, without requiring additional actions. l l Furthermore, after m stnring isolation capability (e.g.. l tripping one trip system with inoperable channel (s)). ITS , 3.3.6.2 Action A would continue to apply to any remaining i untripped channels: thereby allowing 12 or 24 hours prior to commencing additional actions. l
- CTS Table 3.3.2-1 footnote (a) allows required sarveillance testing that causes channels to be inoperable without taking i
- Actions for inoperable channels "provided at least one OPERABLE channel in the same trip system is monitoring that parameter."
ITS SR Note 2 addresses this allowance, but includes a less restrictive change for the reactor vessel water level and drywell pressure Functions. The ITS allowance to delay entering Action applies to these Functions even though that individual trip function may not have an Operable channel in
'the same trip system. The IT$ requires isolation capability.
l which can be met by an Operable valve and isolation logic on the other trip system (a typical 2-out of-2 per trip system). These inr eased allowed Completion Times and testing times are consistent with the allowed outage times and testing allowances i reviewed and approved in NED0 30.851-P A. Supplement 2. " Technical l Specification Improvement Analyses for BWR Isolation l Instrumentation Common To RPS And ECCS Instrumentation." and are l considered appropriate based on the remaining capability to trip. the diversity of the sensors available to provide the trip signals, the low probability of extensive numbers of inoperabilities affecting all diverse Functions, and the low probability of an event requiring the initiation of an isolation. Since a loss of trip function continues to require immediate (1 \n hour) restoration (ITS Action B), this extension to 12 or 24 hours ' forinoberabilitiesthatstillretaintripcapabilitywillnot lk adversely affect safety. l FERMI -. UNIT 2 5 REVISION 6 05/28/99l
l DISCUSSION OF CHANGES l l ITS: SECTION 3.3.6.2 - SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION l l TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" L.1 CTS Table 3.3.2 1 and Table 4.3.2.1-1. Function 6.a. requires that the reactor vessel water level Function be Operable (in addition to other specified conditions) when handling irradiated fuel in the secondary containment and during Core Alterations. ITS Table 3.3.6.21 Function 1 eliminates the handling fuel and Core
- Alteration Applicabilities for the reactor vessel water level Function (but retains the other Applicabilities consistent with the CTS). The reactor vessel low level Function only actuates in the event of a vessel draindown event (i.e.. an event initiated as a result of an operation with a potential for draining the reactor vessel). ileactor vessel water level Function is not assumed to actuate to provide secondary isolation for any event that 13 postulated to occur during core alterations or fuel handling i (which is performed with the reactor cavity flooded). Therefore.
this is a less restrictive change with no impact on safety. L.2 CTS Table 3.3.21. Actions 24 and 27 for an inoperable secondary l containment isolation instrumentation, require Secondary - Containment Integrity be established with standby gas treatment ' (SGT) operating. These Actions are applicable at times when the Secondary Containment Integrity is already required by another Specification, therefore, it is not necessary to explicitly repeat ; the requirement to maintain secondary Containment Integrity. However, consistent with the CTS requirements for Secondary Containment Integrity, which provide options for Operable SCIVs or j taking specified actions for inoperable SCIVs. the ITS Actions for i inoperable secondary containment isolation instrumentation do l explicitly focus on SCIVs. ITS 3.3.6.2 Required Actions C.1.1 and C.1.2 implement the same CTS allowances for SCIVs (maintain them i Operable or take specified acti'ons for inoperable SCIVs). This is an administrative presentation preference presented here for completeness. 3 4 As for the CTS requirement to establish SGT operating. ITS k Required Action C.2.1 presents this same requirement, however, provides an option (Required Action C.2.2) to declare the associated SGT subsystem inoperable. This alternate Action for the loss of secondary containment isolation instrumentation is normally allowed by the CTS definition of Secondary Containment
., Integrity. Since there are accepted safe actions for loss of a SGT subsystem function, allowing these actions will continue to i
l FERMI - UNIT 2 6 REVISION 6 05/28/99l l
I DISCUSSION OF CHANGES ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION ensure continued safe operation. Therefore, this less restrictive l [f' change will have a negligible impact on safety. <1 RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.3.6.2 consistent with the BWR STS, NUREG 1433. Rev. 1. - s Y s o 4 FERMI UNIT 2 REVISION 6 05/28/99 7 l( )
Secondary Containment Isolation Instrumentation B 3.3.6.2 BASES (continued) APPLICABLE The isolation signals generated by the secondary containment SAFETY ANALYSES, isolation instrumentation are implicitly assumed in the LCO, and safety analyses of References I and 2 to initiate closure APPLICABILITY of valves and start the SGT System to limit offsite doses. Refer to LCO 3.6.4.2, " Secondary Containment Isolation Valves (SCIVs)," and LCO 3.6.4.3, " Standby Gas Treatment (SGT) System," Applicable Safety Analyses Bases for more G detail of the safety analyses. The secondary containment isolation instrumentation
' M "".C .";1 icy St;t r nt. Certain 10 g 5t M g p I h atisfies Criterion 3 4o instrumentation Functions are retained for other reasons and are described below in the individual Functions discussion.
The OPERABILITY of the secondary containment isolation instrumentation is dependent on the OPERABILITY of the
~ individual instrumentation channel Functions. Each function must have the required number of OPERABLE channels with their setpoints set within the specified Allowable Values, as shown in Table 3.3.6.2-1. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. A channel is inoperable if its actual trip setpoin
,.6....,t is not
_..a .u. within its required.. Allowable Value.y;; ,
;;;g 0f,l a - . .- -,--
. ,- n . s..f. 7 4 u g u . 4 g.
Od Allowable Values are specified for each4 unction spec fied i in the Table, Nominal trip setpoints are specified in the f1 setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable g Wiwe,tw successhc Value between CHANNEL CALIBRATIONS b Operation with a trip setpoint sen mm dive Inan the nominal trip setpoint, Vui8cAff5M cbf but within its Allowable Value, is acceptable.
"N Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g., reactor vessel water level), and when the measured output value of the process device (e.g. parameter
, trip unit) exceeds changesthe setpoint, state. the associated The analytic limits are derived from the limiting values of the process parameters obtained from the safety analysis. The Allowable Values are derived from the analytic limits, corrected for calibration, process, and some of the instrument errors.
The trip setpoints are then determined accounting for the (continued) BWR/4 STS B 3.3-186 Rev 1, 04/07/95 l l I Rea
l l I Secondary Containment Isolation Instrumentation l B 3.3.6.2 BASES SURVEILLANCE SR 3.3.6.2.1 (continued) REQUIREMENTS channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of-excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit. l The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of , channel status during normal operational use of the displays associated with channels required by the LCO. SR 3.3.6.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required i MTF 'lo f channel to ensure that the entire channel will perform the intended function.f 3 IQSE12T Ac Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of 92 days is based on the reliability analysis of References and . 4 6 SR 3.3.6.2.3 u su c p;3 -
-- g w =Wprovides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.6.2-1. If the trip setting is discovered to be less conservative than (continued)
BWR/4 STS B 3.3-194 Rev 1, 04/07/95 g Re4 .
Secondary Containment Isolation Instrumentation B 3.3.6.2 INSERT: TSTF-205 INSERT A z i A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL _ TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. l l l i l l FERMI - UNIT 2 B 3.3 194 (Indert) REVISION 6. 05/28/99l i
i JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION NON-BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis:. including design features, existing license requirements and commitments. Refer to CTS Discussion Of Changes to the related requirement for a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. Additional rewording. reformatting. and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for ' additional detail. P.4 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES -C.1 TSTF 205: NRC approved change to'NUREG-1433. l 6 FERMI UNIT 2 1 REVISION 6 05/28/99l
l NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION i TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.3.6.2 "L.2" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by i l 10 CFR 50.92 and has determined that the proposed change does not involve a i significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change will provides an option to the requirement to operate the SGT System to declare the associated SGT subsystem inoperable. This Required Action is not considered an initiator for any accident previously analyzed. Therefore, this change does not 3i significantly increase the probability of'a previously analyzed I accident. Declaring the SGTS ensures appropriate Actions are taken in accordance with ITS 3.6.4.3. Therefore, this change does not increase i the consequences of a previously analyzed accident. i
- 2. Does the change create the possibility of a new or different kind of I accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant operation. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated. FERMI - UNIT 2 3 REVISION 6. 05/28/99l
i I f NO SIGNIFICANT HAZARDS EVALUATION , ITS: SECTION 3.3.6.2 SECONDARY CONTAINMENT ISOLATION INSTRUMENTATION I TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.3.6.2 "L.2" Labeled Comments / Discussions)
- 3. Does this change involve a significant reduction in a margin of safety? I The proposed change does not involve a significant reduction in a margin ,y) l of safety because declaring the SGTS inoperable ensures appropriate i Actions are taken in accordance with 3.6.4.3. 4
}
l s-FERMI UNIT 2 4 REVISION 6. 05/28/99l t
l' LLS Instrumentation l 3.3.6.3 3.3 INSTRUMENTATION l l 3.3.6.3 Low Low Set (LLS) Instrumentation q LC0 3.3.6.3 The LLS valve instrumentation for each Function in i Table 3.3.6.3 1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED, ACTION COMPLETION TIME A. One LLS valve A.1 Restore channel (s) to 14 days inoperable due to OPERABLE status. inoperable channel (s). l l B. - NOTE--- - B.1 Restore one tailpipe 24 hours Separate Condition pressure switch for entry is allowed for 11 OPERABLE SRVs, each S/RV. . including one in each Division for an OPERABLE SRV in the One or more Function 3 lowest setpoint channel (s) inoperable, group, to OPERABLE g status. AN_D n
, ............N0TE -- -
LCO 3.0.4 is not applicable. B.2 Restore both tailpipe Prior to 3 pressure switches for entering MODE 2 11 OPERABLE SRVs, or 3 from MODE 4 including 4 of 5 OPERABLE SRVs with the lowest relief setpoints, to OPERABLE status. (continued) l FERMI UNIT 2 3.3 65 Revision 6. 05/28/99
I I l l LLS Instrumentation 3.3.6.3 ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion l Time of Condition A MQ or B not met. C.2 .Be in MODE 4. 36 hours QB Two LLS valves , inoperable due to
)
l inoperable channels. ' l
~
SURVEILLANCE REQUIREMENTS
.....................................N0TE - - - - -- - - -- l Refer to Table 3.3.6.31 to determine which SRs apply for each Function.
l SURVEILLANCE FREQUENCY
- SR 3.3.6.3.1 Perform CHANNEL FUNCTIONAL TEST. 31 days Tl SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST for 31 days portion of the channel outside primary containment.
SR 3.3.6.3.3 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.3.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months l l FERMI - UNIT 2 3.3 66 Revision 6. 05/28/99
1 LLS Instrumentation 3.3.6.3 l I Table 3 3.6.31 (page 1 of 1) l Low low Set Instrumentation 1 REQUIRED CHANNELS PER SURVEILLANCE ALLOWABLE FUNCTION FUNCTION REQUIREHENTS VALUE
- 1. Reactor Steam Dme Pressure- High 1 per LLS valve SR 3.3.6.3.1 s 1113 psig SR 3.3.6.3.3 SR 3.3.6.3.4
- 2. Low-Low Set Pressure Setpoints 2 per LLS valve SR 3.3 6.3.1 Low:
SR 3 3.6.3.3 Open s 1037 psig SR 3.3.6.3.4 Close (a) High: Open s 1067 psig q\ Close (a) l 3. Tailpipe Pressure Switch 2 per SRV SR 3.3.6.3.2 a 25 psig and SR 3.3.6.3.3 s 35 psig SR 3.3.6.3.4 (a) = 100 psi below actual opening setpoint. \ l l l i \ 1 1 l l l l l l l l
- l FERMI UNIT 2 3.3 67 Revision 6 05/28/99
LLS Instrumentation B 3.3.6.3 BASES BACKGROUND (continued) switch coincident with a high reactor pressure signal. Each
-division receives tailpi>e arming signals from tailpipe pressure switches on eac1 of the 15 SRVs: eight tailpipe pressure switches are assigned to Division I and seven are assigned to Division II. Isolation relays are used to convey status between divisions such that both divisions logics receive status input from all 15 SRV tailpipes. Each LLS division receives the reactor pressure arming signal hl from one reactor-pressure transmitter and trip unit assigned to that division. These arming signals seal in until manually reset.
After arming, opening of each LLS valve is by a two-out of two logic from two reactor pressure transmitters and two trip units set to trip at the required LLS opening setpoint. The LLS valve recloses when reactor pressure has decreased to the reclose setpoint of one of the two trip units used to open the. valve (one out of two reset logic). This logic arrangement prevents single instrument failures from precluding the LLS SRV function. The channels include electronic equipment (e.g., trip units) that compares measured input signals with pre established setpoints. When the set >oint is. exceeded, the channel output relay actuates, which tien outputs a LLS initiation signal to the initiation logic. APPLICABLE The LLS instrumentation and logic function ensures that the SAFETY ANALYSES containment loads remain within the primary containment design basis (Ref. 2). The LLS instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 The LC0 requires OPERABILITY of sufficient LLS instrumentation channels to ensure successfully accomplishing the LLS function assuming any single instrumentation channel failure within the LLS logic. Therefore, the OPERABILITY of the LLS instrumentation is dependent on the OPERABILITY of the instrumentation channel Function specified in Table 3.3.6.31. Each Function must have a required number of OPERABLE channels, with their / l FERMI UNIT 2 B 3.3.6.3-2 Revision 6 05/28/99
I LLS Instrumentation I B 3.3.6.3 BASES APPLICABILITY The LLS instrumentation is recuired to be OPERABLE in MODES 1, 2, and 3 since consicerable energy is in the nuclear system and the SRVs may be needed to provide pressure relief. If the SRVs are needed, then the LLS function is required to ensure that the primary containment design basis is maintained. In MODES 4 and 5. the reactor pressure is low enough that the overpressure limit cannot be a>proached by assumed operational transients or accidents. T1us. LLS instrumentaticn and associated pressure relief is not required. ACTIONS fu_L The failure of any reactor steam dome pressure instrument channel to provide the arming. SRV opening and closing pressure set >oints for an individual LLS valve does not affect the a)ility of the other LLS SRV to perform its LLS function. A LLS valve is OPERABLE if the associated logic has one Function 1 channel, two Function 2 channels, and at least three Function 3 channels OPERABLE. Therefore 14 days is provided to restore the inoperable channel (s) to OPERABLE status (Required Action A.1). If the inoperable channel (s) cannot be restored to OPERABLE status within the allowable out of service time. Condition C must be entered and its Required Action taken. The Required Actions do not
, allow placing the channel in trip since this action could result in an instrumented LLS valve actuation. The 14 day Completion Time is considered a>propriate because of the redundancy in the design (two L_S valves are provided and any one LLS valve can perform the LLS function) and the very low probability of multiple LLS instrumentation channel failures, which renders the remaining LLS SRV inoperable, occurring together with an event requiring the LLS function during the 14 day Completion Time.
l B.1 and BJ l Although the LLS circuitry is designed so that operation of a single tailpi)e pressure switch will result in arming both LLS logics: eac1 tailpipe pressure switch provides an input to both LLS logics. Since any overpressure event will normally open at least five SRVs and actuate their associated pressure switch inputs, the LLS logic and instrumentation remains capable of performing its safety
, function even with several SRV tailpipe pressure switch l FERMI - UNIT 2 B 3.3.6.3 -4 Revision 6. 05/'8/99
LLS Instrumentation B 3.3.6.3 BASES ACTIONS (continued) int,trument channels inoperable. Therefore, it is acceptable for plant operation to continue provided that within 24 hours, per Required Action B.1. verification and/or restoration is made to ensure at least: a) one tailpipe pressure switch in each Division OPERABLE on one OPERABLE SRV in the lowest SRV setpoint group: and b) at least 11 OPERABLE SRVs have at least one OPERABLE tailpipe pressure switch. Therefore, it is acceptable for plant operation to i continue even with only one tailpi)e pressure switch j g OPERABLE on each S/RV. However, t11s is only acceptable i provided each LLS valve is OPERABLE. (Refer to Required Action A.1 and C.1 Bases). 4 Required Action B.2 requires restoration of both tailpipe pressure switches on a 11 OPERABLE SRVs. including 4 SRVs , out of the 5 lowest relief setpoint OPERABLE SRVs. to ! OPERABLE status, prior to entering MODE 2 or 3 from MODE 4. j This will ensure that sufficient switches are OPERABLE at i the beginning of a reactor startup (this is because the j switches are not accessible during plant operation). The Required Actions do not allow placing the channel in trip since this action could result in an inadvertent LLS valve actuation. As noted. LC0 3.0.4 is not applicable thus . allowing entry into MODE 1 or 2 from MODE 2 or 3 with l inoperable channels. This allowance is needed since the i channels only have to be repaired prior to entering MODE 2
. or MODE 3 from MODE 4.
A Note has been provided in the Condition to modify the ' Required Actions and Completion Times conventions related to LLS Function 3 channels. Section 1.3 Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within (f) limits, will not result in separate entry into the ( Condition. Section 1.3 also specifies that Recuired Actions 5 of the Condition continue to ap)ly for each adcitional failure, with Completion Times )ased on initial entry into the Condition. However, the Required Actions for inoperable LLS Function 3 channels provide appropriate compensatory measures for separate inoperable Condition entry for each S/RV with inoperable tailpipe pressure switches. l FERMI UNIT 2 B 3.3.6.3 - 5 Revision 6 05/28/99
l h LLS Instrumentation B 3.3.6.3 BASES ACTIONS (continued) L1 If any Required Action and associated Completion Time of Conditions A or B are not met, or two LLS valves are inoperable due to inoperable channels, the LLS valves may be incapable of performing their intended function. Therefore, the plant must be placed in a MODE or other specified condition ir. which the LC0 does not apply. This is done by placing the plant in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LLS REQUIREMENTS instrumentation Function are located in the SRs column of Table 3.3.6.3 1. SR 3.3.6.3.1 and SR 3.3.6.3.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required , contact (s) of a channel relay may be performed by the I verification of. the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all
, of the other required con. tacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjust.71ent shall be consistent with the assumptions of the current plant specific setpoint methodology.
The Frequency of 31 days is reasonable, based on operating experience and on other indications that ensure pro)er functioning between CHANNEL FUNCTIONAL TESTS. Furtiermore. o)erating experience shows that failure of more than one 7 clannel in a given 31 day period is a rare event. E A portion of the SRV tailpipe pressure switch instrument T channels are located inside the primary containment. The allowance for SR 3.3.6.3.2 to only perform the CHANNEL FUNCTIONAL TEST for portions of the channel outside of the primary containment is based on the location of these instruments and ALARA considerations and the requirement for ./ l FERMI UNIT 2 83.3.6.3-6 Revision 6, 05/28/99
LLS Instrumentation B 3.3.6.3 BASES SURVEILLANCE REQUIREMENTS (continued) a complete CHANNEL CALIBRATION (SR 3.3.6.3.3) and LSFT (SR 3.3.6.3.4) every 18 months. SR 3.3.6.3.3 CHANNEL CALIBRATION is a complete check of the instrument loop and sensor. This test verifies the channel responds to the measured parameter within the necessary range and ; accuracy. CF.ANNEL CALIBRATION leaves the channel adjusted ~ to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
~
The Frequency of once every 18 months for SR 3.3.6.3.3 is based on the assumption of a = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. SR 3.3.6.3.4 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specified channel. The system functional testing performed in LCO 3.6.1.6, " Low Low Set (LLS) Safety / Relief Valves (SRVs)." for SRVs overlaps this test to testing of the assumed safety function. provide complete The Frequency of once every 18 mon',hs for SR 3.3.6.3.4 is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually p;ss the Surveillance when performed at the 18 month Frequency. l REFERENCES 1. UFSAR. Figure 7.3-13. Tl 2. UFSAR. Section 5.2.2. l FERMI UNIT 2 B 3.3.6.3 - 7 Revision 6. 05/28/99
DISCUSSION OF CHANGES ITS: SECTION 3.3.6.3 - LLS INSTRUMENTATION ADMINISTRATIVE A.1 In the conversion of the Femi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes. reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433, Rev. 1. A.2 ITS 3.3.6.3 SR Note is included as a clarification of the ITS presentation of SRs: specifying that ITS Table 3.3.6.31 be referred to determine which SRs apply for each Function. As such, its inclusion is an administrative presentation preference. i TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.4.2.2 requires Operability, Surveillances, and Action limitations for the LLS reactor pressure actuation instrumentation. The " arming" instrumentation for the LLS Function (reactor pressure and SRV tail pipe pressure) is not addressed in the CTS requirements for the LLS Function. ITS Table 3.3.6.3 includes Function 1 and 3 for these " arming" Functions. These additional requirements include Operability, Surveillance, and Action requirements. In the case of the SRV tail nipe arming Function, the ITS 3.3.6.3 Action B is provided, and u based on maintaining a high degree of reliability for the supporting function, while minimizing the potential for any unnecessary forced shutdown. Since any one of 30 tail-pipe pressure switches will suffice to arm both LLS valves, the actions ( allow for continued operation with multiple inoperable tail pipe pressure channels. The Actions include requirements to ensure that within 24 hours: a) a minimum of one tail-pipe pressure ' g channel in each division associated w1th 1 of the 5 lowest set i Operable SRVs (to assure arming in the event just the lowest set SRVs lift); and b) at least 11 Operable SRVs have at least 1 Operable tail pipe switch. Additionally, Required Action B.2 is provided to ensure a significant number (at least 11 of 15) have S both tail pipe pressure switches Operable, including 4 of the 5 lowest' set SRVs, on any reactor startup from Mode 4. FERMI - UNIT 2 1 REVISION 6. 05/28/99l
1 DISCUSSION OF CHANGES ITS: SECTION 3.3.6.3 - LLS INSTRUMENTATION 1 TECHNICAL CHANGES LESS RESTRICTIVE
" Generic" l LA.1 CTS 3.4.2.2 details the LLS valves by their plant specific designator. These details are not presented in ITS 3.3.6.3: but l are relocated to the UFSAR. Changes to the UFSAR are controlled in accordance with 10 CFR 50.59. This detail is not required in the ITS to provide adequate protection of the public health and safety since these details have no impact on plant operation, and LLS Operability remains required by the ITS.
LA.2 CTS 3.4.2.2 requires that LLS actuation setpoints be within Trip Setpoint values. However. Actions only apply if the allowable value is Txceeded. ITS 3.3.6.3 requires only that instrumentation l setpoints be within the allowable value. Trip setpoints reflect operational details while the allowable value reflects channel % l Operability. Requirements for trip setpoints are. relocated to the l Technical Requirements Manual (TRM), which requires revisions be I controlled by 10 CFR 50.59. The trip setpoint is established d i based on a combination of instrument design factors, environmental 4 factors, and the allowable value (which is what is conservatively g derived from the value assumed in the safety analyses). Therefore, these details can be adequately defined and controlled in tha TRM. This relocation continues to provide adequate ' protection of the public health and safety since the requirement
'for instrument channel Operability and the allowable value setpoint continues to be required by the Technical Specifications. \
! . TECHNICAL CHANGE!. , __LESS RESTRICTIVE
" Specific" None RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 21.6.3 consistent with the BWR STS. ~
NUREG 1433. Rev. 1. FERMI UNIT 2 2 REVISION 6 05/28/99l
LLS Instrumentation 3.3.6.3 3.3 INSTRUMENTATION 3.3.6.3 Low-Low Set (LLS) Instrumentation LC0 3.3.6.3 The LLS valve instrumentation for each Function in Teble 3.3.6.3 1 shall be OPERAB hsMa+ teosf m 0 3l +di pip' F<554 5sih . 2.4 hovr3
@ T*\ For Il D99%66 W Us>
~ kc1udir$. % eatp 4 e PusssN sWHch ik
- A APPLICABILITY: MODES 1. 2. and 3.
civisim h w OPEM6tf O
,L ACTIONS [ sRv)ok % tewesi[o M78[4 k 4 k CONDITION M T N TIME l
~
fREQUIREDACTION I4 days A. One LLS valve A.1 Restore channel (s) to 2ihers7 hcW h l inoperable due to ' OPERABLE status. inoperable cnannel(s). (% M.1) iVB. One or more :;afety/ B.1 c -----NOTE---- - - & // opeE4ets 5 % \4
, relief valves (S/RVs) _ LC0 3.0.4 is not includmq 4 *f f.
with on Function 3 MD applicable. g pgg gg g, g;4 channel noperable, & - ---- --- --- on et lowest-(Wd of nturc 6.L Restore a 3e Prior to A f6@d*H pressure switcles o entering MODE 2' - OPERABLE status, or 3 from MODE 4 [bc M,1)
.........N0TE ;14 days
% Separate Condition C Ret re one ta' pipe pr ssure swit to entry is allowed for 0 ERABLE sta us.
l I
' each S/RV.
- g. . . . . . . . . . .x. . . . . . .J 0 or mor S/RVs th o Funct on 3 hannel inopera e.
(continued) BWR/4 STS 3.3 67 Rev 1. 04/07/95
1 LLS Instrumentation 3.3.6.3 ACTIONS (continued)
<(crs)
CONDITION REQUIRED ACTION CONPLETION TIME E Required Action and 1 I Dec1 e the associated Completion as ciated LLS Immedja(ely] !Acb b -
"ine of Condition Ay ( ve(s) inop able.] \ 4, b /
[ ops S. 12. hows E / AND { pa due t (1 bb ^ N00E A' 3G inoperable channels. e ^ ' - 3 l i' SURVEILLANCE REQUIREMENTS
---------NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
K Refer to Table 3.3.6.3-1 to determine which SRs apply for each Function. hc A.h
. When channel is placed n an inoperable atus solely for performa eh p,Q re red Surveillances entry into assoc ted Conditions and Requi d ions may be delay for up to 6 hou provided the associate unction sintains tts init Ltion capabilit h M SURVEILLANCE FREQUENCY SR ' .3.6.3.1 P rform CHANNEL CH . 12 hours SR 3.3.6.3.2 Perform CHANNEL FUNCTIONAL TEST for days / \
portion of the channel outside primary 5AC M'I / containment. (continued) ( MON 6 A 3'3 g'31ff *h g @
\
BWR/4 STS 3.3-68 Rev I, 04/07/95 I
e
)
i LLS Instrumentation 3.3.6.3 n febte 3.3.6.3 1 (page 1 of 1) {g Low-Law set Instrumentetten w-RieUIRED l CNANNEL: PER SURVEILLANCE ALLOWASLE ! FUNCTION RAICTION RieUIREE NTS VALLE l 1. Reector steen Deee Preneure-Nish 1 per LLS - ia ;.5.1.5. '? - s pois I ' wet se 3.3.6.3.6* j p OC y g pet 3.3.6.3.93-3R 3.3.6.3.& qj ; l
; 3.0.1.!.' i
- 2. Lew-Leu set Pressure setpointe g per LLs ? ? ? 1 ?.': Leus welwe et 3.3.6.3. l Open 1037 s N psie h N' N p 3.3.6.3.1$ 3 Ctese -'- ' I sa 3.3.6.3.6 4 f E .3.e.;.7 -- medlue- 2 (10252 pop
$ (8753 as fun-Night Open s ( psip
_ Clase _ gig Night f0 67 p Open s pelo y
- 3. Teltpipe Pressure switch 2.Per SRV %~q-
? 5.5.i.! .P - t 400P pois and
- 2 y .T.; st 3.3.6.3 s psis C
p4 i
- = 3.3.6.3 DOCM.lf yst 3.3.6.3 fA D BWR/4 STS 3.3-70 Rev 1, 04/07/95 s
g'
E I LLS Instrumentation l l B 3.3.6.3 I l l Insert B 3.3.6.3 5 The LLS relief mode functions to mitigate containment loads caused by reopenings of an SRV by reducing the fregrncy of subsequer.t SRV actuations following the initial SRV opening. The steam discharge frcm the SRVs cause high frequency containment loads as well as thrust loads on the SRV discharge piping. The LLS allows time for the water leg that forms in the SRV discharge piping following SRV closure (from discharge piping residual steam condensation) to clear. Eliminating the water leg reduces the loading from the subsequent SRV actuations to acceptable levels. In addition, since subsequent SRV actuations will all involve the LLS SRVs the LLS logic acts to reduce the rumber of challenges to the SRVs (by eliminating isolation cycling of the SRVs during some transients) and serves to dampen reactor pressure surges. Reducing the number of SRV challenges acts to reduce the probability of a stuck open relief valve event. Insert B 3.3.6.3-1
~
The LLS instrume. ' tion iogic is arranged in two divisions with logic channels A and C'in one division and logic channels B and D in the other division (Ref.1). Each LLS division controls one LLS valve. The LLS division will not actuate their associated LLS valve at their LLS set points until the arming portion of the associated LLS logic is satisfied. Arming occurs when any one of the 15 SRVs opens as indicated by a signal from one SRV tailpipe pressure switch coincident with a high reactor pressure signal. Each division receives tailpipe aang signals from tailpipe pressure switches on each of the 15 SRVs: eight tailpipe pressure switches are assigned to Division I and seven are assigned to Division II. Isolation relays are used to convey status between divisions such that both divisions logics receive status input from all 15 SRV tailpipes. Each LLS division receives the reactor pressure arming signal from one lh reactor presrure transmitter and trip unit assigned to that divisier. Thera arming signals seal in until manually reset. FERMI UNIT 2 Page B 3.3 198 (Insert) REVISION 6 05/28/99l
LLS Instrumentation B 3.3.6.3 BASES l APPLICABILITY approached by assumed operational transients or accidents. (continued) Thus, LLS instrumentation and associated pressure relief is not required. ACTIONS Reviewer' Note: Certain LCD Completion Time ed on K approved top .. the times, the li rts. In censee to use theCompletionTimesas/' r s aff Safety Evalua ng =+ Q the L1 The failure of any reactor steam dome pressure instrument channel to provide the anning, S/RV opening and closing
- pressure setpoints for an individual LLS valve does not l
affect the ability of the other LLS S/RVg to perbre A 4 ppf _LLS function. logic, (;.;.. A!~LLS
*: valve is OPERABLE ff the associated
.*.), has one Function 1 channel, two Function z channels, andvthree Function 3 channels OPERABLE.
WO 5 Therefore.A 0 f.;,.; is provided to restore'the inoperable channel (s) to OPERABLE status (Required Action A.1). If the inoperable channel (s) cannot be restored to OPERABLE s atus
?.3 within the allowable out of service time, Condition aus C be entered and its Required Action taken. The Required Actions do not allow placing the channel in trip since this i
action M. Thef could result in an instrumented LLS valve actuation. t Completion Time is considered appropriate fue 47 because of ti'e redundancy in the design (fouFLL5 valve: are provided and any one LLS valve can perform the LLS function) and the very low
~
channel failures, probability of multiple LLS instrumentation which render the remaining LLS S/RVp'. inoperable, occurring together with an event requiring the LLS function during the : Completion Time. h
-??2"yM:
b: = % :h t*:: = ': :.h ..;D; M . : ... tb d itit: 1
- f ."d ;.ar.;; 3.
u ad A2- v
.Althoug a single tail
. e LLS circuitry is designed so that operation of k LLS logics ' pipe ^- pressure switch
--- ' " ' "-' ';,sf will each result tailin arming both
'3
. pressure switch provides : dire;' input to ::' pipe --- LLS (continued)
BWR/4 STS B 3.3-201 Rev 1, 04/07/95 Rw 6
I 1 LLS Instrumentation B 3.3.6.3
\
BASES , l ACTIONS R a d 6.2_) j L1 F(continiied) _
.g.,LoggA). Sin each LLS logic normally T rec es at 1 6t five S pressurp switch nputs (and also I other S r logic in the gg jr elves t name di ins ion by ntati signals W th arming s ains e
), LS logic a eo forming it p3 bg f): ction i y S/RV t er ure switch
.rhannel. amae 4 ag AlapTherefore, it is acceptable for ruman+ ety ]
" plant operation to continue with only one ta11 pipe pressure O
- 7. >
l q switch OPERABLE on each S/RV. However, this is only acceptable provided each LLS valve is OPERABLE. - (Refer to 1 Required Action A. d ases). %q lNS EY T l _ Required Action _B.2 requires restoration of alipipe l 83.3.G 3-3b}MOD:. pressure switchesMo OPEEABLE status prior to entering 2 or 3 from MODE 4)t,gDensure that-eM switches are = t- _ OPE MBLli at the Deginning of a reactor startup (this is su ccn because the switches are not accessible during plant operation). The Required Actions do not allow placing the [ ' This @,ll channel in trip since this action could res'. tit in (LL A valve actuation. As noted, .C0 3.0.4 is not applicab ' i Inus allowing entry into rioDi 11from MODE 2fWith inoperable 4 channels. in n aisowance is neeced since the nnels on1 or 3 have to be repaired prior to entering MODE 2 E or MODE 4. . Vat; irn u .i .;;.1; y, ,a ,; , ,o g , , g : age _ :
'. .eaa
. 2 .'..... th; ".:; !-^d Act S- & = r.;t liv.- (
4
.un'i=tt M ep:--t % j
_N ( ' A fai of two press witch channels Matedwith on V ta result in the j e s of the LLS nction (i.e. iple actuation the S/RV yould go i j undetected he LL ic). ever, the S organtz n groups .nd, g an eventvgfou/RVs ps of 5/RVsare , init y open (setpoln re same ettings for a total, i 1 S/RVs in three cups). The re, it would ery unlikely that a e S/RV wou er red to I the i LLS logic. T fore, it is ceptable to days to l restore o ressure switc of the associa to i OPERAB' status (Required' Action C.1 wever, th a11%1e out of sery4fe time is on1). cceptable provide [ e c'h LLS is OPERABLE (Refer to Re red Action A.1 and D.1 ases). If one inoperable tailpipe pressure switch cannot (continued) BWR/4 STS B 0.3-202 Rev 1, 04/07/95 l l
=
Rek \
l LLS Instrumentation i B 3.3.6.3 i l Insert B 3.3.6.3 3a l i
... logics. Since any overpressure event will j normally open at least five SRVs and actuate their associated pressure switch inputs, the LLS logic and instrumentation remains capable of performing its safety function even with several SRV tailpipe pressure switen instrument channels l inoperable. Therefore, it is acceptable for plant operation to continue provided that within 24 hours, per Required Action B.1, verification and/or restoration is made to ensure q at least: a) one tailpipe pressure switch in each division i OPERABLE on one OPERABLE SRV in the lowest SRV setpoint group: and at least 11 SRVs have at least one OPERABLE (
tailpipe pressure switch. . [ l l 1 Insert B 3.3.6.3 3b ; 7 !
. on 211 SRVs including 4 SRVs out of the 5 lowest relief setpoint OPERABLE SRVs
]
l l l l l i
.w FERMI UNIT 2 Page B 3.3 202 (Insert) REVISION 6 05/28/99l
LLS Instru~entation 6 3.3.6.3 BASES ACTIONS ~ ontinued) q J be restore OPERABLE st s within the allowable out of service me, Condition must be entered and its Required Acti taken. The tred Actions do t allow placing the ch nels in trip 34 ce this action c result in a LLS - y lve actuatio V i i A Note has been provided in the Condition to modify the Required Actions and Completion Times conventions related to l f,h LLS Function 3 channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems components, or variables expressed in the Condition, discove, red to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional h failure, with Completion Times based en initial entry into *% the Condition. However, the Required Actions for inoperable T LLS Function 3 channels provide appropriate compensatory measures for separate inoperable Condition entry for each S/RV with inoperable tailpipe pressure swi}ches. L 3 If any Required Actio and associated Completion Time of Conditions A,2, or 'are.not met, or two ee-moet LLS valves P,2J % are inoperable due to inoperable channels, the LLS valves may be incapable of performing their intended function. Therefore,Eii ass aateo LL5 va must De _ sarea - gg7, rinope im fely. A - alve is LE if th as ated c (e ic A) ha e function
$ %,34,3-h o Fun n 2 chan d.g. and the unction 3 els el, j\
v7uCPE _ . 7 SURVEILLANCE Reviewer's Note: Ceds ce4aTED on approved REQUIREMENTS topical reports. I v Tm a 'e Frequen , icensee must justify the Frequenc red by the staff SER for the topical report. % As noted at the beginning of the SRs, the SRs for each LLS instrumentation Function are located in the SRs column of Table 3.3.6.3-1. i - (continued) BWR/4 STS. B 3.3-203 Rev 1, 04/07/95 1
LLS Instrumentation B 3.3.6.3 BASES U r4D SURVEILLANC SR 3.3.6.I.L SR 3.3.6.3.M. (Eich % 0 . 0 . 0 . ^ . .;
~~
REQUIREMENTS Y-m (continued A CHANNEL FUNCTIONAL TEST is performed on each required 1 channel te insure that the entire channel will perform the
/TIFZos-intended function > Any setpoint adjustment shall be @
/ AlSETLT k^
' consistent with the assumptions of the current plant
[ lQ$674T specific setpoint methodology. ( 6 3O 3 'Io M pepi 6.y, F,.yuwm., gi ,ud .[th; r:l/;bi'ity % sis " h
,..... , . - , ,y A portion of the S/RV -
E 0^gi FgM g channels are located inside ailpipepressureswitchtnstrument@(m_s-Q the primary containment. The 41sta for SR 3.3.6.3. , f. ., . .y. . . .. .. .. ,.._. _ _ , . . . CHAppa. FUNCDONAL. W ::t:rin; "^^ ? .;r ..; :h ::h:f I:d ::t ' ?? h:27.3 D T- @ p r # r8s l>[ th4. 't;; ::tr; i: ::f: ' t: pr'rry :::tti-----+ d:- s based on the location of these instrumentsfALARA considerationsy'[and) Ckand DUI6& dIO '
- - : = =:::--
caygtqnnuet _;d-'is muyu w nd;... G.yo t,',e.dC=;'-ti=
',; tin " n:7:and PtitiM;i : fka rw/ 4-
' 4 (ampc4<. CH4u cA u aR An o*J P.l/ se .: ;.: - 6e3.%.3 3) 4A LSpr 6 a. 5 3 6.%4) s ' 4N4ry 1il e nns.
-The ca bration o ... i t ravi ** = ^=9 :. .he ;;tuei; trip etpoints. The e nnel must be declar inoperable if the rip setting is d covered to be less nservative than j t Allowable Value. If the trip setting s discovered to less conservati than accounted for the appropriate setpoint methodel y, but is not beyond the Allowable Valu ,
the channel perf raance is still withi the requirements the plant safe analysis. Under the e conditions, the setpoint must readjusted to be e al to or more conservative han the setting acco ted for in the appropriate etpoint methodology. The Frequency of every 92 days fo SR 3.3.6.3.5 is base on the reliabili y tanalysis f Reference A ' SR 3.3.6.3.h CHANNEL CALIBRATION is a complete check of the instrument loop and sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between succes:;ive (continued) BWR/4 STS B 3.3-205 Rev 1, 04/07/95 g a
1 l LLS Instrumentation B 3.3.6.3 l l INSERT: TSTF 205 INSERT A l A successful test of the required contact (s) of a channel relay may
. be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL l FUNCTIONAL TEST of a relay. This is acceptable because all of the l other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions.
Insert B 3.3.6.3 6 The Frequency of 31 days is reasonable, based on operating experience and on other indications that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furi.harmore. operating experience shows that failures of more than one channel in a given , 31 tiay period is a rare event. - ' i FERMI - UNIT 2 Page B'3.3-205 (Insert) REVISION 6, 05/28/99l
I 1 l LLS Instrumentation l B 3.3.6.3 BASES SURVEILLANCE SR 3.3.6.3. (continued) REQUIREMENTS calibrations consistent with the plant specific satpoint methodology. The Frequency of once avery 18 months for SR 3.3.6.3.% is-Q based on the assumption af ajg18 month calibration interval in the detemination of the magnitude of equipment drift in ! the setpoint analysis. SR 3.3.6.3.Y The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the l OPERABILITY of the required actuation logic for a specified channel. The system functional testing performed in 4
- 7. n/- : LC^ 3.'.3, *hf:ty/Sliaf Ym::( /:"!:)* rd LCO 3.6.1. ,
" Low-Low Set (LLS) Safety / Relief Valves (S/RVs)," for S/RVs overlaps this test to provide complete testing of the assumed safety function.
The Frequency of once every 18 months for SR 3.3.6.3.T is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these wmponents usually pass the Surveillance when performed at the 18 month Frequency, m-= REFERENCES 1. UFSAR, Figure & 7.3- 13
- 2. U FSAR, Section N 6,1,2 s
. GE -770 Inte als and
" Bases lowed Ou Changes Survei f-Service imes fo anceTest}
\ T Select Instru ebruar 1991.
ation Te ical Spe ficati s," *g h BWR/4 STS B 3.3-206 Rev 1, 04/07/95
JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 i ITS: SECTION 3.3.6.3 LLS INSTRUMENTATION l 5 RON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current ! licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting, 9 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 l ITS as presented. ! P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. )
~
l P.3 Bases changes are made to reflect changes made to the Specification. Refer to the Specification, and associated JFD if applicable, for y additional detail, j P.4 ISTS 3.3.6.3 for LLS instrumentation reflects the design of the BWR/4 lead plant. and implementation of GENE 770. The Fermi 2 LLS design and existing CTS requirements result in differing requirements, which are discussed in CTS DOC ~M.1". The ITS presentation also reflects the fact that Fermi 2 has not performed the necessary evaluations to adopt the flexibility of GENE 770 for Functions 1 and 2 of the LLS instrumentation (therefore, CTS test Frequencies are retained). However, for Function 3, since no' existing CTS surveillance Frequency is specified, the typical CTS 31 day Frequency is applied for the l 3 portion of the SRV tail pipe pressure switch channe'is located outside ! of containment. For portions of the SRV tail pipe pressure switch channels located inside containment, the 18 month Frequency for the j Channel Calibration and LSFT are deemed to be sufficient. ! l P.5 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification ;
" split" criteria found in 10 CFR 50.36(c)(2)(ii).
GENERIC CHANGES i C.1 TSTF 205: NRC approved change to NUREG 1433. FERMI - UNIT 2 1 REVISION 6, 05/28/99l
l
}
1 i CREF System Instrumentation 3.3.7.1 3.3 INSTRUMENTATION 3.3.7.1 Control Room Emergency Filtration (CREF) System Instrumentation
. v'0 3.3.7.1 The CREF System instrumentation for each Function in Table 3.3.7.1 1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.7.1-1. ACTIONS
.................................... NOTE-- -- - ---- - ----- -
Separate Condition entry is allowed for each channel. CONDITION REQUIRED ACTION . COMPLETION TIME l l l A. One or more required A.1 Enter the Condition Immediately channels inoperable, referenced in Table 3.3.7.1 1 for the channel. B. As required by B.1 Declare associated I hour from sq Recuired Action A.1 CREF subsystem discovery of anc referenced in inoperable. loss of CREF Table 3.3.7.1 1. initiation capability in
'f both trip Systems
- 4. 80 (g B.2 Place channel in 24 hours trip.
(continued) J l FERMI UNIT 2 3.3 68 Revision 6 05/28/99
r: CREF System Instrumentation 3.3.7.1 l ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME M) C. As required by C.1 Declare associated I hour from l
~-L Recuired Action A.1 CREF subsystem discovery of 4 anc referenced in Table 3.3.7.1 1.
inoperable. loss of CREF initiation l capability in both trip systems b!LD
- Place channel in
, C.2 6 hours downscale trip. l h - D. Required Action and D.1 Place the associated Immediately associated Completion CREF subsystem in the - Time of Condition B recirculation mode of or C not met, operation. E D.2 Declare associated Immediately CREF subsystem inoperable. l FERMI - UNIT 2 3.3 69 Revision 6 05/28/99
l CREF System Instrumentation B 3.3.7.1 BASES ACTIONS (continued)
%l declared inoperable within 1 hour of discovery of the loss of CREF System initiation capability in both trip systems.
The 1 hour Completion Time (B.1) is acceptable because it O minimizes risk while allowing time for restoring or tripping 4 of channels. k !.f the ino)erable channel cannot be restored to OPERABLE 5tatus wit 11n the allowable out of service time, the channel l must be placed in the tripped condition per Required Action B.2. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow , operation to continue. Alternately, if it is not desired to ' place the channel in tri) (e.g., as in the case where placing the inoperable clannel in trip would result in an i initiation), Condition D must be entered and its Required i Action taken. C.1 and C.2 Because of the diversity of sensors available to provide initiation signals and the redundancy of the CREF System design, an allowable out of service time of 6 hours is provided to permit restoration of any inoperable channel to OPERABLE status. However, this out of service time is only acceptable provided the associated Function is still maintaining CREF System initiation capability. A Function is considered to be maintaining CREF System initiation capability when sufficient channels are OPERABLE or in trip such that one trip system will generate an initiation signal from the given Function on a valid signal. For Function 4, this would require one tri) system to have one channel 0PERABLE or in trip. In t1is situation (loss of CREF System initiation capability), the 6 hour allowance of Required Action C.2 is not appropriate. If the Function is not maintaining CREF System initiation capability, the CREF DI System initiation capability must be declared inoperable
$ within 1 hour of discovery of the loss of CREF System initiation capability in both trip systems.
The 1 hour Completion Time (C.1) is acceptable because it minimizes risk while allowing time for restoring or tripping of channels. Q4 l FERMI UNIT 2 B 3.3.7.1 - 7 Revision 6 05/28/99
CREF System Instrumentation B 3.3.7.1 BASES ACTIONS (continued) If the ino)erable channel cannot be restored to OPERABLE status witlin the allowable out of service time per. Required Action C.2. Condition D must be entered and its Required Action taken. i The 6 hour Completion Time is based on the consideration that this Function provides the primary signal to start the CREF System: thus, ensuring that the design basis of the CREF System is met'. D.1 and D.2 With any Required Action and associated Completier Time not met, the CREF System must be p16<.ed in the emergency recirculation mode of operation per Required Action D.1 to ensure that control room personnel will be protected in the event of a Design Basis Accident. The method used to place , the CREF System in operation must provide for automatically ! re-initiating the System upon restoration of power following a loss of power to the System. Alternately, if it is not desired to start the System, the CREF subsystem associated with inoperable, untripped channel (s) must be declared inoperable immediately. 1 SURVEILLANCE As noted at the beginning.of the SRs. the SRs for each CREF REQUIREMENTS ' System instrumentation Function are located in the SRs column of Table 3.3.7.1-1. The Surveillances are modified by a Note to indicate that for functions 1. 2 and 3. when a channel is placed in an j inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours, provided the associated Function maintains CREF System initiation capability. Upon completion of the Surveillance or i expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition 1 entered and Required Actions taken. This Note is based on ' il the reliability analysis (Ref. 5) assumption of the average oT time required to perform channel surveillance. That analysis demonstrated that the 6 hour testing allowance does not significantly reduce the probability that the CREF System will initiate when necessary. l FERMI UNIT 2 B 3.3.7.1 - 8 Revision 6 05/28/99 L
CREF System Instrumentation B 3.3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.7.1.1 Performance of the CHANNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff. based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria it may be an indication that the instrument has drifted outside its limit. The Frequency is based upon operating ex>erience that demonstrates channel failure is rare. T1e CHANNEL CHECK supplements less formal, but more frequent, checks of channel status during normal operational use of the displays associated with channels required by the LCO. SR 3.3.7.1.2 and SR 3.3.7.1.3 A CHANNEL FUNCTIONAL TEST is perfccmed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical-Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. ' l FERMI- UNIT'2 B 3.3.7.1- 9 Revision 6. 05/28/99 f
l CREF System Instrumentation l B 3.3.7.1 { BASES l SURVEILLANCE REQUIREMENTS (continued) The Frequency of 31 days is reasonable. based on operating experience and on other Surveillances that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furthermore, j o>erating experience shows that failure of more than one ! clannel in a given 31 day period is a rare event. l Y The Frequency of 92 days is based on the reliability 1 l l analyses of Reference 5. i SR 3.3.7.1.4 This surveillance provides a check of the actual trip ! setpoints. Any setpoint adjustment shall be consistent with : the assumptions of the current alant specific setpoint l methodology. The channel must >e declared inoperable if the ! trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.7.11. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology but is not beyond the Allowable Value, the channel performance is still ! within the requirements of the plant safety analysis. Under these conditions. the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology. T The Frequency of 92 days is based on the reliability (l , analyses of Reference 5. SR 3.3.7.1.5 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent' with the plant specific setpoint methodology. The Frequency is bat.ed upon the assumption of a a 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. i s l FERMI -' UNIT 2 B 3.3.7.1 - 10 Revision 6, 05/28/99
CREF System Instrumentation B 3.3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.3.7.1.6' The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.7.3. " Control Room Emergency Filtration (CREF) System," over'aps this Surveillance to provide complete testing of the assumed safety function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an un31anned transient if the Sutveillance were performed with tie reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 18 morth Frequency. , REFERENCES 1. UFSAR, Figure 9.4.2.
- 2. UFSAR. Section 9.4.1.
- 3. UFSAR. Section 6.4.1.
- 4. UFSAR, Chapter 15.
d (l '
- 5. NEDC 31677P A. " Technical Specification Improvement Analysis for BWR Is'lation July 1990.
o Actuation Instrumentation." i l s -. l FERMI UNIT.2 B 3.3.7.1 - 11 Revision 6 05/28/99
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ri M n ot y e mo Na g oM i t a o rd i r Rn ea s l o o tR r a t li n o c ot ra N er t i t t l ti 0 Ci i l nd l A n i ed i l r o r un a A opo M C V Fa T rut N tei a nk n e ME 6R M U oao CMM A r a
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c, SP6C IFICATlord 2 3,7. I s l I TABLE 3.3.7.1 1 (Continued) 1 RADIATION MONITORING INSTRUMENTATION TABLE NOTATIONS
*When irradiated fuel is being handled in the secondary containment.
O Wit fuel in the ew fuel vau . f 88 th fuel in e fuel stor e pool, hj l (( Alam only, f 1 ACTION STATEMENTS g l ACTION 70 - ~ g
. \
- a. With one of the reautred monitors inoperable, place the i <T l inocerID1e channel in the downscal tripped condition within U1 % i nouP; restore tne inoperable enanne to OPERABLE status within' T days, or, within the initiate and maintain i g g gnO operationofthecontropitbhoursroom emergency filtration system in '
J the recirculation mode of operation tsubsys A m j
- b. With both of the required monitors inoperable, initiate and I kTied f maintain operation of the control room emergency filtration j f d g system in the recirculation mooe of operation within I hour 4 F
ACTION 71 - Wi theMea monu r inocerapie, perrorm ea surveys of a monitored area wi portable monitoring i rumentation at east once per 24 ho s.
,l ACTION 72 -
I I With one or mor of the required monitor inoperablo, perform ; area surveys o the monitored area with ortable monitoring ; instrumentati at least once per 24 h rs. .
- b. With both a the recuired monitors i perable during fuel movement, ~ plement the preolanned ternate method of monito in using a continuous moni r; otherwise, suspend uel >
movement FERMI - UNIT 2 7/4 3-49 Amenoment No. 72 w PAGE 3 0F 05 kev
i i UISCUSSION OF CHANGES ITS: SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION ] I ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications " (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions ' are adopted which do not result in technical changes (either actual or interpretational). Editorial changes. reformatting. and re' vised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications l NUREG 1433, Rev. 1. I A.2 ITS LC0 3.3.7.1 Actions are modified by a Note. which provides clarification that, for the purpose of the associated LCO.
" Separate Condition entry is allowed for each channel." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable CREF initiation channel. Complying with the Required Actions will allow for continued operation: with subsequent inoperable CREF initiation channels governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on safety because the clarifications provided by the Note ~are consistent with the existing interpretation of the CTS.
A.3 CTS 3.3.7.1 specifies Actions for CREF initiation channels with .3 - setpoints not within allowable values. These Actions state lM
" declare the channel inoperable" if the channel setpoint is not M restored within limit. ITS 3.3.7.1 contains all the requirements ;
and Actions for CREF initiation channels. Including the allowable y values and Actions when it is not met. The usage rules of Technical Soecifications adequately dictate that channels be declared inoperable and Actions taken when setpoints are not within Technical Specification required values. Therefore. elimination of this statement is an administrative presentation preference only. (Refer to discussion "M.1" for additional changes associated with this Action.) 4 FERMI - UNIT 2 1 REVISION 6, 05/28/99l
l l
- l. DISCUSSION OF CHANGES l
ITSi SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION A.4 CTS Table 3.3.7.1 1 Action 70.a presents the required actions for inoperable control center normal makeup air radiation channel (s). These actions allow a total of 7 days. 6 hours, with one l . inoperable channel prior to restoration or requiring initiation of l the system. This Action has been rewritten (as presented in ! ITS 3.3.7.1 Actions C'and D) to require tripping the channel within the first 6 hours (ITS Required Action C.2) or placing m associated subsystem in the recirculation mode (ITS Required Action D.1). If it is not desired to place the system in g g recirculation at this time, then ITS Required Action D.2 would require the system to be declared inoperable. Once the system is declared inoperable. the Actions provided in the system LC0 (ITS LC0 3.7.3) allow o 7 day restoration time. At the end of this l' 6 hours plus 7 days. the ITS 3.7.3 Actions would require the system to be in recirculation mode (other alternate compensatory actions are addressed by discussion M.2"). Therefore. the total ITS Action time provided is consistent with the 7 days. 6 hours. CTS action times, and the change is an administrative presentation preference, l I i TECHNICAL CHANGES MORE RESTRICTIVE l l M.1 CTS 3.3.7.1 Action A states a 4 hour allowance with alarm / trip setpoints not within limits prior to declaring the channel inoperable. ITS 3.3.7.1 follows conventional Technical l Specification rules of use and application in considering the channel inoperable at the point it is discovered that the setpoint is not within the Technical Specification required limit. Elimination of this 4 hour allowance results in a consistent application of Operability determinations, and does not negatively impact safety. l i FERMI UNIT 2 2 REVISION 6 05/28/99l
l l DISCUSSION OF CHANGES ITS: SECTION 3.3.7.1 - CREF SYSTEM INSTRUMENTATION M.2 CTS Table 3.3.7.1-1 Actions 70.a and 70.b do not require any alternative actions if the CREF System is not placed in the recirculation mode of operation as required. Additionally, CTS 3.3.7.1 Action c provides an exception to CTS 3.0.3. As such, if the CREF System can not be placed in recirculation mode, no further Action is necessary. ITS 3.3.7.1 Actions do not exclude ( C/ the applicability of LC0 3.0.3: and Action D provides the action to declare the associated CREF subsystem inoperable (and thereby invoke the Actions of ITS 3.7.3), or place the CREF System in recirculation mode of operation as required. The apparent allowance of the CTS Actions for continued unrestricted operation with inoperable CREF instrumentation is replaced with appropriate consideration of the degradation to the CREF System function (i.e., declare it inoperable): therefore this change does not ' adversely impact on safety. M.3 CTS Tables 3.3.7.1-1 and 4.3.7.1-1 provide the required Applicability for control center normal makeup air radiation monitors, which is not consistent with the Applicability of the CREF System that it supports (refer also to dis; mn "L.1" for additional changes). Specifically, in Mode 4 dur mg operations with the potential for draining the reactor vessel (OPDRVs) ITS Table 3.3.7.1-1 requires Operability of the makeup air radiation monitors, while CTS 3.3.7.1 does not. Note that Mode 5 OPDRVs are covered in both CTS (it addresses all Mode 5 operations) and ITS: therefore this change affects Mode 4 operation only. This added Applicability provides no negative impact on safety. M.4 CTS 4.7.2.1.e.2 lists the automatic initiation Functions for CREF System: however, no specific CTS Actions or Surveillances associated with the CREF initiation Function are stated for these Functions (note the following Functions are required for ECCS and/or secondary containment isolation in other CTS LCOs. but are not directly stated as also required for CREF initiation): 1) low reactor water level: 2) high drywell pressure: or 3) fuel pool ventilation exhaust radiation monitor. ITS Table 3.3.7.1-1 includes these Functions along with appropriate Actions, and Surveillances, and Surveillance testing allowance, consistent with the CTS Actions for other (radiation monitoring) automatic initiation signals and Surveillances presented in NUREG-1433. These added requirements do not adversely impact safety. FERMI UNIT 2 3 REVISION 6, 05/28/99l
I. l DISCUSSION OF CHANGES ITS: SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION / 1 TECHNICAL CHANGES - LESS RESTRICTIVE
" Generic" I b
d LA.1 CTS 3.3.7.1 requires that CREF radiation monitoring actuation l instrumentation trip setpoints to be within the alarm / trip lk setpoint value of Table 3.3.7.1-1. ITS 3.3.7.1 requires that ; instrumentation setpoints be within the allowable value l (consistent with NUREG 1433). However. Actions only apply if the allowable value is exceeded. ITS 3.3.7.1 requires only that l instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details while the allowable value reflects channel Operability. Requirements for trip setpoints in k l CTS 3.3.7.1 and CTS Table 3.3.7.1-1 are relocated to the Technical m Requirements Manual (TRM). which requires revisions be controlled M l l by 10 CFR 50.59. This relocation continues to provide adequate protection of the public health and safety since the requirement
- j. .
I for instrument channel Operability and the allowable value setpoint continues to be required by the Technical Specifications. \ l l LR.1 Not used. f k l k I a l FERMI UNIT 2 4 REVISION 6 05/28/99l L
DISCUSSION OF CHANGES ITS: SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" L.1 CTS Tables 3.3.7.1-1 and 4.3.7.1-1 provide the required Applicability for ccntrol center normal makeup air radiation monitors, which is not consistent with the Applicability of the CREF System that it supports (refer also to discussion "M.3" for additional changes). Specifically, the instrumentation is required fir all Mode 5 operations , while the CREF System Operability requirements during Mode 5 apply only during 3 activities. ITS Table 3.3.7.1-1 specifies the Applicability of these three activities in Notes (a) and (b). as applied to Mode 5 operations. These include only 0PDRVs. Core Alterations and g handling irradiated fuel (the latter continues to be addressed ! consistently in CTS and ITS). During Mode 5 operations only OPDRVs. Core Alterations, and movement of irradiated fuel are > expected to have the potential for radioactivity releases that I ' would require the control center normal makeup air radiation i Function. At other times in Mode 5 the limited activities that l may be conducted do not require the safety function of the CREF ' System (nor Secondary Containment or SGT). There is no safety b impact in relaxing the CREF instrumentation applicability to be consistent with the system which it supports. Therefore, this change has no significant impact on safety. L2 CTS Table 3.3.7.11 Action 70.a sllows one hour to place an inoperable control center normal makeup air radiation monitor in the tripped condition. ITS 3.3.7.1 Required Action C.2 extends i this allowance to 6 hours. With one inoperable monitor the safety { function continues to be assured by the remaining Operable monitor. A one hour Completion Time is appropriate (and is provided in ITS Required Action C.1) for complete loss of automatic initiation capability (i.e.. both monitors inoperable). I However, consistent with NUREG 1433, 6 hours provides a reasonable time to attempt to effect repairs, while considering that this Q I function provides the primary signal to start the CREF System. Since the safety function continues to be assured, the probability k { I , of an event requiring automatic initiation is low, and the I Completion Time extension is minimal. there is not significant impact on safety due to this change.
. l l
FERMI UNIT 2 5 REVISION 6. 05/28/99l 1
DISCUSSION OF CHANGES ITS: SECTION 3.3.7.1 - CREF SYSTEM INSTRUMENTATION RELOCATED SPECIFICATIONS R.1 The area radiation monitors are used to indicate when the radiation in the area has exceeded its allowable setpoint. There are no automatic functions that are performed by these i instruments. The instruments are not l' sed to mitigate a design l basis accident (DBA) or transient. Information provided by these l instruments on the radiation levels within secondary containment would have limited or no use in identifying / assessing core damage. Comoarison to Deterministic Screenina Criteria:
- 1. These area monitors are not used for, nor capable of. ,
detecting a significant abnormal degradation of the reactor l coolant pressure boundary prior to a DBA. l 2. These monitors do not monitor a process variable that is an ! initial condition of a DBA cr transient analyses. l
- 3. These area monitors are not part of a primary success path -
in the mitigation of a DBA or transient that assumes the failure of, or presents a challenge to the integrity of a j fission product barrier. I
- 4. As discussed in Sections 3.5 and 6, and summarized in Table 4 1 (Item 150) of NED0 31~466, the loss of these area monitors was found to be a non-significant risk contributor j l to core damage frequency and offsite releases. DECO has j reviewed this evaluation. considers it applicable to Fermi- ;
- 2. and concurs with the assessment. Moreover, this system )
is not included in the Maintenance Rule (MR) scope and thus l 1s considered by the m Expert Panel to be non-risk significant.
Conclusion:
Since the screening criteria have not been satisfied, the Area l Monitors Criticality Monitors (New Fuel Vault and Fuel Storage 9 M l Pool) and Control Room Direct Radiation Monitor LC0 and Surveillances are relocated to the Technical Requirements Manual. N l where revisions are controlled oy 10 CFR 50.59. g I l / i FERMI - UNIT 2 6 REVISION 6 05/28/99l l
"r;CREC] System Instrumentation gggp 3.3.7.1 3.3 INSTRUMENTATION T
3.3.7.1 fMa4e ControldiRoom (gwqm
'rer.; .t:1 C\% hre (tstEF)
C=tr:1 (MCREC,, ystem Instrumentation CREF LCO 3.3.7.1 The-[MCREC-} System instrumentation for each Function in ' 3 '1' I\/ Table 3.3.7.1-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.7.1-1. ACTIONS ___.N0TE- - - - - - - - - - - - - - - - - - - - - - - - , - - - - - f$$$ $_". ".' .$'_. I I""'b ____. . ..._____ CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Enter the Condition Imediately (&4;m a g channels inoperable, referenced in Table 3.3.7.1-1 for ' the channel. [Asrequiredby . B.1 Declare associated I hour from Required Action A.1 *MCP50 subsystem discovery of and referenced in h Inop, era]ble. loss of [ MCI:0)1 CE fl Table 3.3.7.1-1. initiation
- capability in Doc Ah both trip ,
systems 1 0-l E < y) B.2 Place channel in 24 hours l trip. o\ (continued) E C< BWR/4 STS 3.3-71 Rev 1, 04/07/95 1 l
-o
{MGAEC3 System Instrumentition 3.3.7.1
' ACTIONS (continued)
<cn>
to CONDITION REQUIRED ACTION COMPLETION TIME g M C. As required by C Declare associated I hour from Required Action A.1 c(Ley: j% " C] subsystem discovery of and referenced in ' inoperable. loss of 7."iC] CA G Table 3.3.7.1-1. initiation capability in # both trip systems MlD C.2 Place channel in 1st s.sa. -l, } 6 hours trip. gg4;,,73 7; D. Required Action t,d D.1 -\ -N0 ----\- associated Completion Plac in tox gash Time of Condition B prote ion if s or C not met. utomat c trans r toxic as i pr ection e is ino rable. h ~~~
\
~
Place the e. u m t M
\
~
hdi
. .tr y stem %
cre a s ';ggsig:=: -d-E _
-D.2 -------- E--------
Only a icable to Funct n 3 channe . olate asso ted hour main steam ne (MSL). / jl g (continued) BWR/4 STS 3.3-72 Rev 1, 04/07/95 s
l l l Chi \
-MCREE System Instrumentation l B 3.3.7.1 l l
l BASES l ACTIONS L1 (continued) Required Action A.) directs entry into the appropriate Condition referenced in Table 3.3.7.1-1. The applicable Condition specified in the Table is function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the , appropriate subsequent Condition. I B.1 and B.2 Because of the diversity of sensors available to provide initiation signals and the redundancy of the Nyste - C/2E'F design, an allowable out of service time of 24 hours has been shown to be acceptable (Refs. 5 and 6) to permit restoration of any inoperable channel to OPERABLE status. However, this out of service time is only acceptable - provided the associated Function is still maintaining 4tsftff~ 0ggp gy System initiation capability. A Function is considere to ~ be maintainingM System initiation capability whe sufficient channels are OPERABLE or in trip such that one trip system will generate an initiation signal from the given function on a valid signal. For Functions 1 and 2, go this would require one trip system to have :n :hrn:1 p., cpypELS h;i. _t. . g OPERABLE or in trip. ': 1:;f: :trin; i: th; e - p . . =t f t': ; -ti r Of : rt rf tr i d = tuin h;i;
- ...;ng r r t}. For Function 3, this would require one trip odTorre system to ,have one channel ;:r 1:;i: :tr':;, n;;; :t;d ith gp 796 CEEF r rh ."C., OPERABLE or in trip. E thi: ;it..tix 'in; :f
% MeRef System initiation capability M the 24 hour allowance CREF of Recuired Action B.2 is not appropriate. If the Function' g g
, is not maintainingW. System initiation capability, the Cl!EP .. Systen must be declared ineparable within I hour of '
discovery of the loss of stem initiation capability % trip systems. CRED
,UBa tr b capab;Y. d e ur Completion Time (8.1) is acceptable because it minimizes risk while allowing time for restoring ~or tripping 4 3
of channels. g) If the inoperable channel cannot be restored to OPERABLE - status within the allowable out of service time, the channel must be placed in the tripped condition per Required N Action B.2. Placing the inoperable channel in trip would (continued) BWR/4 STS B 3.3-213 Rev 1, 04/07/95
CREF
-MCRE{ System Instrumentation B 3.3.7.1 BASES ACTIONS B.i and B.2 (continued) conservatively compensate for the inoperability, restore f c:pability to accommodate a single failure, and allow operation to continue. Alternately, if it is not desired to 4 g
place the channel in trip (e.g., as in the case where placing the inoperable channel in trip would result in an k initiatien), Condition D must be entered and its Required Action taken. (T C.1 and C.2 Because of the diversity of sensors available to provide gp initiation signals and the redundancy of the MM!CTystem design, an allowable out of service time of 6 hours is
- _ provided to pemit restoration of any inoperable channel to OPERABLE status. However, this out of service time is only CUP acceptable provid J the associated Function is still =
maintaining fReft System initiation capability. A Func% n is considered to be maintaining k na syst.em initiation _ f g gp , capability when sufficient channels are OPERABLE or in trip such that one trip system will generate an initiation signal from the given Function on a valid signal. For Functione 4 antP't, this would require one trip system to have one channel OPERABLE or in trip. In this situation (loss of CREF - Jah System initiation capability), the 6 hour allowance of Required Action C.2 is not appropri;te. If the Function is not mainta.ining M System initiation capability, the [f) CgEP "C"I: System #must be declared inoperable within I hour of i discovery of the loss of '" S stem initiation capability ~
.. in both trip systems.
ie 41Ah'M C.apAW lWf s c p k
' The I hour Completion Time (C.1) is acceptable because it minimizes risk while allowing time for restoring or tripping of channels.
If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time 'h
=:t be pl::;d ;.. L tripp:d ::nditi:, per ReqE, : :hnnne'\
d
'cti;n 0.0.
Pi;;in; the iaaaar=Me channel ia tripperforms\ f,3 +1: ir,t;;t d 'eactica af + ka d :nn:1 ':t:rts Lm.. nCREC A r dryrte-r ia +ha m:rrt:M:: =d:,' fit:- ste!y, i' it - is not desired d: pl::: the c'? nel ir trip (;.g., ;; in e " - d a-- it i: n:t d;;ir:d te :t:rt th; ;4,;ji..7,- j_ Condition D must be entered and its Required Action taken. (continued) BWR/4 STS B 3.3-214 Rev 1, 04/07/95 6 V/
l l C CEF M6RES System Instrumentation B 3.3.7.1 BASES (continued) SURVEILLANCE ' Note: Certain Frequencies are based o REQUIREMENTS topical repor . for use these Frequencies requencies as s i _ r^ % . .u oy he staff SER for the topical repo . l hs System notedinstrumentation at the beginning Functionof arethe SRs, located the in the SRs for each yCE SRs column of Table 3.3.7.1-1. M *I The Surveillances are modified by a Note to indicate that ! b'3 W '^ when a channel is placed in an inoperable status solely for perfonnance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours, provided the associated Function maintains wcREF ' System initiation capability. Upon completion of the - Surveillance, or expiration of the 6 hour allowance, the channel must be returned to GPERABLE status or the applicable Condition entered and Required Actions taken. Ob This Note is based on the reliability analysis (Ref)(. 5 T M O assumption of the average time required to perform - channel surveillance. That analysis demonstrated that the 6 hour testing allowance does not significantly reduce the k probability that the System will initiate when necessary. (pgp SR 3.3.7.1.1 Performance of the CHANNEL CHECK once every 12 hours ensure-that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is nonnally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring'the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECY. will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. Agreement criteria are determined by the plant staff, based on a combination of the channel instrument unc2rtainties, including indication and readability. If a channel is l (continued) BWR/4 STS B 3.3-216 Rev 1, 04/07/95 p J SW b
i l I CEEF
-MGREE System Instrumentation B 3.3.7.1 BASES SURVEILLANCE SR 3.3.7.1.1 (continued)
REQUIREMENTS outside the criteria, it may be an indication that the instrument has drifted outside its limit. The Frequency is based upon operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel status during nonnal operational use of the displays , associated with channels required by the LCO. j l SR 3.3.7.1.2 6/2.3,30el.3, bTM~M Q A CHANNEL FUNCTIONAL TEST is performed on each required i fuse 9X A channel to ensure that the entire channel will perform the
- e. intended function.fr Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint l gggp methodology. .
f 3 3.~7,I - l The Frequency of 92 d s is based on the reliability analyses of Reference 5 and=fr. 1 7 ~
'9'7ftrs Suni<a)Iau l
-The celit,retics. J i. '.; =f t. provides a check of the actual I trip setpoints. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.7.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.
The Frequency of 92 days is based on the reliability 7 Odo analyses of ReferenceK 5 and-ft: 4 (continued) BWR/4 STS B 3.3-217 Rev 1, 04/07/95 i
CREF System Instrumentation 3.3.7.1 INSERT: TSTF-205 INSERT A A successful test of the required contact (s) of a channel relay may be' performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL ! FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. INSERT B 3.3.7.1-1 The Frequency of 31 days is reasonable, based on operating experience and on other Surveillances that ensure proper functioning between CHANNEL FUNCTIONAL TESTS. Furthermore, operating experience shows that failure of more than one channel in a given 31 day period is a rare event. j l 1 l , i I i l i J ; 1 l FERMI - UNIT 2 B 3.3-217 (Insert) REVISION 6 05/28/99l 3
7-- cREF HOREC System Instrumentation B 3.3.7.1 BASES SURVEILLANCE SR 3.3.7.1 REQUIREMENTS { l (continued) A CHANNEL CALIBRATION is a complete check of the instrument l loop and the. sensor. This test verifies the channel l responds to the measured parameter within the necessary i range and accuracy. CHANNEL CALIBRATION leaves the channel I ad, justed to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. The Frequency is based upon the assumption of a418 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. l SR 3.3.7.1 _ j The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the (oftfrob g OPERABILITY of the required initiation logic for a specific channel. The s i i gefgf g eqI LCO 3.7.$, .._.ystem functier.Al..u testing performed
....;.t;l Ce.itrelin (.. "IC) !
System," overlaps this Surveillance to provide complete fjlt.fg*p testing f e assumed safety function. N The 18 mon Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant g} outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these comoonents usually pass the Surveillance when performed at the IB month Frequency. REFERENCES 1. OFSAR, Figure h 947-.
- 2. U FSAR, Section=[CC*,]. 4.4. l . l
- 3. U FSAR, Section ,BM7 E}. 6,4./.
l
- 4. U FSAR, ?=*=^= ~
2.2"'. 5 ft:T7 otJ / F' 1 G -770-06 1, " Bases or Chan s to S Int vals an Allowed -of-Se ice Ti eill nce Test for y i l y Selec d ntation chnica (pecif ion " l l l (continued) BWR/4 STS E,3.3-218 Rev 1, 04/07/95 m
1 CkEF l
-MGREC System Instrumentation B 3.3.7.1 l
BASES l REFERENCES NEDC-31677P-A, ' Technical Specification Improvement I Y l Analysis (continued)f,h July 1990. for BWR Isolation Actuation Instrumentation,"lI k ! l l l l C l BWR/4 STS B 3.3-219 Rev 1, 04/07/95 C e
JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION P.6 ITS Bases for the SRs refer to " Reference 5" (i.e.. GENE 770) as a basis for some of the surveillance intervals. Since Fermi-2 has not submitted and received NRC review of applicability of this Topical- "I' Report to Fermi, this reference is deleted. The remaining reference j(( to NEDC 31677 (which is also applied to these same surveillance intervals) has been reviewed and is applicable to Fermi-2. GENERIC CHANGES C.1 TSTF-205: NRC approved change to NUREG-1433. 9 l l
.ma FERMI - UNIT 2 2 REVISION 6, 05/28/99l t
NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.7.1 - CREF SYSTEM INSTRUMENTATION TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.3.7.1 "L.2" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? .
The proposed change extends the Completion Time allowed to trip an inoperable initiation channel. The proposed change does not involve a q significant increase in the probability of an accident previously i evaluated because the CREF initiation is' not an initiator of an analyzed d event. The proposed change does not involve a significant increase in M the consequences of an accident previously evaluated because the CREF System remains capable of its assumed automatic function and there are no changes to the operation or design of the system.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change will not involve any physical changes to plant systems, structures, or components (SSC), or changes in normal plant operation. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
.r' h
FERMI UNIT 2 3 REVISION 6. 05/28/99l l
i l i NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.3.7.1 CREF SYSTEM INSTRUMENTATION l TECHNICAL CHANGES LESS RESTRICTIVE _(Soecification 3.3.7.1 "L.2" Labeled Comments / Discussions) l l 3. Does this change involve a significant reduction in a margin of safety? l h The proposed change does not involve a significant reduction in a margin y of safety because the safety function continues to be assured, the g
- probability of an event requiring automatic initiation is low, and the l Completion Time extension is minimal. Therefore, there is no
! significant reduction in a margin of safety due to this change. l l
, p 9
FERMI UNIT 2 4 REVISION 6 OS/28/99l
LOP Instrumentation 3.3.8.1
'3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LC0 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.
APPLICABILITY: MODES 1. 2, and 3. When the associated emergency diesel generator (EDG) is required to be OPERABLE by LC0 3.8.2, "AC Sources - Shutdown. " ACTIONS _.
..................................... NOTE - - - -- - -- - -- - --- - -
Separate Condition entry is allowed for each channel. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with A.1 Restore channel to 72 hours one or more channels Ql OPERABLE status, inoperable. B. Required Action and B.1 Declare associated Immediately associated Completion EDG inoperable. l Time of Condition A not met. M l One or more buses with LOP trip capability not maintained. 1
.l FERMI - UNIT 2 3.3 72 Revision 6, 05/28/99
LOP Instrumentation 3.3.8.1 I Table 3.3.8.1-1 (page 1 of 1) i Loss of Power Instrumentation ' REQUIRED CHANNELS SURVEILLANCE FUNCTION PER BUS REQUIREMENTS ALLOWABLE VALUE
- 1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage).
l a. Bus Undervoltage 4 SR 3.3.8.1.1 (a) SR 3.3.8.1.2 SR 3.3.8.1.3 l b. Time Delay 4 SR 3.3.8.1.1 (b) SR 3.3.8.1.2 SR 3.3.8.1.3
- 2. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) _
l a. Bus Undervoltage 4 SR 3.3.8.1.1 (c) ! SR 3.3.8.1.2 i SR 3.3.8.1.3 i
't l b. Time Delay 4 SR 3.3.8.1.1 (d) i SR 3.3.8.1.2 SR 3.3.8.1.3 (a) Division I: a 2972.3 V and s 3093.7 V Division II: a 3016.4 V and 5 3139.6 V (b)- Division 1: a 1.9 see and s 2.1 see Division II: a 1.9 sec and 5 2.1 sec (c) Division I; a 3873,0 V and s 4031.0 V j Division,II: a 3628.0 V and 5 3776.0 V '
(d) Division I: a 41.8 see and s 46.2 see Division II: a 20.33 see and 5 22.47 sec j l l J l FERMI - UNIT 2 3.3 74 Revision 6, 05/28/99 l
T 1 i LOP Instrumentation B 3.3.8.1 l B 3.3 INSTRUMENTATION B 3.3.8.1 Loss of Power (LOP) Instrumentation BASES BACKGROUND Successful operation of the required safety functions of the Emergency Core Cooling Systems (ECCS) is dependent upon the availability of adequate power sources for energizing the various components such as pump motors, motor operated valves, and the associated control components. The LOP instrumentation monitors the 4.16 kV emergency buses. Offsite power is the preferred source of power for the 4.16 kV emergency buses. If the monitors determine that insufficient power is available, the buses are disconnected from the offsite power sources and connected to the onsite emergency diesel generator (EDG) power sources. Each 4.16 kV emergency bus has its own independent LOP instrumentation and associated trip logic. The voltage for each bus is monitored at two levels, which can be considered as two different undervoltage Functions: Loss of Voltage and 4.16 kV Emergency Bus Undervoltage Degraded Voltage. I Bus undervoltage instrumentation for the loss of voltage function monitors the Class 1E emergency bus for a level of voltage that is. insufficient to o)erate the required ESF equipment caused from a loss of t1e preferred off-site power source. Bus undervoltage instrumentation for the degraded , voltage function monitors the Class 1E bus for a level of i' voltage from the preferred off site power source that is insufficient to operate the required ESF equipment, but is not low enough to cause the loss of voltage function to operate. thereby ensuring adequate voltage for ESF o)eration ! and protecting the ESF equipment from damage caused >y low ' k voltage operation. Both loss of voltage functions' within a bus cause identical actions. Class 1E bus isolation, load shedding to prevent overloading of the associated EDG. i transfers, and automatic starting of the associated EDG and load sequencer. *, Each Function is monitored by four undervoltage relays that compare measured input signals with pre established j setpoints in each bus. When the setpoint of the j undervoltage relay is exceeded continuously for 2 seconds, j the channel output relay actuates. The outputs of the undervoltage relays are arranged in a one out-of two-taken-twice logic (i.e., two trip systems) for each Function in each bus. The input signal to the undervoltage relays is at l FERMI - UNIT 2 B 3.3.8.1 - 1 Revision 6. 05/28/99 l 1
Q LOP Instrumentation { B 3.3.8.1 i BASES BACKGROUND (Continued) the 120 Volt level and is derived from two independent step-down bus potential transformers (PT). Each PT is electrically connected to the associated Class 1E bus when the off site power source is supplying the bus. Each bus l uses one potential transformer connected to the line side of l 1 the Class 1E bus feed breaker providing input to one of the ' redundant wired pair of undervoltage relays, and a second potential transformer connected to the load side of the bus feed breaker providing input to the other redundant wired pair of undervoltage relays. A coincident trip in each redundant pair of undervoltage relay channels then causes a LOP trip signal to the trip logic. The degraded voltage function for each Class 1E bus has an additional time delay relay that is summed with time delay action provided in the undervoltage relays. The additional time delay is to prevent actuation of the trip logic for a pre-established time limit, unique for the 7.ssociated divisional off site power source. t Both LOP Functions are automatically bypassed whenever the associated EDG is supplying its respective ESF bus. This
- ensures that the voltage dips encountered during load sequencing on the EDG will not interact with the load shedding feature. l.
APPLICABLE ' The LOP instrumentation is required for Engineered Safety SAFETY ANALYSES. Features to function in any accident with a loss of offsite LCO, and power. The required channels of LOP instrumentation ensure APPLICABILITY that the ECCS and other assumed systems powered from the EDGs, provide plant protection in the event of any of the Reference 2, 3 and 4 analyzed accidents in which a loss of offsite power is assumed. The initiation of the EDGs on loss of offsite power, and subsequent initiation of the ECCS, ensure that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. Accident analyses credit the loading of the EDG based on the loss of offsite power during a loss of coolant accident. The diesel starting and loading times have been included in the delay time associated with each safety system component requiring EDG supplied power following a loss of offsite power. l
,e' l FERMI UNIT 2 B 3.3.8.1 - 2 Revision 6. 05/28/99
LOP Instrumentation B 3.3.8.1 BASES APPLICABLE SAFETY ANALYSES LC0. and APPLICABILITY (continued) The LOP instrumentation satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). The OPERABILITY of the LOP instrumentation is dependent upon the OPERABILITY of the individual instrumentation channel Functions specified in Table 3.3.8.1-1. Each Function must have a required number of OPERABLE channels )er 4.16 kV emergency bus, with their setpoints within t1e specified Allowable Values. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions. The Allowable Values are specified for each Function in the Table. Nominal trip setpoints are specified in the setpoint calculations. The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS. Operation with a trip setpoint less conservative than the nominal trip setpoint. but within the Allowable Value, is acceptable. Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g. degraded voltage), and when the measured output. value of the process parameter exceeds the setpoint the associated device (e.g., trip unit) changes state. The analytic limits are derived from the limiting
- values of the process parameters obtained from the safety analysis. The Allowable Values are derived from the analytic limits, corrected for calibration, process, and some of the instrument errors- The trip setpoints are then determined accounting for the remaining instrument errors (e.g. , drift). The trip set >oints derived in this manner provide adequate protection )ecause instrumentation uncertainties, process effects calibration tolerances, instrument drift, and severe environment errors (for channels that must function in harsh environments as defined by 10 CFR 50.49) are accounted for.
The specific Applicable Safety Analyses. LC0. and Applicability discussions are listed below on a Function by Function basis. l FERMI UNIT 2 B 3.3.8.1 - 3 Revision 6 05/28/99
l LOP Instrumentation B 3.3.8.1 BASES APPLICABLE SAFETY ANALYSES. LCO, and APPLICABILITY (continued) 1
- 1. 4.16 kV Emeraency Bus Undervoltaae (Loss of Voltaae)
Loss of voltage on a 4.16 kV emergency bus indicates that : offsite power may be com)letely lost to-the respective emergency bus and is una>1e to supply sufficient power for proper operation of the applicable equipment. Therefore, the power supply to the bus is transferred from offsite power to EDG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment. The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment. l Four channels of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) Function per associated emergency bus are only g required to be OPERABLE when the associated EDG is required to be OPERABLE.to ensure that no single instrument failure can preclude the EDG function. Refer to LC0 3.8.1 "AC Sources-0perating." and 3.8.2. "AC Sources-Shutdown." for Applicability Bases for the EDGs.
- 2. 4.16 kV Emeraency Bus Undervoltaae (Dearaded Voltaae)
A reduced voltage condition on a 4.16 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function. Therefore, power supply to the bus is transferred from offsite power to onsite EDG power when the voltage on the bus drops below the Degraded Voltage Function Allowable Values (degraded voltage with a time delay). This ensures that adequate power will be available to the required equipment. The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough g.' l FERMI - UNIT 2 83.3.8.1-4 Revision 6. 05/28/99
LOP Instrumentation B 3.3.8.1 BASES APPLICABLE SAFETY ANALYSES LC0. and APPLICABILITY (continued) to provide time for the offsite >ower supply to recover to ' normal voltages, but short enoug1 to ensure that sufficient power is available to the required equipment. l Four channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) Function per associated bus are only required to be OPERABLE when the associated EDG is required ! to be OPERABLE to ensure that no single instrument failure l can preclude the EDG function. Refer to LC0 3.8.1 and I LC0 3.8.2 for Applicability Bases for the EDGs. 1 i
~
ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3. Completion Times. specifies that once a Condition has been entered. subsequent divisions, subsystems. components, or variables , expressed in the Condition. discovered to be inoperable or ! not within limits. will not result in separate entry into ' the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate com)ensatory measures for separate inoperable channels. As suc1, a Note has been provided that allows separate
, Condition entry for each , inoperable LOP instrumentation channel.
M With one or more channels of a Function ino>erable. the Function may not be capable of performing t1e intended function (if LOP trip capability is lost. Condition B is also required to be entered). Therefore. 72 hours are allowed to restore the inoperable channel to OPERABLE status. If the ino>erable channel cannot be restored to OPERABLE status wit 11n the allowable out of service time. Condition B must be entered and its Required Action taken. The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 72 hour Completion Time is acceptable because it minimizes risk while allowing time for restoration of channels. / l FERMI - UNIT 2 B 3.3.8.1 - 5 Revision 6 05/28/99
LOP Instrumentation B 3.3.8.1 BASES ACTIONS (continued) EL1 If Required Action A.1 and associated Completion Time is not met, or the associated Function is not capable of performing the intended function, the associated EDG(s) is declared inoperable immediately. This requires entry into applicable i Conditions and Required Actions of LCO 3.8.1 and LC0 3.8.2. which provide appropriate actions for the inoperable EDG(s). SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS ins.trumentation Function are located in the SRs column of . Table 3.3.8.1 1. ! SR 3.3.8.1.1 l A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact (s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non Technical Specifications tests at least once per refueling interval with applicable extensions. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency of 31 days is based on operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is a rare event. SR 3.3.8.1.2 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel
. responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel l adjusted to account for instrument drifts between successive l calibrations consistent with the plant specific setpoint methodology. This SR also ensures the sum of the degraded voltage time delay and the longest time delay of the four l FERMI - UNIT 2 B 3.3.8.1 - 6 Revision 6. 05/28/99
1 l LOP Instrumentation B 3.3.8.1 l BASES l SURVEILLANCE REQUIREMENTS (continued) l associated bus undervoltage relays remains consistent with hl the plant specific setpoint methodology. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology. The Frequency is based upon the assumption of a = 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. SR 3.3.8.1.3
~
The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in , LC0 3.8.1 and LC0 3.8.2 overlaps this Survei.llance to provide complete testing of the assumed safety functions. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unalanned transient if the Surveillance were performed with tie reactor at power. 0)erating exper.ience has shown these components usually pass t1e Surveillance when performed at the 18 month Frequency. REFERENCES 1. UFSAR, Figure 8.3 8.
- 2. UFSAR, Section 3.6.
- 3. UFSAR, Section 6.3.
- 4. UFSAR, Chapter 15.
e l FERMI UNIT 2 B 3.3.8.1 - 7 Revision 6. 05/28/99
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5pgc g p u.n on 3. 5. 3.1 (Also see SpeciAcob 3 3.5 0 m m :... w (Continued) EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION ACTION STATEMENTS ACTION 30 - Gith the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement:
- a. For one trip system, place that trip system in the tripped condition within 24 hours or declare the associated ECCS !
inoperable.
- b. For both trip systems, declare the associated ECCS inoperable.
$l ION 31 - With the number of OPERABLE channels less than required by the gggg \
Minimum OPERABLE Channels per Trip System reoutrement, declare the associated ADS Trip System inoperable within 24 hours. 3 3 5d With the number of OPERABLE channels less than required by the TION 32 - Minimum OPERABLE Channels per Trip System requirement, place the inoperable channel in the tripped condition within 24 hours. ACTION 33 - Restore the manual initiation and/or manual inhibit function to OPERABLE status within 24 hours or declare the associated ECCS or ADS Trip System inoperable. ACTION 34 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System requirement, place at least one inoperable channel in the tripped condition within 24 hours, align the HPCI system to take suction from the uppression pool, or declare the HPCI system inoperable. ACTION 35 - With the number of OPERABLE channels: _ m_ ..,u__ ,_ir' u. Number of Channels, restore the t ino erable channel to OPERABLE status within 72 hours or
,kCT}0 h[ dec are the associated emergency diesel generator r
inoperable (3.5.1.A ena4.2. or 3.8 uv.eastne ALitun (e. anoropri reasireo r oy spectttpation/ Q*g
- b. "::: '"-+k" "'-i d Channels OPERABLE requirement, CTlod Q declare the associated diesel generator inonerahl n v ~
(takenne AL110N regtp'reo oy spectricapn 3.8.1.1 or
\3.Y. l .2, as appropMate.f-i FERMI - UNIT 2 3/4 3 26 Amendment No. JJ, 7), 83 i
PAGE d - 0F 05
I DISCUSSION OF CHANGES I ITS: SECTION 3.3.8.1 - LOP INSTRUMENTATION ADMINISTRATIVE I A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS) certain wording preferences or conventions are adopted which do not result in technical changes (either ; actual or interpretational). Editorial changes, reformatting, and ! revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications l NUREG 1433. Rev. 1. A.2 ITS LC0 3.3.8.1 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LCO,
" Separate Eondition entry is allowed for each channel." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable LOP channel.
l Complying with the Required Actions will allow for continued operation: with subsequent inoperable ECCS channels governed by subsequent Condition entry and application of associated Required Actions. This is an administrative change with no impact on j safety because the clarifications provided by the Note are consistent with the existing interpretation of the CTS. ? . A.3 CTS 3.3.3 specifies Actions for LOP channels with setpoints not within allowable values. These Actions state " declare the channel lT inoperable until the channel 1s restored to Operable status." Q ITS 3.3.8.1 contains all the requirements and Actions for LOP O channels . including the allowable values and Actions when it is ~ not met. The usage rules of Technical Specifications adequately dictate that channels be declared inoperable and Actions taken until restored to Operable, without a specific statement to that effect. Therefore, elimination of this statement is an administrative presentation preference only. A.4 CTS 4.3.3.2 requires an LSFT "and simulated automatic operation" of all channels. The " simulated automatic operation" is interpreted to be included in the LSFT and/or Channel Functional lyM Test. This additional detailing of the required test is [ unnecessary. Therefore its elimination is an administrative ( change. 4 e" n FERMI - UNIT 2 1 REVISION 6 05/28/99l
i I DISCUSSION OF CHANGES ITS: SECTION 3.3.8.1 - LOP INSTRUMENTATION A.5 CTS- Table 3.3.3-1 footnote ** states the Applicability for the LOP Functions during Mode 4 and 5 as "when ESF equipment is required 1 to be OPERABLE." This is further clarified by associated ) Action 35, which requires the associated EDG to be declared ! inoperable if inoperable channels are not restored to Operable ] status. Therefore, the intent and reasonable interpretation of )
"ESF equipment" is presented in ITS 3.3.8.1 Applicability as "when j the' associated emergency diesel generator (EDG) is required to be '
OPERABLE." This clarification is an administrative presentation preference only. 1 A.6 CTS Table 3.3.3 1 Actions 35.a and 35.b include direction to declare the EDG inoperable "and take the ACTION required ... " for the inoperable EDG. ITS 3.3.8.1 Action B requires the EDG be declared inoperable, but does not provide direction to "take the Action required." The proper use and application of the Technical Specifications is accepted without instructional direction to comply with necessary Actions. Therefore the explicit statement is considered an unnecessary informational reminder. Elimination of this reminder is presentation preference which represents no change in intent. Therefore, it is an administrative change with no impact on safety. A.7 CTS Table 3.3.31 requires Loss Of Power channels to be Operable. The table lists not only the " Total No. Of Channels" but also has columns for " Channels To Trip" and " Minimum Channels Operable." l The associated CTS Action (Action 35) references " total" channels and " minimum" channels, but no reference to or utilization of the
" Channels To Trip" information is made in CTS. ITS 3.3.8.1 Actions reword and reformat these requirements such that references to the total number of channels is all that is required. Therefore, elimination of any reference to " Channels To Trip" and " Minimum Channels Operable" is not necessary. As such, this reformatting is an administrative change only.
FERMI - UNIT 2 2 REVISION 6 05/28/99 h
DISCUSSION OF CHANGES ITS: SECTION 3.3.8.1 LOP INSTRUMENTATION A.8 CTS Table 3.3.3-1 presents the undervoltage instrumentation channels as consisting of a total of 2 channels per bus. The CTS also states that the logic is such that only one of the two channels is required to actuate the function. Given this presentation, the interpretation of "undervoltage channel" that is needed to correctly apply the CTS requirements to the actual Fermi-2 design is not typical of most other Specifications
- treatment of " channel." The actual Fermi-2 l undervoltage channel logic design is more specifically a 1-out-of 2-taken twice logic. Therefore, the LOP definition of " channel" is being revised and will be stated as "4" channels. This utilizes a more typical interpretations of " channels" consistent with the 1-out-of-2 taken-twice logic. With this change, the Actions are modified to reflect the actions consistent with CTS given the revised interpretation of a LOP channel. Therefore, the ITS presentation is retained technically consistent with CTS and the change is administrative.
t TECHNICAL CHANGES - MORE RESTRICTIVE L M.1 CTS Applicability for Table 3.3.31. Loss of Power instrumentation does not include any requirements when the unit is defueled (i.e.. ! I not in Modes 1, 2. 3. 4. and 5). ITS Applicability for l l LC0 3.3.8.1 includes "when the associated EDG is required to be ! Operable." which in turn includes the Applicability of "during movement of irradiated fuel." Since fuel handling accidents can l occur with the core defueled, the addition of this Applicability ) ensures appropriate requirements for the necessary support of the EDG function are applicable. 1 l l l FERMI --UNIT 2 3 REVISION 6 05/28/99l
\
l { DISCUSSION OF CHANGES ITS: SECTION 3.3.8.1 LOP INSTRUMENTATION i TECHNICAL CHANGES LESS RESTRICTIVE
" Generic" ,
LA.1 CTS 3.3.3 requires that ECCS actuation instrumentation trip setpoints to be within Trip Setpoint column values of CTS Table 3.3.3 2 (which also includes trip setpoints and allowable values for LOP instrumentation). Additionally. CTS 3.3.3 Action a requires that an inoperable '.0P instrument channel setpoint be restored consistent with the trip setpoint value. However. Actions only apply if the allowable value is exceeded. ITS 3.3.8.1 requires only that instrumentation setpoints be within the allowable value. Trip setpoints reflect operational details while g the allowable value reflects channel Operability. ITS 3.3.8.1 relocates trip setpoints and the 120V basis allowable values (consistent with the NUREG 1433) to the Technical Requirements Manual (TRM). which requires revisions be controlled by 10 CFR d 50.59. The trip setpoint and 120V basis allowable values (corresponding to the 4160V basis values remaining in ITS) are 4 g established based on a combination of instrument design factors. ; environmental factors, and the allowable value (which is what is ' conservatively derived from the value assumed in the safety k analyses). Therefore, these details can be adequately defined and , controlled in the TRM. This relocation continues to provide 1 adequate protection of the public health and safety since the requirement for instrument channel Operaility and the allowable g value setpoint continues to be required by the Technical ' Specifications. TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" None RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BAS _E_5 The CTS Bases for 'this Specification have been replaced by Bases that reflect ', the format and applicable content of ITS 3.3,8.1 consistent with the BWR STS. NUREG 1433 Rev. 1. FERMI UNIT 2 4 REVISION 6 05/28/99l
l l l l LOP Instrumentation , 3.3.8.1 l 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation , LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 .3 D shall be OPERABLE. EDG) APPLICABILITY: MODES 1, 2, and 3, (diesel generator is required to be When the associated OPERABLE by LCO 3.8.2, "AC Sources-Shutdown." ACTIONS _
---- =----- = = = = = --- NOT E = -- - = = ; = - = ------------- -
Separate Condition entry is allowed for each channel. .
--____________- --- _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = = - -- - = _ _ _ _ _ - -
. CONDITION REQUIRED ACTION COMPLETION TIME
@3s wi&_gorrn h R 4A}o 3r 0,2. a I hour f) A. One or moretchannels-inoperable.
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E I 1 l l l l LOP Instrumentation 3.3.8.1 l l Table 3.3.8.1 1 (page 1 of 1) Loss of Power Instruuntation REQUltEO CHANNELS SURVEILLANCE ALLOWA3LE FUNCTICol PER BUS REQUltEMEMf3 VALUE l i l 1. 4.16 kV Emergency sus undervoltage
/ (Loss of Voltage)
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i LOP Instrumentation B 3.3.8.1 i I
-B 3.3 -INSTRUMENTATION J
B 3.3.8.1 Loss of Power (LOP) Instrumentation f BASES BACKGROUND Successful operation of the required safety functions of the l
-Emergency Core Cooling Systems (ECCS) is dependent upon the i availability of. adequate power sources for energizing the !
various components such as pump motors, motor operated valves, and the associated' control components. The LOP i instrumentation monitors the 4.16 kV emergency buses. l Offsite power is the preferred source of power for the i 4.16 kV emergency buses. If the monitors determine that p,t . insufficient power is available, the buses are disconnected ! from the offsite power sources and connected to the onsite [gesegdiesel generator power sources. l l Each 4.16 kV emerg Ncy bus has its own independent LOP instrumentation and associated trip logic. The voltage for each bus is monitored at two levels, which can be considered as two different undervoltage Functions: Loss of Voltage and 4.16 kV Emergency Bus Undervoltage Degraded Voltage. _ 3 (Eacn tun ion causes varyous Dus transrer; ana oisconnects.
,q Each Fu tion is monitofed by two undervfitage relays for b'b i
d 5 in ude electronic quipment (e.g.,
- (k. T e chann s ip units) that i c pares measured nput signals wit pre-established l
/d5 M i etpoints. When he setpoint is e eeded, the chann l g g,3,g.[- j K, output relay a uates, which then outputs a LOP tri signal}
to the trip i ic. I i APPLICABLE The LOP instrumentation is required for Engineered Safety , SAFETY ANALYSES, Features to function in any accident with a loss of offsite i LCO, and power. The required channels of LOP instrumentation ensure i APPLICABILITY that the ECCS and other assumed systems powered from the j E )Gs, provide plant protection ~ in the event of any of the ! leference 2, 3, and 4 analyzed accidents in which a loss of f, offsite power is assumed. The initiation of thellTGs on loss of offsite power, and subsequent initiation of the ECCS, ensure that the fuel peak cladding temperature remains below the limits of 10 CFR 50.46. (continued) l BWR/4 STS B 3.3-220 Rev 1, 04/07/95 Rev6
l LOP Instrumentation B 3.3.8.1 INSERT B 3.3.8.1-1 Bus undervoltage instrumentation for the Loss of Voltage Function monitors the Class 1E emergency bus for a level of voltage that is insufficient to operate the required ESF equipment caused from a loss of the preferred off-site power source. Bus undervoltage instrumentation for the Degraded Voltage Function monitors the Class 1E bus for a level J of voltage from the preferred off-site power source that is insufficient to operate the required ESF equipment, but is not low enough to cause i the Loss of Voltage Function to operate, thereby ensuring adequate voltage for ESF operation and protecting the ESF equipment from damage caused by low voltage operation. Both Loss of Voltage Functions within a bus cause identical actions, Class 1E bus isolation, load shedding to prevent overloading of the associated EDG, transfers, and automatic starting of the -associated EDG and Load Sequencer. Each Function is monitored by four undervoltage relays that compare measured input signals with pre-established setpoints in each bus. When the setpoint of the undervoltage relay is exceeded continuously for 2 seconds, the channel output relay actuates. The outputs of the undervoltage relays are arranged in a one out of-two taken twice logic (i.e., two trip systems) for each Function in each bus. The input signal to the undervoltage relays is at the 120 Volt level and is derived from two independent step down bus potential transformers (PT). Each PT is electrically conn 3cted to the associated Class 1E bus when the off-site power source ir supplying the bus. Each bus uses one i potential transformer conr.ected to the line side of the Class 1E bus feed breaker providing input to one of the redundant wired pair of undervoltage relays, and a second potential transformer connected to the ' load side of the bus feed breaker providing input to the other redundant l wired pair of undervoltage relays. A coincident trip in each redundant l pair of undervoltage relay channels then causes a LOP trip signal to the trip logic. The Degraded Voltage Function for each Class 1E bus has an additional time delay relay that is summed with time delay action provided in the undervoltage relays. The additional time delay is to prevent actuation of the trip logic for a pre established time limit, ; unique for the associated divisional off site power source. l l Both LOP Functions are automatically bypassed whenever the associated l , EDG is supplying its respective ESF bus. This ensures that the voltage l dips encountered during load sequencing on the EDG will not interact with the load shedding feature. I FERMI UNIT 2 B 3.3 220 (Insert) REVISION 6. 05/28/99l l
LOP Instrumentation B 3.3.8.1 BASES I APPLICABLE The specific Applicable Safety Analyses, LCO, and SAFETY ANALYSES, Applicability discussions are listed below on a function by LCO, and Function basis. APPLICABILITY (continued) 4.16 kV Emeraency Bus Undervoltaae (Loss of Voltaae) 1. Loss of voltage on a 4.16 kV emergency bus indicates that offsite power may be completely lost to the respective emergency bus and is unable to supply sufficient power for proper operation of the applicable equipment. Therefore, theogrsupplytothebusistransferredfromoffsite power to DG power when the voltage on the bus drops below the L5ss of Voltage Function Allowable Values (loss nf voltage with a short time delay). This ensures that adequate power will be available to the required equipment. ! The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available o the required equipment. b W channels of 4.16 kV Emergency Bus Undervoltage (Loss of ii Voltage) Function per associated emergency bus are only 0 , f,1 required to be OPERABLE when the associated *0G is required to be OPERABLE ensure that,no single instrument failure li l li can prec d a DGRefer function. (T=3.8.1,5 to LCO 6 si AC 6 ':.pt - coa
- m, u - . _ .~ . r l, l
Sources--Operating," and 3.8.2, "AC Sources-Shutdown," for - l Applicability Bases for the A
- 2. 4.16 kV Emeroency Bus Undervoltaae (Dearaded Voltaael A reduced voltage condition on a 4.16 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function.
Therefore, power supply to the bus is transferred from offsite power to onsite DG power when the voltage on the bus drops below the Degrade Voltage Function Allowable Values E (continued) BWR/4 STS B 3.3-222 Rev 1, 04/07/95
1 LOP Instrumentation l B 3.3.8.1
! BASES APPLICABLE 2. 4.16 kV Emeroency Bus Undervoltaoe (Dearaded Voltaael SAFETY ANALYSES, (continued)
LCO, and APPLICABILITY (degraded voltage with a time delay). This ensures that j adequate power will be available to the required equipment. l The Bus Undervoltage Allowable Values are low enough to l prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required l equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient g ower is available to the required e ipment.
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hr E channels of 4.16 kV Emergency Bus ndervoltage (Degraded y Voltage) Function per associated us are only required to be y OPERABLE when the associated DG is required to be OPERABLE h f,D to ensure that no single instrument failure can preclude the DG function. (T danneia ' - ' '- ^ " ' " " ---- o
-: -c;;.ov bus == .nd 00a.) Refer to LCO 3.8.1 and LC0 3.8.2 for Applicability' Bases for the DGs. A ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentatio6 channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables
, expressed in the Condition, discovered to be inoperable or not within limits, will not re'sult in separate entry into the Condition. .Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable LOP instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable LOP instrumentation channel. 1
,(LOA +6fbdim l
is lost, Cond Hem 8 h N Y U is also reg < art A4D bL h) l With one or more hannels of a Function inoperable, U.NM e Function not capable of performing the intended function + Therefore, anly our 49 allowed to restore the inoperable
'7 2, ,5 a M
; (continued) 4 BWR/4 STS B 3.3-223 Rev 1, 04/07/95 s
l
LOP Instrumentation B 3.3.8.1 BASES ACTIONS M (continued) channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time 4he ch:--c' = t N /..ad ,o .i tripsd-r.diti:r.dr quired Action .l. Placing the ginopera e channel in rip would con rvatively compen ate for th inoperabilit , restore capa lity to accommo te a sing 1 failure (wit in the LOP ins umentation), an allow f.3 oper ion to conti ue. Alternate y, if it is not esired t pl e the channe in trip (e.g. as in the case w ere pl cing the ch= tel ia +-fa 'en d *er"!t ia e ne
...itiati g Condition B mIJst be entered and its Required Action taken.
The Compietion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The
- 72. hour Completion Time is acceptable because it minimizes risk while allowing time for restoration :r t"- 'ng of channels.
M . ( es l If.asprRequired Action nd associa'ted Completion Time not met, the associated Function is not capable of A performing the intended function /._'s "rm the associated k,L OEG(s) is declared inoperable immediately. This requires entry into applicable Conditions and Required Actions of LC0 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inop DG(s). SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP REQUIREMENTS instrumentation Function are located in the SRs column of Table 3.3.8.1-1. ine -urvellianges are modified by a No e to inuncate Inat when a channe71s placed in an inope ble status solely for performance ' required Surveillanc s, entry into associate Conditions nd Required Actions m be delayed for up to f,3 2 hours ovided the associated unction maintains DG initiat n capability. Upon mpletion of the Surveill nee, or exp ration of the 2 hour lowance, the channel mu be A (continued) , BWR/4 STS B 3.3-224 Rev 1, 04/07/95 s .
r l I
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1 LOP Instrumentation i B 3.3.8.1
' BASES
, SURVEILLANCE
- return / to OPERABLE stat (Is or the applicable C[itionj l REQUIREMENTS enterf0 and Reauired Astions taken. f (continued)
F SR 3.3.8.1.1 1 Performance of th CHANNEL CHECK once every 12 ours ensures that a gross fa ure of instrumentation has t occurred. A CHANNEL CHECK s normally a comparison of e parameter indicated o one channel to a similar par ter on other channels, t is based on the assumptio that instrument channels onitoring the same paramete should read approx ately the same value. Sign icant deviations .. betwe the instrument channels c ld be an indication of l exc sive instrument drift in o of the channels or l so thing even more serious. CHANNEL CHECK will detect 3f j g oss channel failure; thus it is key to verifying the nstrumentation continues operate properly between each i i f.3 CHANNEL CALIBRATION. l l Agreement criteria a determined by the plant staff b d I on a combination of he channel instrument uncertaint s, , including indicat' n and readability. If a channel s I outside the crit ria, it may be an indication tha the instrument has Brifted outside its limit. The Frequen is based upon operating experi ce that demonstrat s channel failure is rare. The ANNEL CHECK' suppleme s less formal, but more frequen checks of channel during normal operational use o the displays associ ed.with channels required by t LC0 7 SR 3 . 3'. 8.1.
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r A CHANNEL FUNCTIONAL TEST is performed on each required i I p-M channel to ensure that the entire channel will perform the
. intended function f Any setpoint adjustment shall be l
l lNMT k - consistent with the assumptio'ns of the current plant specific setpoint methodology. C.l The Frequency of 31 days is based on operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is a rare event.
; (continued)
A , BWR/4 STS B 3.3-225 Rev 1, 04/07/95 s L
7. I. LOP Instrumentation l B 3.3.8.1 l l l l l l INSERT: TSTF 205 l INSERT A A successful test of the required contact (s) of a channel relay may h be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL j FUNCTIONAL TEST of a relay. This is acceptable because all of the
- other required contacts of the relay are verified by other
, Technical Specifications and non Technical Specifications tests at l least once per refueling interval with applicable extensions. i i l L i l l
.)
FERMI UNIT _2 B 3.3 225 (Insert) REVISION 6 05/28/99l l l
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l l LOP instrumentation B 3.3.8.1 BASES SURVEILLANCE SR 3.3.8.1. REQUIREMENTS (continued) A CHANNEL CAllBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel l responds to the measured parameter within the necessary g range and accuracy. CHANNEL CALIBRATION leaves the channel f
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adjusted to account for instrument drifts between successive
/Nb calibrations consistent with the plant specific setpoint methodology.7
'g g,3,8.l - 2,,
Any setpoint adjustment shall be consistent with the assumptions of tre current plant specific setpoint OP,7, methodology. The Frequency is based upon the assumption of aX 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis. l i SR 3.3.8.1. The LOGIC SYSTEM FUNCTIONAL TEST denionstrates the OPERABILITY of the required actuation logic for a specific channel. The system functional testing performed in LCO 3.8.1 and LC0 3.8.2 overlaps this Surveillance to provide complete testing of the assumed safety functions. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for in unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. REFERENCES 1. M SAR, Figure {-.-b
- 2. 4FSAR, Section 3q 1 4FSAP., Section {6.3[.
4.(M,FSAR, Chapter {l5h BWR/4 STS B 3.3-226 Rev 1, 04/07/95
.s
LOP Instrumentation B 3.3.8.1 I l { INSERT B 3.3.8.1 2 1 This SR also ensures the sum of the degraded voltage time delay and the longest time delay of the four associated bus / undervoltage relays remains consistent with the plant specific setpoint methodology. l l FERMI - UNIT 2 B 3.3 226 (Insert) REVISION 6 05/28/99l
1 JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 l ITS: SECTION 3.3.8.1 LOP INSTRUMENTATION
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l 1 NON BRACKETED PLANT SPECIFIC CHANGES 1 1 P.1 These changes are made to NUREG-1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. Refer to CTS Discussion Of Changes to the related requirement for a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. P.2 Bases changes are made to reflect plant specific design details, 1 equipment terminology, and analyses. I P.3 Bases changes are made to reflect changes made to the Specification. ~ Refer to the Specification and associated JFD if applicable, for additional detail.
'l P.4 Editorial presentation preference. With differing allowable values for each Division, a footnoted presentation allows for clearer reading.
P.5 Fermi 2 CTS presents the undervoltage instrumentation channels as l consisting of a total of 2 channels per bus. The CTS also infers that the logic is such that only one of the two channels is required to actuate the function. Given this presentation, the interpretation of "undervoltage channel" that is needed to correctly apply the CTS requirements is not typical of most other Specifications
- treatment of " channel." The actual Fermi-2 undervoltage channel logic design is more specifically a 1 out of 2 taken twice logic. Therefore, the LOP definition of " channel" is being revised and will be stated as "4" channels. This utilizes a more typical interpretations of
" channels" consistent with the 1-out of 2 taken twice logic. With '4 ,
l this change, the Action Conditions are modified to reflect the ! actions consistent with CTS given the revised interpretation of a LOP l channel. Therefore, the ITS presentation is retained technically , consistent with CTS. P.6 The reference to the PRC Policy Statement has been replaced with a , more appropriate reference to the Improved Technical Specification !
" split" criterda found in 10 CFR 50.36(c)(2)(ii).
1 FERMI UNIT 2 1 REVISION 6 05/28/99l i i
[, JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.3.8.1 ' LOP INSTRUMENTATION GENERIC CHANGES C.1 TSTF 205: NRC approved change to NUREG 1433. b 1. l' 1 1 l
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FERMI UNIT 2 2 REVISION 6, 05/28/99l
INSERT THIS PAGE IN FRONT OF VOLUME 11 Volume 11: CTS MARKUP COMPILATION ' Remove Replace 1.0 CTS M/U (3/41-1) pg 1 of 14 1.0 CTS M/U (3/41-1) pg i of 14 Rev 6 1.0 CTS M/U (3/41-2a) pg 4 of 14 1.0 CTS M/U (3/41-2a) pg 4 of 14 Rev 6 1.0 CTS M/U (3/41-3) pg 5 of 14 1.0 CTS M/U (3/41-3) pg 5 of 14 Rev 6 1.0 CTS M/U (3/41-4) pg 6 of 14 1.0 CTS M/U (3/41-4) pg 6 of 14 Rev 6 1.0 CTS M/U (3/41-5) pg 7 of 14 1.0 CTS M/U (3/41-5) pg 7 of 14 Rev 6 3.3.2.1 CTS M/U (3/41-16) pg i of 9 3.3.2.1 CTS M/U (3/41-16) pg i of 9 Rev 6 j 3.3.1.1 CTS M/U (3/4 3-1) pg 4 of i 1 3.3.1.1 CTS M/U (3/4 3-1) pg 4 of I I Rev 6 3.3.1.1 CTS M/U (3/4 3-8) pg il of 11 3.3.1.1 CFS M/U (3/4 3-8) pg i1 of 1I Rev 6 3.3.6.1 CTS M/U (3/4 3-9) pg 1 of 13 3.3.6.1 CTS M/U (3/4 3-9) pg 1 of 13 Rev 6 { 3.3.6.2 CTS M/U (3/4 3-9) pg i of 8 3.3.6.2 CTS M/U (3/4 3-9) pg i of 8 Rev 6 3.3.6.1 CTS M/U (3/4 3-11)pg 3 of 13 3.3.6.1 CTS M/U (3/4 3-11) pg 3 of 13 Rev 6 3.3.6.1 CTS M/U (3/4 3-12) pg 4 of 13 3.3.6.1 CTS M/U (3/4 3;12) pg 4 of 13 Rev 6 3.3.6.I CFS M/U (3/4 3-14) pg 6 of 13 3.3.6.1 CTS M/U (3/4 3-14) pg 6 of 13 Rev 6 3.3.6.1 CTS M/U (3/4 3-14a) pg 7 of 13 3.3.6.1 CTS M/U (3/4 3-14a) pg 7 of 13 Rev 6 3.3.8.1 CTS M/U (3/4 3-25) pg 2 of 5 3.3.8.1 CTS M/U (3/4 3 25) pg 2 of 5 Rev 6 3.3.5.1 CTS M/U (3/4 3-26) pg 4 of 8 3.3.5.1 CTS M/U (3/4 3-26) pg 4 of 8 Rev 6 3.3.8.1 CTS M/U (3/4 3-26) pg 3 of 5 3.3.8.1 CTS M/U (3/4 3-26) pg 3 of 5 Rev 6 3.3.5.1 CTS M/U (3/4 3-27) pg 5 of 8 3.3.5.1 CTS M/U (3/4 3 27) pg 5 of 8 Rev 6 3.3.5.1 CTS M/U (3/4 3-28) pg 6 of 8 3.3.5.1 CTS M/U (3/4 3-28) pg 6 of 8 Rev 6 3.3.4.1 CTS M/U (3/4 3 32) Pg 1 of 4 '3.3.4.1 CTS M/U (3/4 3-32) Pg 1 of 4 Rev 6 3.3.5.2 CTS M/U (3/4 3-38) pg 3 of 5 3.3.5.2 CTS M/U (3/4 3-38) pg 3 of 5 Rev 6 3.3.2.1 CTS M/U (3/4 3-43) pg 5 of 9 3.3.2.1 CTS M/U (3/4 3-43) pg 5 of 9 Rev 6
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3.3.2.1 CTS M/U (3/4 3-44) pg 6 of 9 3.3.2.1 CTS M/U (3/4 3-44) pg 6 of 9 Rev 6 : 1 3.3.7.1 CTS M/U (3/4 3-48) pg 2 of 5 3.3.7.1 CTS M/U (3/4 3-48) pg 2 of 5 Rev 6 ! 3.3.7.1 CTS M/U (3/4 3-49) pg 3 of 5 '3.3.7.1 CTS M/U (3/4 3-49) pg 3 of 5 Rev 6 1 3.3.3.2 CTS M/U (3/4 3-57) pg 1 of 3 3.3.3.2 CTS M/U (3/4 3-57) pg i of 3 Rev 6 i 1 Rev 6 05/28/99 t l.
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-P&" DEFINITIONS a e- w ' ;,. ...; t; = r : :f> :: 3.The t..d ou; fem. 1r.\.;. . a .u ... J eese defined teradappear in capitalized y and
- !'inti:n: n, i: 29t: :d.
t; applicable throughout these Technical SpecificationsfY74~~ses ;
- d. . '. p at-
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\.bf"'.SI'^*h prescribes Fr'di9 .
-t-t- ACTI hall be that part of a Spec ication -
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ated nditionsf ' _.....__.--..a_.2 der des b
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O Cp tAin g ed [*~?Ut**n '* i AVERAGE PLAflAR EXPOSJAE - shall pplicable a specifi lana eight _, [ .7 ' 1.2 T AVERAGE 4AR EXPOS d is e to the of the e sure of a e fuel r in he soecif d height ided by th umber ffuelrods) specif bundle a in t e fuel bundle f _" b AVERAGE PLANAR LINEAR L:'::'" HEATRATC 3:A! ;G;;^nAT;0% GENERATION APLHGR shall be RATE 'bE" applicable t-+ The AV ".".CE "L"""" to a spec _ific planar height and is equal to the sum of the LI% CAR 3 CAT all ebes Ec. GG;C;ATIO;; RATES for all the fuel rods in the specified bundle at the i* ^8 ht"i" E specified height divided by the number of fuel,ygg,in the fuel bundle. l W '""^' I M, '> 4xb the heif
- = ~ - -
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#ND CHANNEL CALIBRATION-
#^d 4.4- A CHANNEL CAllBRATION shall be the adjustment, as necessary, of the channel output such that it responds with he necessary range and accuracy to known values of the parameter - the channel monitors. The CHANNEL CALIBRAT]QN snali encompass .h: ;nt'r:
- 1. :.., in. ....... , ..d el ;; .;. ::d/_
g tri: L....;;;n;,y;...s.11 9:- J .':e:
..;'.. th CHANNEL FUNCTIONAL TEST a The CHA CALIBRATION may be performed byVany series of sequential,loverlapoing or (toc :n t ' - ; .t...c.. :; ;;?itr:t: M Calierau un l
@ total channel steos-:::5 th:t th:of instrument channels with resistance temperature I
- - thermocouple sensors ';d' :; .;i;t of ;;rt::oftie.; ef ;;;;r:b!'ity ;f the the e--=ining adiustabi I l
. -.m ::n sens.ing-elemerrt er.; edsudmm -s devices in the channel. [
l l ma cani*s t of a n inJ'La Le f**UC*bvt , \ a ss4
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- v-CHANNEL CHECK 4r6- A CHANNEL CHECK shall be the Qualitative assessmen of channel behavior during operation,b.7 et:;r;;;i:n This determinat n shall include, where possible, comparison of the channel indication a G F. status M othe_r indications ameror status derived from independ nt initrument chalinels O measuring the same parameter. A c6s CHANNEL FUNCTIONAL TEST
.3
-h fr- ANNEL FUNCTIONAL TEST shall be/s ### '
o4 atthces 4.3 ~ m th ckmanc i -;. ^r' ; :h:en:15 Sthe injection of a simulate signal into the channel as close to the sensor as practicable to verify OPERABILIT@he+ag regu' red fe >;1:- :nd/:r * -9_:f"a" 4 a" sad e "- :' f;:1... ;.,,,;. cwut - OPEWvalOTY
- b. 9 5 :t 9' c h:-- ' : t'e 'njecti:n f : i =1 :t-d e 4aa=1 En&tYe fenM te ve-4'" DoEPf E ll"v 4 .:!udin; 21:r- 2nd,/ r ty.ip funcMons, %];
L , The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential, overlapping.or total channel steps sootr'that the ntire channel is tested. 42725 o[ 11 endment No. 41 FERMI UNIT 2-
" i PAGE 0F 14 Rc4
l 1 l l SP W & ca%'on i.O l A.i l DEFINfTIONS 1 EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME fo ;
-4rH The 0;G;G;. wns ;ea:e ^,7^T ;;ht CC RESPONSE TIME shall be that time l l interval from when the monitored parameter exceeds its ECCS "W j l , setpoint at the channel sensor until the ECCS equipment is capable of '
l performingitssafetyfunction,(1.e..thevalvestraveltotheirrequired positions, pump discharge pressures reach their required values, etc.) Timesapplicable. where shall include Thediesel generator response starting time may and sequence be measured loading by,any series of delaysf J [ l sequential,overlappingEor total steps that the enu re response time is measured. C k=1 l l + 4e4tThejFRACTION OF LIMITING a given location divided POWER by the spec DENSITY)ified LHGR limit for thatgbundle tFtP9) shall be the LHGR existing 1 type. _ 9 ( FRACTf6N OF DATED THERMAL \_ POWER l l T CT RAT HERMAL PO ( A 0VER Alfided by the RATED THERMAL POWER TP) shal the mes TH[RMA /. % l l FEP)tl - UNIT 2 1 24 Amendment No. 64 l l l l ' PAGE 9 0F 14 Av(g l
l Specoceriou 0 l A./ (. / nrrtutttnut l
. _ .m ....,s NOTATIDM spe d for the p ruance of 5 elllanc 5 ,
g The FREQUE a d --- __ p t P : --- - d +a 'ha inta ah defi--d 4 Tahia 1 41DENTIFIED} LEAKAGE 1.15 IDENTIFIED LEAKAGE shall be: g494 YM kom Le_a1gsp into . .h:th.. ., ;;- .. such astpump sea $ar valve packing {[ p. lear 1, that is captured duct sump e M ollecting tank, or r3- - - - l 2, V. Le e intl the ---*- s sources that are both i sp c fically located anni known either not to interfere wuth the - l operation of the leakage detection systems or not to be WRE55URE4 w__-nmov 4: raract
> @ohnCEAEAGE Emf f Ided'N8d cLN unid8H ed LEAkAGh i 150tATIUM 3 m EM RESPON5E TIME Cf{g.Q -
tit- The ISOLATION SYSTEM RESPONSE TIME shall be that time ' interval fras l when the monitored parameter exceeds its isolation ::fhth setpoint ! j at the channel sensor until the isolation valves travel to their required positions. Times shall include diesel generator starting Incins e and secuence loading delays where applicable. The response time may be measured Dhany series of sequential, overlapping or total steps , that the entire response time is measured. l x
. R00 PA m nn snati k- l 1.17 A LIMITING CONT the core bein on a thermal hydra e a paii.
limit, n ;.;d, i.e., operXr}- ng eit; on M, A,2 i limitino va e far Ap1 W.o f ur.D e Woof LINEAR HEAT GENERATION RATE 2.1^ i;;;;;" :::".' ,;;;;."'T;^Q., "".. 4LHGRk shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over re q uired 6,- the heat transfer area associated with the unit icngth. 6 SYSTEM FUNCTIONAL TEST IO Ml -h49- A LOGIC SYSTEM FUNCTIONAL TEST (shall be a test of all logic componentssh:., -P nhy; : .: ::- ::::, :1' td" weke, seHP s .Q [, M"a '=e al---tr. :t:, of a logic circuit frin}bensor thaeugh.g
-- ^^d including the actuated device, to verify 0PERABILITY. The LOGIC.. 'S u?b bdoot ' $YSTEM FUNCTIONAL TEST may be perfomed by any series of sequential, overlapping or total systes steps that the entire loci ystem is tested. So ru6s_ ,
(MA11MUMFRACT19k0FLIMIT'NGPOWERD(NSITF
'm rearv 1.20 TM "' y n --';;;;G POWEk DENSITyd(MFLPD) shallgj q "d:?t-value of the FLP[hich exists in tty corey
'" [ " ' [ ', ^
- T Li f B1900 Tf
.21 MEMBER (5) THE ruhis snaii ane individual an inuiviousi in .-
is not a d,J 11w d UNRESTR ED AREA. However ER OF TH PUBL1 uring any period which the individual grelves an tional dose.f FERM1 - UNIT 2 1-3 Amendment No. 93 'b PAGE 5 0F 14 fe%
.- l SPEC lPCAnoM l O j
(%.o ut spc; kcake 5. 5 ) \
/
\
- i. n V.I ;
ErtNTTiONS ! MINIMUM CRITICAL POWER RATIO"(<nIphJ) hfMfM h
+22- The i .i-i - -- a i =' E- :
PR l exists in thegcore -(w eac.h +ypTof fue(QHT!D gg DICPR) shall b 0FF-CAS TREA7HENT SYSTEM 1 4x23- An FF-GAS TREATMENT YSTEM is any system des ned and install to reduce 3 r dioactive gaseous ffluents by collecting eactor coolant stem ] ffgases from the eactor coolant and prov ing for delay holdup for the purpose of ducing the total radio ivity prior to lease to the g,-[ vi, neunent . j (p0FFSITE DOSE CALCULATION MANUAL The OFFSITE DOSE CALCULATION MANUAL (00CM) shall contain the methodology ; and parameters used in the calculation of offsite doses resulting from i radioactive gaseous and liquid effluents, in the calculation of gaseous f*C and liquid effluent monitoring AlarsVTrip Setpoints, and in the conduct of j the Radiological Environmental Monitoring Program. The ODCM shall also i s cM4fi contain (1) the Radioactive Effluent Controls required by Section 6.8.5 ! g,$ 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 j ) re utred by Specif! cations 6.9.1.7 and 6.9. --r- g ! OPERABLE - OPERABILITY
. A system, subsystem, t.. er dW/d_" M B' omponent or device shall e OPERABLE or have C j AAl OPERABILITY when it is capabl of cerforming its spec ie? function (s) and MM when all necessary attendant instrumentationp controls, electrical power, D cooling-+r-seal water, lubrication pr other/ auxiliary equipment that are required for the system, subsystem, tea.ta /tomponent or device to perform SPt M itsafunction(s) are also capable of a forming their related support M function (s). of
-0DEnaTIOR 'CGNDiiiGW - C
- 5
+r3&- ^- 0 ER*"0NAL CONDiiiGH, i.... 0MD!'!0._, shall any one inclusive 4,lo combinatio'n of mode switch positio , av aoe reactor coolant -
temperatur as Jpecified in Table d~rekte/ vessel rua
.. I,l-W h4lm thc(gack (eg PHYSICS TESTS sloswt bol+ Wstein 4.I'0
{ 4,U- PHYSICS TESTS ~shall be those tests per o to measure the fundamental I nuclear characteristics of the reacto ore and related instrumentation N5h Wh5
. . described in Chapter 1 of th provisions of 10 CFR 50.59 or et SAR, rwise authorized under the i
i theacommissinn. M vedby[Wpw@3dl43 LEAKAGE ~la l AT'edPqr. ( jN 4 ,34-PRESSURE BOUNDARYonent LEAKAGE *-"wa h a nonisolable
"- '---- throu$1, orfault vesselin wall afeactor/colant/yste body, pipe 7;""~. ;GsTAIeEnT iniiniA Res bf
/PRIMARYCO AINMENT INTEGRIIT isexistwnen:{
s g,l g }
- a. Al primary containment enetrations requ d to be close during 4 l a cident conditions ar either: q l
- 1. ' Capable of bei closed by an 0 RABLE primary ontainment automatic iso ation system, or ,
FERMI - UNIT 2 1-4 Amendment No. RZ,
~PAGE lo 0F 14 gy(,
o
4prh0 C fr o!) - l0
],l DUINITf 0NS 2.
Closed / bya at deactfvated least osatic one y ve manual valve 3 nt nange, or } b secur in i s closed esition, g except for y es that re open er a Inistrati contesi as reitte by Specif cation 3 .3. A.i -
- b. 11 pri r ipment ches a closed and sealed. y
- c. Eachima pr/y yontainee cent inment air 1 k is e /
a compliance with the
. 1x
( reeuirements f Specif atten 3. 3.3. / j 9 [. The primer containednt les e rate are with 'n the 11 its of 5 fficat on 3.6.3 .
. \ 'l.
- e. T supp ssion ri in camp tance wit the re roment of cift tion 3. 2.1.
- f. he s ling chanism ssociat with es primar contairment penet ation, .g., wel s, bell , or 0 ri s, is RABLE.i
- g. The suppression chamber to reactor buildi g vacu compliance with Specification 3.6.4.2. breakers are in 1 f
f THE PROMS $ CONTROL PROGRAM A
- 3. The OCE55
. , 1 ROL GRAM ) sh contain curre formulas, '
sa ling, nalyse , test, dete nations be made ensur hat (M.2 oces g and chagin f soli dioacti wastes ba on de trate proc ing o actual simul d wet so su wastes w be act is a wa s to a ure c ance wt 10 CFR Pa 20, El d 71. 5 att 991 ns, bu al gro require nts, and o er requirements gov,erningj the d posal o solid radioactiv watte. - kE8f PURGING
\
7 --
- 1. PU or PURG Giste-controMedproc V6f disc
.$ ing 41 gas f a
, a enfine t to a sinpNaperatur.a ressor umidit ce os r oth opera con ton, in such a mann hat repl ment a is r utred i urify or gasj e confinement.f- ~-
RATED THERMAL POWER
--h42 ."/* " 7:::sm Ei; shall be a total reactor core heat transfer rate to the reactor coolant of 3430 WT.
RT'P FERMI - UNIT 2 15 Amendment No ff, 52. $7 102 PAGE 7 0F 14 I?ai&
e~ .- QECt1 ICAToots 3.3 2.I O '9L Cu Yh1 b. I (o i REACTIVITY CONTROL SYSTEMS 3/4 d CONTR0t R00 PROGRAM CONTROLS ROD WORTH MfFfMffER , LIMITING CONDITION FOR OPERATION LCo 3 Ml-M,44-The rod worth minimizer (RWM) snall be OPERABLE. N'I TBL lt em 2. OPERATIONAL CONDITIONS 1._ and 2*, when THERMAL POVER is less than APPLICABILIT1: Ior equal to 10% of RATED THERMAL POWERf ty mignum alloyable prpset power JI walg 78L dolc(b) ACTION:
- a. With the RWH inoperable, verify control rod movement and compliance with
$ Q (,g,,j the prescribed control rod pattern by a second licensed operator or other f technically Qualified member of the unit technical staff 5: . ; -- x : Me 0 d'I RtgACY O'l Jstartup ,. L mr usu'reJ The use of this provision during reactor h
i contro t prior to the first 12 control rods being fully withdrawn is C .2. . s .L restricted to one startup per calendar year. Otherwise. control rod I g9 g c.2.. ).; ) g movement may be only by actuating the manual scram or placing the reactor f' Act' C. / mode switch in the shutdown position. g SURVEfttANCE DE0VIREMENTS g Ww u + - in, 4.1.4.1 The RVM shall be demonstrated OPERABLE: M ~
- n = r:w:: :: ec-t-11 SR 3,3. 2.,L i
- a. In OPJJATIONAL CONDITION 2.withint g ,ge.- ; ;;;;;; . ...._, - y _ ; ;o._- s
=r-r 11 iaim and in OPERAT10NAL k g 3,3,2.1.L CONDITION 1 within I hour af ter KwM automatte initiation wnen reducing THERMAL POWER.foyferuying proppr inapaucn p1 Ine stiecuonArror of at; Q,2. hl f ggg y l'q t Qegst one oat-of/secuenef contrarl rod /f' (% 2. ,4 a y3 r
=- a w -i, r ::: :: r=:m' ,k
'3d 34' y'g b. yIn f:-
- OPERATIONAL CONDITION 2 withinta
= ;uranc. m _m - ~ .- m --a m s by
-- verifyine the r a ,4
.u pu i v i ,65 ar block functionyy* Mumuy+r45g aopuy y4 :fayniwipALe r i .
g'g, qgtrai r- m- __ 4a- _ . . D'1W5 8 - on (L
'I\
In OPERATIONAL CONDITION IV.in1_n i nour af ter RWM automatic initt 2 3.3 2.l.1 c. gg when reducing THERMAL _ POWER,9 osmannraying tne wunpaw oigu, anapnser (blocyfunct1ons. f _ -
/.,,* 3
- d. By demonstrating that the S ch d 90:iti.., = .dr.-.. sequence input to the N 3*3 2d 7 RWM computer is correctly loaded following any loading of the program into the computer.
O
/ $/L 3.32.1 l
- Entry into/0PERATIONAL CONDITION 2 and withdrawal of selected control rods is permitted /for the purpose of determining the OPERABILITY of the RWM prior to gg um_a: c ' b r -- ' C - ~ & --- M withdrawal m i<1 . - . , .
of control rodsf a tt 3/4 1 16 Amendment No. /2, J/, 83 FERMI . UNIT 2 PAGE 1 0F 09 Rd lo
3/4.3 INSTRVMENTATTON S k6C l F'I CArTitPd 3'. 3. / ./ 3 /4.3 .1 REACTOR PROTECTION SYSTEM INSTRUMENTATION llMITING CONDITION FOR ODERATION
-hib) As a minimum, the reactor rotection system instrumentation channels shown 1.314 in Table 3.3.1-1 shall be OPERABL
-APPLICABILITY:
ACTION: As shown in Table 3.3.1-1. k ADD AL710N S NoWk _
- a. With the number of OPERABLE channels less than required by the Minimum OPERABLE channels per Trip System requirement for one trip system:#
LC.
- 1. Within I hour, . .ify u,.i inci Functional cn' tl =" h " +3 r I
~
y m re I n an_ : no p yge gg g ena g gg,3 hcTlobl C M *"_ .k ! " . ."..g* ?. ". .
....s '. . ".I'..~ "..t
..,1 gM:: 24~^^" .(Rq%y Res k;p cata bil%.$ ,. .., ......
ACT10blb .
^
' - ' ' ^'
b'b
. ------.- . ... withi
~
hours or tit ACil6N required by Table gggofJ D 3.3.1-1 for the affected ional Unit shall be taken. }
- 3. -!f -'s-iq + ka 4-ar--d'.. .....,,., , y ggA r d - ^. ;... .. . x nr. pl a ce the Ino,,,e p r...
able. . .cIsa n..,,. .. . . . ...nel(s) and/or that trip system in the tripped condition within 12 hours. Q MNO b. With the numbe'r of OPERABLE channels less than require by the Minimum 1 ERABLE Channels per, Trip _5 stem re L/2 b me g e,,, i e one irlp sys irementforbothtripsfstem.hour g ed~cThdit ""on, wit in h{ AcTtorJ A,0 nWGys-TAagrTinN the renuira __ __ ___,,,P-- Y -Win 11 houq &ip chor c%s h n- h-ip N s W 3 _
- c. With one or more Tnannels requirec oy laore 3.3.1-1 inoperable in one C.
or more APRM Functional Units 2.a. 2.b, 2.c or 2.d:
- 1. Within I hour, verify sufficient ' channels remain OPERABLE or kCTION C tripped *" to maintain trip capability in the Functional Unit, and 4CNgg 2. Wiihin 12 hours, restore the inoperable channels to an OPERABLE status or tripped ***.
Othentise, take the ACTION required by Table 3.3.1-1 for the Functional Unit. hfst A.2.Nok l A6 Tion 8 Na0
)) factions a anc b not applicable to APRM Functional Units 2.a. 2.b, 2.c, and 9 l2.d. Action c applies only to APRM functions 2.a. 2.b 2.c and 2.d.
u
*gmn,ya.ups.ugJn.nngn,www.nuypepi.c7,,n e,nt. term n, , .s., 6sy trioom,ou mnyt-n wnereevjyij .
.. 7 n , ,,,,,,, so.mo. .n.., g,,
er/the cbyianndl was fir [,t 6u vr bestu[,ed eter t n [os. inn dr.. able...drinA hc -ACTION
^ - , N required lable 3.3.1-1 for that Ach,nD
*^ Functional Unit shall be taken.
pn 6cip afst,m ursy nut u- n: : - . - - . c r _: ->4 ni al 4' icause 4 tersta tn ne u r/pg n , ,, ,, g - *_ ;;m ; ;:-_
, 3 a ;- " , , , , 7, ;^ ^, , , ,
^
ny a scram to o ur, place tite ip system wit th
~
p.n.. ..n -,6nvu. ... most noperable chann s in the tripp d condition: if oth systems hfve th na rP T sa him eksnnoit numoer- of inane' __ _. b - _ " t- - are either tr svetem in the/trinn
'*" Anwould i noauserabieacnannei scram ton occur. o not be ln placed thes cases, in theif tripped the i cerable dition wnere thi ]
not stored to OPE E status withi the required.ti channel ,k L by , the ACT]ON re red, ble 3.3.1-1 for the Functional it shall be ta nf-FERMI - UNIT 2, 3/4 3 1 Amendment No. 75, D. JDS. 1 2 PAGE '-l 0F 11 /W(o
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ee I. L mvFL ins ot l m da N: t c t i w s a Cys" v r i o t u a nMK lei : a . fv A ae g r a,i t I. b K n 3 fl rL r bl ch u g oR P - . ad e*. q e 0 c . . u rC aS n i trI A" s0n t u r cll twe i. a:m nN u e a - . hl 3 l i S ab l T R M n uedn eh Nt au n i h00 k h t c - t t o C T Cr t n : if I N E#u B I i r F 8 9 0 1 2
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4, QEC I FickTiod 3.3.( .I lW SZ/ .hCIhCQMor 3*3*(e.'2 INSTRUMENTATION 3/4.3.2 ISOLATION ACTUATION INSTRUMENTATION ,l tIMITING CONOTTION FOR OoEDATION 2 LC'l 4-D-f The isolation actuation instrumentation enannels snown in Table 3.3.2-1
..u. _ /7,/
eir trip set column ble n6a >=6 an of 3.3.2-2. [>
.m W. [ i. d..
gshall na-n bein OPERABLEIUTthfint ea- ma (=' l APPtfCA9ftfTY: As shown in Table 3.3.2 1. g h 00 AC770A) NOTE / '
- a. With an isolation actuation instrumentation cnannel trip setpoint ,
4c.T109 M less conservative than the value shown in the Allowable Values [( De( .(OpstA6uly) channel is rettored column of Table to OPERABLE status 3.3.2 /witn its/ 2.trio declare setdoing the - channel 4 inocerable u 4 UdjusteVeenststent M n tne Trio de<ooint vaK e f With the numoer of OPERABLE cnannels less than reoutred by the b.
. Minimum OPERABLE Channels per Trio System reoutrement h . .... A k kC T10M b M @hau.cloM Arid
- 1. If p' cing tne inoperaole annel(s) in the tr1 d condition wou cause ar. isolation, he inocerable enann (s) shall be r tored to OPERABLE sta t/within nours or tne ALIlon reoutrea by Table 3.3.2-1 f or the ffected trip function shall gM b be taken. n ,, N ' Aq
- 2. f placing i inoperaote gnannelts) in tneArioped conai) Mon would not se an isolatybn/tne inoceraone enannet(s)Wnd/or that trio stem /snall oe placed in the tripoed Condition within:
$sptAgg wers ruwn/ri :dh ,
a) 12 hours for trio functaen common to RPS Instrumentatto . and b) 4 24 hours for trio functionfot common to RPSggpM instrumentatio$ wm rwnd d 'j
- c. With the number of OPERABLE cnannels less than reouired by the Min OPERABLE Channels oer Trio System recuirement(f r tet" m o' '
C4
,Chr M 1:rt : ; w , dr- -- n ....._m kCilONb>C. ' within one nour amp tate the ACTION reouired_ov laole 3.3.2 1.
N es tirec. el o to h' art ca/wh//ih D-
*Plac ne trio system 4 wit / tne most inocerable enandels) in the trioDed ]
_ cond i on /fi ny tr w > r > 6 =m 7. o.. w. up m . . .. f i . ., m . .; . y . . . . . . p.. ; a puia cadfie tee itolatwn ta e m.e /r . J FERMI UNIT 2 3/4 3-9 Amenor.ent *.o. /l, 75, 23. 100 p;h
-l PAGE / OF 13 g
$PEcocAnad 5.3 G Z-
[A(So sec. QeciOcafian 3.3.G.l) INSTRUMENTATION 3/4.1.2 ISOLATION ACTUATION INSTRUMENTATION
/
[TMITING CONDITION FOR OPERATION LLO 3,3.G.2 -t-th+- The isolation actuation instrumentation channels shown in Table 3.3.21 gA. I shall be OPE _RABLE ynn 6n. u.y .wo. 6. av6 consi ~nt witn tne v yuesj ynown in trys irip setootn column of T e 3.3.2 2. j APPLICARTLITY: As shown in Table 3.3.2 1. M MdTIO N M 075
- a. With an isolation actuation instrumentation channel trip setpoint a n less conservative than the value shown in the Allowable Values
/RTlch) ri column of Table 3.3.2-2. declare the channel inoperable until the a h its t.1ppetpoirfy
[g De{ of DrftA61tITV)(channel adjugea consistent is restored with to tne OPERABLE irto seto statuslw t valuea [A./
- b. With the number of OPERABLE channels less than required by the C (s Minimum OPERABLE Channels per Trip System reautrement sv. un= 6 r i p_
[t,TlOA)k V y frggggy =_ - _ - - - (_ Place channel inkit)
, ii scing tne in trable channe s) in the trippeo oncillo ,
wo d cause an i ation, the i carable channelfs shall - i 1 r stored to OPE LE status /WTthin ours or the ACTION 'k required by lable 3.3.2 1 for the ffected trip function shall k l CU6AJC be taken. /2 W lCA Z. If acing the inopurpiar wn nns'.iaf in ins 6pipptQ Co w d not cause an ilolation, tne inoperable /channelf s) na . 46 at trio system khall De placed in the trippec condition within:
. . rdEPLACE V0% funeT14Q th$
a) 12 hours for trip function coninon to RPS Instrumentation) V b) 24 hours for trip function 01 coninon to RPS
$ @EPLACG Wolu FhcyM Q
- c. With the number of OPERABLE channels less than required by the f1 kgf m Minimum OPERABLE Channels per Trip system reautrement W. 2:r Mio r1 : = _ . _ _ :- --
,V (*l T
!y 8
within one hou take tne A_CTION reoutred by Table _3.3.21. Q isola % capWIHy okV LC.\ P1 one trio
- stem iwun 1n 7 mm. rd e uianne m m Er timo
.E. , t }nn Ip, .... ...; ;, p ;;:
, ins uigg.o unu u .yu .,
.y FERMI - UNIT 2 3/4 3 9 Amenoment No. 41, 75. 23, 100 PAGE ! 0F 08
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- .i (Continued) 150lAiENdTUU10N INSTRUMENTATION g isocce msW ACTION STATEMENTS ACTION 20 - Be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN /7 AC% % Gr within;-the rg eaunext= : 24 x- hou drsthe associated isolation valves close A cnDM D ACTION 21 - i within@ hours or be in at least HOT SHUTDOWN within 12 hours a in COLD SHUTOOWN within the next 24 hours. -g,g l ACTlon r ACTION 22 - Be in at least STARTUP within 6 hours.
ACTION 23 - Close the affected system isolation valves within I hour A.q MTion p 3-g ..
- u 3ts ,+3a ,y.+. 4 ...gie Su
*cistdow ACTION 3141 g4 Estaoitsn SECONDARY -,
CONTAINMENT operating within I hour. INTEGRITY with the standby gas gog p ACTION 2 - pi;;t!: d the closeo position the affected system isolation valves within I hour ed ::cler: ': :"r* $r-- '*:' ' ; ;;;; : f ""
':;;;.;bie. l,Q,4
- K tore t manual innia on f unct)ClyLo UVLKMLL status nnin q ;
j EllUN Zb urs or ose tne affee o system saa seriar. , ess tr a g t: if:lation _ :- :valves d , wit ' th/e l' ort han_ g ,( ( ACTION.b _xestore the manual hours or establish initiation SECONDARY function toINTEGRITY CONTAINMENT OPERABLE with, thestatus within 8 ppgg\ Stan Treatment System operating. g,g TABLE NOTATIONS C*When handling irradiated fuel in the seconcary containment, during CORE L ALTERATIONS, or during operations with a potential for draining the g reactor vessel. 1.
'The high condenser pressure input to the isolation actuation TBL 3.% l-1, **
Nok, (a) instrumentatinn may be bvokssed durina reactor shutdown or for reactor startup GFIeMondensepfressure gaoove the tpfp setootnM g g 3,, Actuates dampers shown in Table 3.6.5.2-1. psMicahe. 5361 { ,( (a) A* channel may be placed in an inocerable status for uo to '=2 6 hours--for " reouired surveillance without rc;;r n: = a . m .m . 0, & - - --'oroviceo 9 - .. - .. . z n-
=a *g g*g SOJ0TE 7-(-^
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-::.. x :ti .. ' r ...., ..ive u, D@E"f"LE :-d :" :: Pre ut=t unC4f"5ne channel may- -- i -
oe placed in an inoperable status 8 hours for reautredstxx c surveillans[p nr.nnn r ithua nucino = gn ' : - - in: Su; c b) Also starts the standby gas treatment system. N A channel is OPERABt F if ? nf a Mot entnet s 's that enannel are OPERABLT:y-
'@ ":' : t; . m M C. ; s i. .--
3/4 3-14 Amenoment No. 4 , 75, 102 FERMI - UNIT 2 _J PAGE- /p op _ y3
.2 SPEC % cAn erJ 2,3 6,. l (Also Su Spe;Cea tim s.3.S,2.)
" ': : 2.: i (Continued)
ISOLATION ACTUATION INSTRUMENTATION TABLE NOTATIONS (Continued) l [vridim if) A tes with simui neous KLIL 5tenin supyy Pressure-Low (Iso tio 4E 1 trumentation) Orywell Pressure Hig6 (ECCS Actuation nstrumentation) bCNM
~
) t nes witn simu aneous NFLA steam p6y Pressure-Low tI ati /g, i
~3 e, uation Instr ntation) and Drywell ressure-High (CCCS tuatton Q nstenmentatin f I
(h) bstri tunction is ce ved n redundant from inree flo sunner. non ecundant InoperaDi ity of theflow transmnttiers non-recun and a
- tre try causes the annels in both tri systems to be inoper le. }
Ine emainece. of th eter"" " --cu-c'
- rr :- :: ::-Me- c -- '
s d Both trip systems may be placed in an inoperable ; trio system en gR 407614 estatus for up to 2 hours for recuired surveillance of the non recuncant .. circuitry without tak1ng tne reoutred ACTION provided that the remaincer of the Reactor Water Cleanup System Isolation channels (except the SLCS Initiation) are OPERABLE. ec ta (i) Seconcary Containment Isolation Push Duttons. f _rji nainted f Vth time gelay of $ secon@ b Thes( trio function (s) a/e common to the PPS trip functi h 40.3 3/4 3 14a Amenoment No. 41, 75, 76, 102 FERMI - UNIT 2 gs PAGE 7 _ 0F 13 MV b
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j ~,- 1 l l D'EC I ric A v o ^/ 3.5,5,1 kiso see $cificqggn 3.3,g,j) 7.3 5.H l TABLE :.:.:-i (Continued) EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION l
. ACTION STATEMENTS J ON 30 - With the nuncer of OPERABLE channels less than recuired by the M OPERABLE Channels per Trip tv"a= caoutrement: A.lO N' \ r- 30's + rip <ti um o /'
% or one trio system- niace that trip syuwm in h ripped ACTied 84 Ch a, A cuo" a gaa"*E3 . L 3 .. gna T.h 2r conditionwithinCl4hourslorde(lare$neassociatedE w For both trip ds declare the associated ECC5' yy $.b #
- 1 h' 4N bd -
k S.Lf< l 'Ha* .. . . f i ACTION 31 - With the numoer of OPERABLE channels less than reoutred by the 10 Minimum OPERABLE Channels per Trip System reoutrement. declare l gga y g .2 3 6.1 associated ADS Trip System inoperaole within 24 hours. .1 Amoua u n u ,. w . 4.. ,c ACTION 32 - With the numoer of OPERABLE cnannels less than reoutred v the _resvg A.I 1 Minimum OPERABLE Cha nels ce Trto System reouir_emen __ l REA Act C.'2 _ hours. gov j e.,,w g g , y gg , 4 g Q*go ACTION 33 - Restore the manuaI initiation and/or manual inhibit function to lI KE4 @T 4,2, OPERABLE status within 24 '..ours or declare the associated ECCS or ADS Trip System inoperable. gtg % y A60 REh tne Ac.T D iofalOPERABLE G. i e ACTION 34 - With number channels less than reautred by the REdct D.110.t'2 Minimum least one inoperableOPERABLE enannel Channels in the tripoed per Trip System condition within reautrement, place a 8 l 3 24 hours. align the HPCI system to take suction from the suppression pool, or ceclare the HPCI system inoperable. A CT10td H ACTION 35 - /N the number of OPERABLE channels: One less than the Total Number of Channels, restore the v, operable enannel to OPERABLE status within 72 hours or l datlare tne associated emeroency ciesel oenerator Inoperable ano taxe the ACTION reoutred by Specification {P4. 1.'.l.l.1 or 3.B.1.2 as appropriate. ih(Clh'n1 b. Less than the Min 1 mum Channels OPERABLE reautrement,
- ' declare the associated diesel generator Inoperable and g' g ,7* / take the ACTION reautred by Specification 3.B.1.1 or i
3.8.1.2, as appropriate. l l l 3/4 3 26 Amenoment No. 35, 73. 83 FERMI - UNIT 2 PAGE C 0F 08
/fev 6
5PeC t P tekn ord E33I Also sat. Specilicab 3 3.5. 0 j 6 Continued) EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION ACTION STATEMENTS ACTION 30 - 91ththenumberofOPERABLEchannelslessthanrecuiredbythe I Minimum OPERABLE Channels per Trip System requirement:
- a. For one trip system, place that trip system in the tricoed condition within 24 hours or declare the associated ECCS !
inoperable.
- b. For both trip systems, declare the associated ECCS inoperable.
6LL 10N 31 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System reoutrement, declare i i cgg 3 N the_ associated ADS Trip System inoperable within 24 hours. l 3351 TION 32 - With the number of OPERABLE channels less than required by the Minimum OPERABLE Channels per Trip System reautrement, place the Inoperable channel in the tripped condition within 24 hours. ACTION 33 - Restore the manual initiation and/or manual inhibit function to l OPERABLE status within 24 hours or declare the associated ECCS l' or ADS Trip System inoperable. ACTION 34 - With the number of OPERABLE channels less than required by the l Minimum OPERABLE Channels per Trip System requirement, place at least one in perable channel in the tripped condition within i
;, 24 hours, align the HPCI system to take suction from the
%.;iuppression pool,. or declare the HPCI system inoperable,
'! {
j ACTION 35 - With the number of OPERABLE channels:
- a. Cx 1rr* tt . P: '; _ Number of Channels, restore the ( !
inoperaole enannel to OPERABLE status within 72 hours or hC, Tion 4 % oeclare the associated emeroeney diesel oenerator j inoperable yo (3.B .1. 4 or ,B Ar,ne
.2, the ALilVM req as aooroprt 51 red Dy specifiration/ Q*
ge.f
- b. 9 ::- "-+h- ""--5ChannelsOPERABLErecuirement, (1 )are the associated diesel oenerator inocerabi n OCT70d U takunne AL610N reotyreo Dy specificapn 3.8.1.1 or
.Y.l.2, as appronoiate.f j
l l Amendment No. 35, 7J, 83 ! FERMI - UNIT 2 3/4 3 26 l 1 PAGE d 0F 0S
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/0 08 PmL$ PAGE 0F Revlo
a? Spec ses cariou 3.3 m I INSTRUMENTATION 1/4.3.4 ATW5 RECTRCULATION PUMD TRIP SYSTEM INSTRUMENTATION l l tiMITING CON 01T10N FOR OPERATION t:T;M"system
- L,(o J.jS,l RPT) The anticipated transient without scram recirculation pump trip ( ATWS-instrumentation channels shown in Table LL4-1 shall be OPf_RABLE 6 rip s oinu >= 6 co u6=n6 wun sne sutues sr.wr inen= iri g*j ;
l (witnSe[nuirntcolumno[eable 3.3.4- bn-Appt1CAstt1TY: : OPERATIONAL CONDITION 1. EllE ~[ Apo AcT7ous NO7E )
- a. With an ATWS-RPT system instrumentation channel trip setpoint less :-
- ScTinN A conservative than the value shown in the Allowable Valuesra" column a -d ta of Table
) l .( b 4 U C D U y OPERABLE 3.3.4-2, status declare in the enannel 6. inoperable sountil theconsistdt channelwithL it - }.h . l i
tne ww.....e .,. ,yvint mstaa l' Cthe prio setoni[value.1 i f i-404 Rf4 vid50 AatoN A.7. Note - With the numoer of OPERABLE enannels o(ne less tnan reoutred ,y by the b. Minimum OPERABLE Channels per Trio System reautrement for one or cath ( ALIIDN 4 trio sy a place the inocerable cnannel(s) in the trtpped conditioni 4 daqQ-within . With the numoer of OPERABLE channels two or more less than reouired by Y the Minimum OPERABLE Channels per Trip System requirement for.one trip g ACDd b c. g g system and: 1 1. If the inocerable channels consist of one reactor la vessel water h/r'- level ~ I channel and one reactor vessel pressure enannel, onor, if inoperable enannels in the tripped condition within this action will initiate a pump trip, declare the Ptp system inoperacle.
- 2. If the inoperable channels include two reactor vessel water level channels or two reactor vessel pressure channels, declare the trip system inoperable.
-a V_M*Y337
{d h bel i
- d. With one trio system nocerable,/festore the inoperable trip system to 2
OPERABLE status withinhfor be .in at least STARTUP within the next e bCTTON bg6 hours, j gg m p,y g gg g rabi , restore at least one trip system to ON Oe .'. With both trio systems 1 or ce in at least STARTUP within the next 6 l OPERABLE status within Set \D$'#N P"f b'* 8""'"' ' #') d# N k h ; i 32 1 M ,l.) 1.2.,.;- Each ATWS RPT system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK. CHANNEL FUNCTIONAL TEST and go,3. .i s CHANNEL CALIBRATION operations at +ne frequencies snown in Table 4.3.4-1.
' g g 3,3,4,3,3 e LOGIC SYSTEM FUNCTIONAL TESTS 6 J......n: __=:n : :;rn n :" G - <
$'R 3.M.I .4 y.3. , . :shall be performed at least once per le montns, g gg cACAue en h
3/4 3 32 Amenoment No. 55 FERMI UNIT 2 PAGE / OF 04 by (o
)
1 5 PEC l Ft cAnoy 5 3. 5,'L 1 Lco 3.3.5,L l l TA"LE 2.2.5 MContinued) REACTOR CORE ISOLATION COOLING SYSTEM i ACTION STATEMENTS ACT:C.1 LO - With the number of OPERABLE channels less than reouired by the
, Minimum OP RABLE Channels per Trip System reautrement: Aj' j
~ .
g ACT100 8.gC- - -.(Re3For
- a. one t to systemTjplace tne inoperable enannel(s) 1
)
- - - - - - - - trip system in the tripped condition ;
ACTioed 6- , , And/or inatnaurs g ceclare tne MLAL system inoperacte. in[2R . - g Rea Ac.mocJ 6.I b. For both trip systems, declare the RCIC system inoperable. thove L.l k AC7;en Li - With the number of OPERABLE channels less than reautred by the Minimum OPERABLE Channels per Trip System reautrement, place at ' l ACTled n least one inoperable channel in the tripped condition within 24 l u hours or align RCIC to take suction from the suppression pool I
# ".eciare the RCIC system inoperable. [Appggap,,yggp,i l g,Q, A CT10t0 E
=:= :s n = = : = = . . = : = = r. . ; . . . . ; . ::: =. : . . . #.
w: --- lt un :r =i= = '::: ;y n;; =s;re;;; LAS 1 l l I FERMI - UNIT 2 3/4 3-3B Amenoment No. 75, B3 PAGE 3 0F 05 Rev6
l Sf G CI F/pf70A) 3. 3. 2. l LCO 3.3.2.l T'O E 3.; ~d (Continued) CONTROL R0D RLOCK INSTRUMENTATION ACTION STATEMENTS C5CTIONA0 - Declar/the R8M inoppfable and tahrthe ACTION reAGired b L 5nacMic_ation 3.1.K3. / ~ '
^
(ACTION /I-With he number or pruuufLE annels. I la One less than requ 1ed by the Minimum 0 RABLE Channels per Trip Function re resent, restore the inoperable chan"el to O'I I l OPERABLE status ithin 7 days or pla the inoperable k.2, channel in the ripped condition wi in the next hour, f i b. Two or mor ess than required by he Minimum 0PERABLE r Trip Function requi ement, place at least ne ) l Channels i 6perab channel in the trion d condition within 1 our). ACTION 62 - ith the number of RABLE channels less tha equired by in f.4 Minimum OPERABLE annels per Trip Function equirement, p e the inoperable cha 1 in the tripped condit within 1 houri R5 bod arTtan.43 . With the number of OPERABLE channels less than required by the 6 ft d MinimumOPERABLEChannelsperTripFunctionrequirement,['-itiate] e-fed-M*eh lk
- I TABLE NOTATIONS sQ .1 g,3[t f
- With THERMAL POWER greater than or equal to 30% of RATED THERMAL POWER.
l E ith more Jhan one control N d withdrawn. Not 3pplicable 19 controp" g,q iade rended per Specificafinn Lt 10.1 or 3.V.10.2 r N A00: tt no Fren
'3 33 Ll Y (e) The swivura RBM or Int shall bej t :tte:11; bypassedjwhen,e n
t"- p)eri(ne=ui of RATED N contro THERMAL POWER. greterence aran enavnel indtlates ht:
' Cum.b oO -- 4>------ 'i function snurr-es ... m;;;11y Lip ;;;l if etect..
Th __..t f.te '
> 00 cps or the IRM cha als are on ran 3 or higher.
c) his funct n shall be tomatically b assed when the sociated channels re on range or higher. I d This fu tion shall automatica11 yeassed when t IRM cha als are R'1 e 3 or hicho . /-- E on ra u
~
on anai av snosaucg6y pyps..wd wu'ss i'sn inn cnanne.rs arujL
~ 5;; 0;.
Disp._ n,Te;ification [,- 9.2. fL,v. nw.aors shall Jnr OPERABLE 8. ' of reautreo myq l
- i FERMI - UNIT 2 3/43-43 Amendment No. H.112 PAGE 6 0F 09 g
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