Text

Rev 11 to ITS Submittal,Dtd 980403,providing Update to ITS Sections 3.5,3.6 & 3.8
	ML20216D609
Person / Time
Site:	Fermi
Issue date:	07/26/1999
From:	; DETROIT EDISON CO.
To:	;
Shared Package
ML20216D597	List: ML20216D609; NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS;
References
	NUDOCS 9907300038
	Download: ML20216D609 (200)
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Spc,fEdkn.14. 8 (Also see spwGea&on e.toD REAC73R COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL HQlJHUIDOWN

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LIMITING CONDITION FOR OPFRATION kCO -3.4.9.! TwoI shutdown cooling mode loops of the residual heat removal (RHR) 3.46 system shall be OPERABLE and, at least one recirculation pump shall be in o eration or, at least one shutdown cooling mode loop shall be in operation *88 witn c cK loop consisting of a least:

a. E RH ump, nd '

/O

. ne ERABL RHR heat exce g/

APPLICABILITY: OPERATIONAL CONDITION 3, with reactor vessel pressure less than the RHR cut-in pennissive setpoir.t.

E.TlDtf:

{Md Acfion s Hole 4 th less than the above required RHR shutdqvn cooling mode loops OPERABLE, insnediately initiate corrective action to return the

/ho.fy / required loops to OPERABLE status as soon as possible. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months fod'atAeait-onca-eer 2Lhours-thereafterX verify the M,} j OFIRABILITY of at least one alternate method capable of decay heat I removal for each inoperable RHR shutdo ooling mode loop. Be in at least COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 4r.-'- With neither a recirculation pump nor an RHR shutdown cooling mode loop in operation, immediately initiate corrective action to return \ l l

either at least one recirculation pump or at least one RHR shutdown

[c,f/ON-vR e

cooli g mode loop to operation as soon as possible. Within I hour establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per fchronSAdC$

1 3'q,g j -er' The provisions of Specification 3.0.4 are not applicable for up to 4 9- Ds hours for the purpose of esteslishing the RHR system in the shutdown NOW cooling mode once the reactor vessel pressure is less than the RHR cut-in permissive setpoint. A SURVEILLANCE REOUTREMENTS S --44.5.1.1- At least one si.utdown cooling mode loop of the residual heat 3 , g, g Y reinoval system or at least one recirculation pumn shall be determined to be in M operation and circulating reactor coolent at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . g

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9 LLO 3%

rJ of t '3-I0ne RHR shutdown cooling mode loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing, geo 3 f. [*The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months l g,te I i per 8-hour period.

i Me } 88The RHR shutdown cooling mode loop may be removed from operation during hydrostatic testi Dg, ~

-4*hpfioft o, ) *Wh'eiseve'rToWl(H'R shutdowrt cooling mo' d eQoops are t rable, i ablesto M

e'i'\

s ON, main ctor ntN 'l attain COLDasSHUTDOWN emperature as requ low a't_pr_actic,aQy use Qd of by al this ACT (ternate1 heat met rem.

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FERMI - UNIT 2 3/4 4-26 PAGE / _OF 02. MI 9907300038 990726 PDR ADOCK 05000341 p PDR

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DISCUSSION CF CHANGES ITS: SECTION 3.4.8 - RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN ADMINISTRi1TIVE A.1 In the conversion cf the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Tecnnical Specifications (ITS), certain wording preferences or conventions are adopted which do not result in technical changes. (either actual or iriterpretational). 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 3.4.8 adds Note 2 to the Actions " Separate Condition entry is allowed for each RHR shutdown cooling subsystem." This Note provides explicit instructions for proper application of the ,

Actions for Technical Specification compliance. In conjunction I with the ITS 1.3 " Completion Times," this Note provides direction consistent with the intent of the CTS Actions.

Therefore, this is an administrative change with no impact on safety.

A.3 CTS 3.4.9.1 Action a. requirement to periodically verify (at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after an initial verification) the Operability of an alternate method of decay heat removal for each inoperable RHR shutdown cooling loop is unnecessary since the Action also requires that the plant be in Mode 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (i.e., exit this Specification). Once in Mode 4. CTS 3.4.9.2 and Ils 3.4.9 require the periodic verification of the availability of an alternate decay heat removal method. Since there is no change in the technical requirements from this change, this is an administrative change with no impact on safety. j a

A.4 Not used. l*

. B s ,

i FERMI UNIT 2 1 REVISION 11. 07/14/99l 1

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DISCUSSION OF CHANGES ITS: SECTION 3.4.8 RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN TECHNICAL CHANGES - MORE RESTRICTIVE M.1 CTS 3.4.9.1 footnote "**" states that "Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this' ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods." This y footnote is being deleted from ITS because it provides unnecessary Q duplication of the Actions. contains no additional restrictions on a the operation of the plant, and could be interpreted as a 4 relaxation of the requirements to achieve Mode 4. The Action to be in Mode 4, which is modified by the footnote, adequately d encompasses the requirement to make efforts to " maintain reactor coolant temperature as low as practical." If conditions are such that Mode 4 cannot be attained, the Action remains in effect, essentially requiring efforts to reach Mode 4 to continue.

Elimination of the potential relaxation is a more restrictive change with no impact on safety.

< TECHNICAL CHANGES LESS RESTRICTIVE "Generi c'*

LA.1 CTS 3.4.9.1 LCO details system design. ITS 3.4.8 requires that RHR SDC be Operable, but does not detail 'the system design. This is acceptable because the system design does not impact the requirement to have the RHR SDC system Operable. Therefore, these details can be relocated to the Bases. 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. This relocation continues to provide adequate protection of the public health and safety since the requirement for RHR SDC Operability continues to be required by the Technical l Specifications. -

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FERMI - UNIT 2 2 REVISION 11. 07/14/99l

DISCUSSION OF CHANGES C

ITS: SECTION 3.4.8 - RHR SHUTDOWN COOLING SYSTEM - HOT SHUTDOWN LR.1 CTS SR 4.4.9.1.2 requires that "At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months verify the required RHR. shutdown cooling mode loop (s) are capable of taking suction from the reactor vessel through the RHR heat exchanger (s) with their associated cooling water available." This is essentially equivalent to " verify the required RHR subsystem is Operable." ISTS surveillances prescribe specific acceptance criteria or require verification of a specific feature: but ISTS surveillances do not require non specific verification of system Operability without specifying details for this verification.

Tracking the status of system Operability is an ongoing activity. 9 Therefore, the requirements of CTS SR 4.4.9.1.2 are removed from lp4 Technical Specifications consistent with the NUREG 14J3.

Regulatory control of changes to these requirements (e.g.. d 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 RHR Shutdown Cooling system Operability continues to be required by the Technical Specifications.

TECHNICAL CHANGES - LESS RESTRICTIVE

" Specific" None RELOCATED SPECIFICATIONS None 1

TECHNICAL SPECIFICATION BASES l

The CTS Bases for this Specification have been replaced by Bases t' hat reflect i the format and applicable content of ITS 3.4.8 consistent with the BWR STS, 1 NUREG 1433. Rev. 1. ]

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FERMI - UNIT 2 3 REVISION 11 07/14/99l i

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i ECCS -Operating .

3.5.1 i

SURVEILLANCE REQUIREMENTS FREQUENCY j SURVEILLANCE 7 days )

SR 3.5.1.1 Verify correct voltage and breaker alignment to the LPCI swing bus.

SR 3.5.1.2 --- - - -

NOTE -- - - - - - -

When LPCI is placed in an ino erable status

% solely for' performance of thi SR, or when the LPCI swing bus automatic throwover Q scheme is inoperable due to EDG 12 being d paralleled to the bus for required testing, 4 i entry into associated Conditions and -

s i Required Actions may be delayed up to 12

% hours for completion of the required 9 testing.

Perform a functional test of the LPCI swing 31 days bus automatic throwover scheme.

I SR 3.5.1.3 Verify for each ECCS injection / spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

(continued) l FERhI UNIT 2 3.5 4 Revisioit'11. 07/14/99 l 1

1 SPECIFuctiT'ord 3.T.1 EMERGENCY CORE COOLING SYSTEMS LIN TING CONDITION FOR OPERATION (Continued 1 ,

El23: j 3, g, l a. For the core spray system:

1. With'oneCSSsubsysteminopgrable,providedthatatleastoneLPCI MT/04' A -

pump in each LPCI subsystem is OPERABLE, restore.the inoperable CSS subsystem to OPERABLE status within 7 days or be in at least l

HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within

_ A C7/10M D the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

1 A.gfog . 7 2. With bo Lh CSS subsystems inoperable, be in at least H " SHUTDOWN d

hours. L.I within Q ours and in COLD SHUTDOWN within the next

b. For the LPCI system:

1. With one LPCI pump in either or both LPCI subsystems inoperable, A c.7/06). AS provided that at least one CSS subsystem is OPERABLE, restore the inoperable LPCI pump (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD A C.7IO N D SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A cy,od 4

2. WithoneLPCIsubsystemothgrviseinoperable,providedthatboth CSS subsystems are OPERABLE , restore the inoperable LPCI subsystem to OPERABLE status within 7 days or be in at least HOT RTtod o SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

3.

A C7/0M .T hith DOWNa LPCI

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system cross-tie valve closeM in at least HOT

~~

within @ours and'in COLD ~ SHUTDOWN within the next@

hours.

N-

\

A ( 4. With both LPCI kubsystems otherwise inoperable, be in at least HOT

/f CTIO N J SHUTDOWN within @ hours and in COLD SHUTDOWN within the next hours.*

$ Q 3.6.1, b 5. diie orovirions of snecification 3.0.4 are not annlicahTb for up to gg 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the purpose of estab'ishing the RHR system in the Lru Qg mode once the reactor vessel pressugis greater than the RHR cut-in permissive setpoint.4in Mo0E- 3s A(,Tiord 7

c. 3i F,ortheHPCIsystem,@IRABLE:rovidedtheCSS.theLPCIsystemQtheADSand i

l2 fcTjorgf i the RCIC system]are OP 000 ACTipJ F

1. With the HPCI system inoperable, restore the HPCI system to -

0c7,gg g OPERABLE status within 14 days or be in at least HOT SHUTDOWN $

within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to o

. s 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ,

[*When r two or more

^

subsystems are ino as reovire y this ACTION, main ble, if unable reactor coolant t ttain COLD spar 2 NrV r-h']8 :

E "3

inw me net. y m e ef e'te-este _st -e - e1 d ~te l Acnogl- C #_xcept f one Cis subsys_ tem and one LPCI subsystem may be inoperablefdue to a lack'

'oTIECW coolin3 provided the(Aliivn3 vi 5pecific sion a.i.a.4 are taken.

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( App AcTier, c )

,,_ FERMI - UNIT 2 3/4 5-2 Amendment No. J,80

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PAGE 4 0F 10 bI,

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DISCUSSION OF CHANGES ITS: SECTION 3.5.1 ECCS-Operating

]>.

5 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 change,s (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.

O A.2- Not used.

A.3- CTS 3.5.1, footnote "#" to the Applicability. references CTS v -

3.10.6 Training Startups, which allows a relaxation to the requirements for ECCS system Operability if certain conditions are j maintained during training startups. ITS 3.0.7 adequately' prescribes the use of the.Special Operations LCOs and eliminates i the need for this " cross reference." - Elimination of this L reference is an administrative change with no impact on safety.

A.4 The CTS provides a specific Action for LPCI cross tie valves closed. The ITS recognizes that both LPCI subsystems are inoperable with a LPCI cross tie valve closed (ITS Bases specifically discusses). Therefore both the CTS and ITS Actions for LPCI cross tie valve closed are the same as for both LPCI subsystems inoperable. This administrative presentation

- preference to eliminate specific treatment of a closed cross tie valve, and allow the definition of Operability to accomplish the identification of the appropriate Action does not result in any -

technical changes. Therefore, this is an administrative change with no impact on safety. -

y A.5 Not used. l

&O*

FERMI UNIT 2 1 REVISION 11 //14/99l

l DISCUSSION OF CHANGES ITS: SECTION 3.5.1 - ECCS-Operating A.6 CTS LC0 3.5.1. Actions a.1, b.2, and c, for inoperable ECCS subsystems, contain a footnote "#" allowance for one inoperable CSS subsystem in conjunction with one inoperable LPCI subsystem. This allowance is intended to provide 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore one or more of these inoperable subsystems when certain other provisions are met, i.e., the Actions of Specification 3.7.1.2 are taken. These other provisions of CTS 3.7.1.2 are addressed separately:

1) CTS 3.7.1.2. Action a.1: The ITS presents a new administrative control in Section 5.5, Safety Function Determination Program. This Program implements the same verification required by CTS 3.7.1.2 Action a.1.a). The verification of ADS Operability is addressed with ITS Conditions H and I.

2) CTS 3.7.1.2, Action a,2: The intent of this CTS Action will be addressed by ITS LC0 3.0.6 and the ITS Safety Function .

Determination Program. The relation of the CTS Action to the ITS requirements will be addressed in detail in the Section 3.7 package.

For the purposes of identifying the appropriate Actions for inoperable ECCS, this CTS Action only clarified that other actions are alto applicable. This intent is considered generically applicable, and is enforced without explicit statement in the ITS.

3) CTS 3.7.1.2 Action a.3: The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time provided in this CTS Action is adopted in ITS 3.5.1 Action C.

Since the CTS provisions contained in "the Actions of Specification 3.7.1.2" are addressed in the administrative reformatting of the ITS, this change is acceptable. Any related technical changes are addressed separately (refer to 3.5.1 DOC L.3).

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DISCUSSION OF CHANGES ITS: SECTION 3.5.1 ECCS-Operating l

- S l

M.2 CTS 4.5.1.d.1 requires only a functional test of the low pressure alarm circuit for the ADS pneumatic supply (refer to Discussion of lg q

Change "LR.2" for relocation of this requirement). However, no y CTS requirement exists for verification of the necessary pneumatic supply pressure to assure ADS function. ITS SR 3.5.1.5 provides a more restrictive requirement by requiring verification of the actual supply pressure once per 31 days. This change will have no negative impact on safety, and will provide increased assurance of ADS Operability.

M.3 CTS 3.5.1. footnote **" to Action b.4. states that "Whenever two or more RE subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION. maintain reactor coolant %

temperature as low as practical by use of alternate heat removal g .

methods." This footnote is deleted because it does not establish any additional restrictions on plant operation. Furthermore, this 4 M

footnote could be interpreted as a relaxation of the requirement to achieve Cold Shutdown. The ITS 3.4.8. Residual Heat Removal J l (RHR) Shutdown Cooling System-Hot Shutdown. Action to be in Mode

4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months when no RHR systems are Operable adequately prescribes the requirement to make efforts to " maintain reactor coolant temperature as low as practical." If conditions are such that Mode 4 cannot be attained, the Actions remain in effect.

l requiring that efforts to reach Mode 4 continue. Elimination of i the potential relaxation is a more restrictive change with no l impact on safety.

l FERMI - UNIT 2 6 REVISION 11 07/14/99l )

DISCUSSION OF CHANGES ITS': SECTION 3.5.1 ECCS-Operating .

TECHNICAL CHANGES - LESS RESTRICTIVE

" Generic" LA.1 CTS LCO 3.5.1 includes details relating to system design, function, and Operability for the Core Spray System, the Low Pressure Coolant Injection System and the High Pressure Coolant Injection System. ITS 3.5.1 includes only a requirement for Operability and does not include .the details of system design and specific Operability requirements. This is acceptable because these details do not impact the requirement to maintain the equipment Operable and the ITS definition for Operability ensures that all equipment required to maintain Operability is i functioning. These details will be adequately defined and '

controlled in the Bases, which require change control in -

accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection n of the public health and safety acceptable because these details r-do not impact the requirement to maintain the equipment Operable.

LA.2 Not used.

LA.3 Not used. ly LA.4 ' The following CTS details for performing Surveillances are not included in the ITS. These detailed methods for performing Surveillances are moved to the Bases:

a. CTS 4.5.1.a.1.a details a requirenent for verifying that L the system is filled with water. "by venting at the high l point vents":

b. CTS 4.5.1.a.1.b contains a footnote "*" which details a requirement for the correct position of ECCS valves:

c. CTS 4.5.1.a.3 details a requirement for the HPCI pump flow controller to be in the' correct position. The function of the flow controller is to provide the control signal to l ensure correct positioning of the HPCI steam governor ;

valve. ITS SR 3.5.1.4 requires all system valves be in their correct position, without separately detailing the HPCI pump flow controller. Therefore, as detailed in the

- Bases, the verification of the " correct position" of the governor valve is accomplished by proper flow controller positioning:

FERMI - UNIT 2 7 REVISION 11 07/14/99

1 DISCUSSION OF CHANGES ITS: SECTION 3.5.1 - ECCS-Operating LA.4 (continued)

d. CTS 4.5.1.b.1 and 4.5.1.b.2 details test line pressure requirements for the CSS and LPCI pumps:

e. CTS 4.5.1.b.3 and 4.5.1.c.2.a details requirements for verifying HPCI pump flow "in the test flow path" with a system head " including injection line losses":

f. CTS 4.5.1.c.2.b details requirements for verifying automatic HPCI system transfer;

g. CTS 4.5.1.d.2.b details requirements for ADS pressure testing: -

h. CTS 4.5.1.d.2.b.1 and 4.5.1.d.2.b.2 details requirements ,

for verifying ADS valve open; and j

i. CTS 4.8.3.1.2 details requirements for verifying automatic throwover scheme for the AC power distribution system swing bus.

These details can be adequately defined and controlled in the l Bases, which require change control in accordance with Chapter 5 l of the ITS. These details are not required to be in the ITS to I provide adequate protection of the public health and safety since the details in the ITS are adequate for assuring proper performance of the required Surve111ances.

I LA.5 CTS 4.3.3.3, note **. allows the response time for ECCS actuation 1 instrumentation to be exempted from being tested with the value !

" assumed to be the design instrumentation response' time." ITS l SR 3.5.1.14 includes a Note to specifically detail this. allowance. I however, the specific method of accounting for the response time (assuming the design sensor response) is. relocated to the Bases.

This detail of performance can be adequately controlled in p j accordance with ITS 5.5.10. Bases Control Program. The relocation D continues to provide adequate protection of the public health and safety since the requirement for the ECCS response time testing

$ i j remains a Technical Specification requirement.

g

DISCUSSION OF CHANGES ITS: SECTION 3.5.1 ECCS-Operating LR.1 The following Actions and Surveillances of alarm only functions are not assumed in any accident analysis. Alarm only functions do not relate directly to the Operability requirements for the system. ITS does not specify indication only or alarm only to be Operable to support Operability of a system or component:

a. CTS 3.5.1.e details a requirement for restoring an inoperable CSS header differential pressure alarm;

b. CTS 3.5.1.f details a requirement for performing an SR when a LPCI or CSS system keep filled" alarm is inoperable: and

c. CTS 4.5.1.c.3 and 4.5.1.c.4 details requirements for '

performing Channel Calibrations on CSS and LPCI instrumentation.

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

Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and l

safety since alarm only functions do not relate directly to the Operability requirements for the system or analysis assumptions.

LR.2 CTS 4.5.1.d.1 and 4.5.1.d.2.c require surveillance tests of ADS pncumatic supply pressure alarm channels. ITS SR 3.5.1.5 replaces these with a requirement directly related to Operability of ADS: a Surveillance to verify greater than a minimum supply pressure, which assures ADS Operability. The alarm only functions are not l assumed in any accident analysis. Alarm only functions do not l relate directly to the Operability requirements for the system.

These details of alarm surveillances are not required to be in the ITS to provide adequate protection of the public health and safety since alarm-only functions do not relate directly' to the Operability requirements for the system. The replacement of these Surveillances with ITS SR 3.5.1.5 is a more restrictive change (which is discussed here for clarity), which provides a more direct Surveillance of ADS Operability with no impact on safety.

rERMI UNIT 2 9 REVISION 11. 07/14/99l

l DISCUSSION OF CHANGES l ITS: SECTION 3.5.1 - ECCS-Operating LR.3 CTS 3.5.1. Action g. requires submitting a special report to the i

NRC following any ECCS actuation and injection of water into the l reactor coolant system. ITS does not retain the requirement for l

this special report because reporting requirements are adequately

addressed by 10 CFR 50.73(a)(2)(iv). 10 CFR 50.73(a)(2)(iv) )

requires an LER to be submitted for any event or condition that l resulted in manual or automatic ECCS " actuation." Therefore, an LER will cover any " actuation and injection" as is currently required by CTS 3.5.1. Action 9 An LEP. is required to be submitted within .30 days which also meets the Special Report p requirement of 90 days. CTS 3.5.1. Action 9. requirements governing the tracking and reporting to the NRC of accumulated actuation cycles and the current value of the usage factor are k

t accomplished in accordance with plant procedures. Compliance with % -

10 CFR 50.73(a)(2)(iv) and plant procedures will ensure that the NRC is informed of events as required. These details are not required to be in the ITS to provide adequate protection of the I public health and safety because reporting requirements are adequately addressed by 10 CFR 50.73(a)(2)(iv).

m89

TECHNICAL CHANGES - LESS RESTRICTIVE

Speci fi c

L.1 CTS 3.5.1. Action a.2 (loss of both CS subsystems). Action b.3 (LPCI cross connect closed), and Action b.4 (loss of both LPCI subsystems), require that the reactor be in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Mode 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Under the same conditions. ITS 3.5.1 Condition J. requires immediate entry into LC0 3.0.3. LC0 3.0.3 allows 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months to reach Mode 3 and 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months to reach Mode 4 and, therefore, is less restrictive. However, the ITS LCO 3.0.3 actions also ir.clude a more restrictive requirement: to be in Mode '

2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . The requirement to enter LC0 3.0.3 following the loss of both CS subsystems or the loss of both LPCI subsystems recognizes that a significant plant transient (reactor shutdown and cooldown) will be performed without the required complement of emergency core cooling systems. Under these circumstances, entry into LC0 3.0.3 and the resulting associated requirements is appropriate. The additional hour allowed to reach Mode 3 and Mode 4 is not significant and has no impact on the level of plant l

safety. Furthermore, any impact is offset by the associated more restrictive requirement to be in Mode 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months .

FERMI UNIT 2 10 REVISION 11 07/14/99l0

DISCUSSION OF CHANGES ITS: SECTION 3.5.1 - ECCS-Operating L.2 ITS 3.5.1 includes two new Actions. Action F is added for the

-condition of HPCI inoperable coincident with: 1) one low pressure ECCS injection / spray subsystem inoperable: 2) one LPCI pump in one or both LPCI subsystems inoperable: or 3) one CSS and one LPCI subsystem inoperable. Action H is added for the condition of one ADS valve inoperable coincident with: 1) one low pressure ECCS injection / spray subsystem inoperable: 2) one LPCI pump in one or both LPCI subsystems inoperable: er 3) one CSS and one LPCI subsystem inoperable. Both Action F and Action H require restoration of either the inoperable high pressure (HPCI or ADS) or the inoperable low pressure ECCS system within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is less restrictive than the same conditions addressed in CTS 3.5.1. Actions c and d, which would default to LC0 3.0.3, and '

require Mode 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months and Mode 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . (Note that some specific combinations of ECCS inoperability addressed in this change are allowed in CTS action c. in accordance with footnote #. However, all combinations are discussed as part of this overall less restrictive change for completeness.) This change is acceptable because ITS 3.5.1, Condition F and Condition H, result in adequate ECCS systems available to respond to a design basis LOCA although the ability to tolerate a single failure may be lost. In Condition F. adequate core cooling is ensured by the Operability of the ADS and the remaining low pressure ECCS subsystems. However ECCS reliability is reduced because a single failure in one of the remaining Operable subsystems concurrent with a LOCA may result in the ECCS not being able to perform its intended safety function. In Condition H.

adequate core cooling is ensured by the Operability of HPCI and the remaining low pressure ECCS injection / spray subsystems.

However, ECCS reliability is reduced because a single failure concurrent with a LOCA could result in the minimum required ECCS equipment not being available. Therefore, ITS 3.5.1. Action F and Action H, require restoration of either the inoperable high ;

pressure (HPCI or ADS) or the inoperable low pressure ECCS system j within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Completion Time is based on a reliability '

study cited in memorandum from R.L. Baer (NRC) to V. Stello.

Jr.(NRC), " Recommended Interim Revisions to LCOs for ECCS Components." December 1, 1975. This change is consistent with NUREG-1433 Rev. 1.

FERMI UNIT 2 11 REVISION 11 07/14/99 l 4

DISCUSSION OF CHANGES ITS: SECTION 3.5.1 ECCS-Operating L.3 CTS Actions (LC0 3.7.1.2. Action a.3 and LC0 3.5.1 Actions. Footnote

"#") for one CSS subsystem and one LPCI subsystem inoperable due to lack of EECW cooling. allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable EECW (and therefore the inoperable CSS and LPCI subsystems). However, the CTS Actions for one CSS Eubsystem and one LPCI subsystem inoperable for any other reason, requires immediate . shutdown. The ITS eliminate the restriction on the inoperabil' ties of CSS and LPCI having to be due to lack of EECW cooling: allowing 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for one CSS subsystem and one LPCI subsystem inoperable for any reason. In the condition of one CSS and one LPCI subsystem inoperable. provided all other safety related equipment is available to perform its function (which is assured by other ITS Specifications and the ITS Safety Function Determination Program), the remaining ECCS subsystems are adequate to perform the assumed ECCS function in the event of an accident.

L.4 CTS 4.5.1.b.3 (HPCI high pressure flow verification). CTS 4.5.1.c.2.a (HPCI low pressure flow verification). and CTS {

4.5.1.d.2.b (ADS valve manual operation) .are modified by a i footnote allowing performance to be deferred until ~12 hours after reactor steam pressure is adequate to perform the test" but also states that the test is performed at 2150 psig. This allowance to defer testing is based on the need to establish appropriate conditions for testing. The corresponding ITS SRs. 3.5.1.9.

3.5.1.10 and 3.5.1.13. are modified by a similar Note that allows deferring the performance of these tests until reactor steam pressure "and flow" are adequate to perform the test. This change is necessary because the CTS allowance to reach only the required reactor steam pressure only partially addresses the issue of adequate test conditions. Requiring performance of these tests before adequate steam flow can be maintained creates the potential for an undesired reactor depressurization. This change is less restrictive because it may allow additional time before -the tests are required to be performed. This change is acceptable because the allowance permits the test to be delayed until appropriate conditions are established and will not normally result in a significant delay in performing these tests. Additionally. the Bases which detail the conditions defining " adequate pressure and flow" specify adequate pressure as 2 850 psig. This pressure is that recommended by the valve manufacturer and represents clarification of the CTS presentation that states testing is done at 2150 psig after " adequate pressure" to perform the test has been achieved.

FERMI UNIT 2 12 REVISION 11 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.5.1 - ECCS-Operating L.5 CTS 4.8.3.1.2. and ITS SR 3.5.1.2. requires demonstration of the LPCI swing bus, automatic transfer scheme. Performance of this test requires that the swing bus (and therefore both LPCI subsystems) be made inoperable. Additionally, performance of EDG surveillances that require the EDG to be paralleled to its bus, render the automatic throwover scheme inoperable. As a result.

these tests would result in ITS requiring an intentional entry into LC0 3.0.3 (LC0 3.5.1. Condition J). To preclude this intentional LC0 3.0.3 entry the ITS adds a Note to SR 3.5.1.2 allowing a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months delay in entering the actions for the lq inoperability caused by performing these required Surveillances. S Since this test: 1) is not expected to de energize the swing bus:

2) is performed under control of a dedicated individual in communication with the control room operator: and 3) results in the period of inoperability being much less than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an l avoidance of an intentional entry into LC0 3.0.3 will not significantly affect safety.

RELOCATED SPECIFICATIONS None l

l TECHNICAL SPECIFICATION BASES ,

l

' l The CTS Bases for this Specification have been replaced by Bases that reflect l the format and applicable content of ITS 3.5.1 consistent with the BWR STS.

NUREG 1433. Rev. 1. l g

ECCS-Operating 3.5.1 INSERT 3.5.1 02 SR 3.5.1.1 Verify correct voltage and breaker 7 days alignment to the LPCI swing bus.

SR 3.5.1.2 - - - - NOTE ---- +

When LPCI is placed in an inoperable status solely for performance of this SR. or when f ,

the LPCI swing bus automatic throwover scheme is inoperable due to EDG 12 being 7 q paralleled to the bus for required testing. 2d entry into associated Conditions and Required Actions may be delayed up to 12 ll_ J i hours for completion of the required m" '

testing. D Perform a functional test of the LPCI swing 31 days bus automatic throwover scheme.

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I FERMI UNIT 2 Page 3.5 4 (Insert) REVISION 11, 07/14/99l

1 Sge ctficaf fo a F. S. 7 CAlso see specwicasiaa g. g.g3 i j

i ELECTRICAL PolMR SYSTEMS sec . s SURVEILLANCE REQUIREMENTS /

crecScd.oh 3.&.8 )

%3.5* 4.8.3.2. Maast the above requitgLpower,41stribution system division)and 5

the swing bus shais os cesereined energized at least once per 7 days by l verifying correct breaker alignment and voltage on the bussec/ cabinets, f3 1

f4.8' 3. 2 The A.C. power distribution system swt g bus automatiq. throw )1 sch shall be demonstr ted OPERABLE at least ce per 31 days by man 11y -

ope ng position 3C bu 72C and verifying that he automatic transfer scheme

[*q A

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l FERMI - UNIT 2 3/4 8 15a Amendment No. 29 t?ev n ll l

PAGE K'0F 08

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l DISCUSSION OF CHANGES ITS: SECTION 3.5.2 ECCS-Shutdown A.8 CTS LCO 3.8.3.2.a.3 requires the LPCI swing bus to be Operable, and g the associated Action c requires declaration of LPCI inoperability with the swing bus inoperable (i.e., not energized). The ITS ld4 provides this intent within the ECCS Specification, without separately specifying Operability of the swing bus in another Specification. The ITS recognizes that LPCI is inoperable with the swing bus inoperable (ITS Bases specifically discusses). Therefore both the ITS and CTS Actions for an inoperable swing bus are the same. This administrative presentation preference does not result in any technical changes. Therefore, this is an administrative change with no impact on safety.

A.9 Not used.

w A.10 CTS 4.5.1.b.2 specifies that the LPCI pump flow verification test be performed at a pressure corresponding to a reactor vessel to primary containment differential pressure (psid) greater than or equal to the value assumed in the safety analysis. ITS SR 3.5.1.8 and SR 3.5.2.6 specify that the LPCI pump flow test be performed ld at a system head corresponding to a reactor pressure greater than or equal to the value assumed in the safety analysis. This change was made to make the test description for the LPCI test the same ,

as that currently used for the CS test. Both tests are intended p to verify the flow rates at the rector pressures assumed in the safety analysis. NEDC 32071P. Table 4 3. NEDC 32071P Table 4 3 3 footnote (1), indicates that the pressures assumed for LPCI or CS pump injection and the values at which the pumps are tested is expressed in " vessel to drywell differential pressure." The acceptance criteria used for ITS SR 3.5.1.8 (and ITS SR 3.5.2.6) is expressed as minimum flow rate against a system head W

corresponding to reactor pressure. This criteria is clarified in the Bases which states that pump flow rates are verified against a system head equivalent to the elevation head pressure between the pump suction and the vessel discharge, the piping fricfion losses, and RPV pressure present during a LOCA. The SR acceptance criteria is presented in "psig" (instead of psid) and clarified in the Bases to ensure that the flow verification test is not FERMI UNIT 2 3 REVISION 11 07/14/99l l

l

DISCUSSION OF CHANGES ITS: SECTION 3.5.2 - ECCS-Shutdown performed based on pump differential pressure alone. This is an administrative change because there is no change to the existing requirement to test the CS and LPCI pumps at the pressures and flows assumed in the safety analysis.

A.11 CTS 4.5.1.c.1 requires the performance of a system functional test that includes " simulated automatic actuation." ITS SR 3.5.2.7 lg permits the system functional to be initiated by an " actual or g simulated

automatic initiation signal. This change allows satisfactory automatic system initiations to be used to fulfill

(

the system functional Surveillance Requirement. Operability is adequately demonstrated because the ECCS subsystem can not discriminate between " actual" or " simulated" initiation sig' als.

This is an administrative change with no impact on safety be. mse it is a reasonable interpretation of the existing requirement. '

3 A.12 CTS 3.5.2 and 3.5.3. Applicability footnote "*". provides an allowance for ECCS to be not required when the refueling cavity l water level is "within the limits of Specification 3.9.8 and 3.9.9."

The ITS simply states this provision as a single required water level. Since the allowance only applies when the spent fuel pool gates are removed, the water level can be refer ~:nced from a single point, and be known to satisfy both CTS 3.9.8 and 3.9.9. This bounding level is presented in the ITS. This is a presentation preference only. with no technical change. Therefore. this change is administrative. ,

A.13 Not used.

2 FERMI UNIT 2 4 REVISION T1~. 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.5.2 ECCS-Shutdown L.4 CTS 4.8.3.2.2 requires demonstration of the LPCI swing bus automatic throwover scheme: however the associated LC0 only requires that the LPCI swing bus be energized from the one required energized division. In this condition (only one division energized), the automatic throwover performs no safety function ._

since there is not a second division to throwaver to. d{E Furthermore, the associated acticas only provide for actions to be taken if the swing bus is de energized: no action is provided for 3 an inoperable throwover scheme, and the provisions of LCO 3.0.3 G are also not applicable. Therefore, the CTS presentation for LPCI 12.

swing bus automatic throwover scheme while in the shutdown Modes, does not contain any functional requirements or limitations. As such. ITS provides an enhanced presentation by deleting the Surveillance. Therefore, this change has no negative impact on safety.

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 3.5.2 consistent with the BWR STS.

NUREG 1433. Rev. 1.

FERMI UNIT 2 9 REVISION 1E. 07/14/99 l

ECCS-Shutdown B 3.5.2 INSERT B 3.5.2 1 SR 3.5.2.3 The LPCI System injection valves, recirculation pump discharge valves, and LPCI cross tie valve are powered from the LPCI swing bus, which l must remain energized to support OPERABILITY of any required LPCI subsystem. Therefore, verification of proper voltage and correct ~

breaker alignment to the swing bus is made every 7 ' days. The correct breaker alignment ensures the Lppropriate electrical power sources are available, and the appropriate voltage is available to the swing bus.

The verification of proper voltage availability ensures that the l }k required voltage is readily available for critical system loads connected to this bus. The 7 day Frequency takes into account the redundant capability of the AC, DC, and AC swing bus electrical power sources, and other indications available in the control room that alert the operator to subsystem malfunctions.

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1 FERMI - UNIT 2 Page B 3.5 21 (Insert) REVISION 11. 07/14/99l i l

1

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.5.2 - ECCS - Shutdown

( ,\

v TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.5.2 "L.3" 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 allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore two ECCS subsystems to operable status, with at least one aligned to the suppression pool.

prior to requiring suspension of OPDRVs. This change will not

/

significantly increase the probability of an accident previously evaluated because the amount of time allowed to restore equipment to 2

C] operable does not affect the initiators of any analyzed accident. This change will not significantly increase the consequences of any accident previously evaluated because the remaining operable ECCS subsystem would be available to perform the core flooding function.

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). The changes in normal plant operation are not in conflict with any current safety analysis assumptions. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

v FERMI - UNIT 2 5 REVISION 11 07/14/99l l

J

m-NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.5.2 ECCS - Shutdown

( .-

TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.5.2 "L.3" 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: 1) the allowance is consistent with that approved in CTS 3.5.2 Actions: 2) the availability of the remaining operable subsystem: and 3) the low probability of an event during this limited time.

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d FERMI.- UNIT 2 6 REVISION 11 07/14/99l

=' rd'em e m"

L NO SIGNIFICANT H'4ZARDS EVALUATION ITS: SECTION 3.5.2 - ECCS - Shutdown

. TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.5.2 "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. ,

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 deletes a Surveillance on the LPCI swing bus %

throwover scheme while in shutdown modes, since the throwover scheme is not required.to function in this condition. This change will not k

, significantly increase the probability of an accident previously J

evaluated because the LPCI swing bus throwover scheme does not affect

the initiators of any analyzed accident. This change will not significantly increase the consequences of any accident previously evaluated because the remaining operable ECCS components, including the remaining' requirement to maintain the LPCI swing bus energized, are available.to perform the core flooding _ function.

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 l systems, structures, or components (SSC). The changes in normal plant i operation are not in conflict with any current safety analysis assumptions. Therefore, this change will not create the possibility of-a new or different kind of accident from any accident previously

evaluated.

L

[w

.o' FERMI - UNIT 2' 7 REVISION 11 07/14/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.5.2 ECCS - Shutdown TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.5.2 "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, in this condition (only one division energized), the ,

automatic throwover performs no safety function since there is not a f second division to throwover to. Furthermore, the associated actions g only provide for actions to be taken if the swing bus is de-energized; g no action is provided for an inoperable throwover scheme, and the bi 5

provisions of LC0 3.0.3 are also not applicable. Therefore, the CTS presentation for LPCI swing bus automatic throwaver scheme while in the shutdown Modes, does not contain any functional requirements or limitations. As such, the deletion does not involve a significant I reduction in a' margin of safety, i

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d REVISION 11 FERMI - UNIT 2 8 07/14/99l

INSERT THIS PAGE IN FRONT OF VOLUME 7

'< Z ; / ~ " ?Vohime 7 SECTION 3.6 4 Remove Replace 3.6.1.1 ITS pg 3.6-2 Rev 0 3.6.1.1 ITS pg 3.6-2 Rev 1I B 3.6.1.1 ITS pg B 3.6.1.1-5 Rev 0 B 3.6.1.1 ITS pg B 3.6.1.1-5 Rev i1 3.6.1.1 CTS M/U (3/4 6-17) pg E of 8 3.6.1.1 CTS M/U (3/4 6-17) pg 8 of 8 Rev i1 3.6.1.1 DOC's pg 2 Rev 5 3.6.1.1 DOC's pg 2 Rev 11 3.6.1.1 DOC's pg 3 Rev 5 3.6.1.1 DOC's pg 3 Rev i1 3.6.1.1 DOC's pg 4 Rev 0. 3.6.1.1 DOC's pg 4 Rev i1 3.6.1.1 DOC's pg 5 Rev 11 3.6.1.1 NUREG M/U pg 3.6-2 Rev 5 3.6.1.1 NUREG M/U pg 3.6-2 Rev i1 3.6.1.1 NUREG M/U pg 3.6-2 (Insert) Rev 11 B 3.61.1 NUREG M/U pg B 3.6-5 B 3.6.1.1 NUREG M/U pg B 3.6-5 Rev i1 B 3.6.1.1 NUREG M/U pg B 3.6-5 Onsert)

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3.6.1.1 JFD's pg 1 Rev 5 3.6.1.1 JFD's pg i Rev 11 3.6.1.3 ITS pg 3.6-11 Rev Sa 3.6.1.3 ITS pg 3.6-1I dev i1 3.6.1.3 ITS pg 3.6-12 Rev Sa 3.6.1.3 ITS pg 3.6-12 Rev i1 3.6.1.3 ITS pg 3.6-15 Rev Sa 3.6.1.3 'l TS pg 3.6-15 Rev 11 B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-5 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-5 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-7 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-7 Rev 11 B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev

1 B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-16 Rev Sa B 3.6.1.3 ITS pg B 3.6.1.3-16 Rev i1 3.6.1.3 CTS M/U (3/4 6-3) pg 5 of 9 Rev Sa 3.6.1.3 CTS M/U (3/4 6-3) pg 5 of 9 Rev ,11 3.6.1.3 CTS M/U (3/4 6-14) pg 6 of 9 Rev Sa 3.6.1.3 CTS M/U (3/4 6-14) pg 6 of 9 Rev i1 3.6.1.3 CTS M/U (3/4 6 21) pg 8 of 9 Rev Sa 3.6.1.3 CTS M/U (3/4 6-21) pg 8 of 9 Rev i1 3.6.1.3 CTS M/U (3/4 4-24) pg 9 of 9 Rev Sa 3.6.1.3 CTS M/U (3/4 4-24) pg 9 of 9 Rev 11 3.6.1.3 DOCS pg 3 Rev Sa 3.6.1.3 DOCS pg 3 Rev i1 3.6.1.3 DOCS pg 7 Rev Sa 3.6.1.3 DOCS pg 7 Rev i1 !

1 3.6.1.3 DOCS pg 8 Rev Sa 3.6.1.3 DOCS pg 8 Rev i1 3.6.1.3 DOCS pg 9 Rev Sa 3.6.1.3 DOCS pg 9 Rev 11 3,6.1.3 DOCS pg 10 Rev Sa 3.6.1.3 DOCS pg 10 Rev i1 Rev 11 07/14/99 a

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, Volume.7:SECTION 33 (cont'd)l * ' % J -

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Remove Replace 3.6.1.3 DOCS pg ii Rev Sa 3.6.1.3 DOCS pg 11 Rev i1 3.6.1.3 DOCS pg 12 Rev Sa 3.6.1.3 DOCS pg 12 Rev i1 3.6.1.3 DOCS pg 13 Rev 11 3.6.1.3 NUREG M/U pg 3.6-10 (Insert) Rev Sa 3.6.1.3 NUREG M/U pg 3.6-10 (Insert) Rev i 1 3.6.1.3 NUREG M/U pg 3.6-17 Rev SA 3.6.1.3 NUREG M/U pg 3.6-17 Rev i1 B 3.6.1.3 NUREG M/U pg B 3.6-17 Rev SA B 3.6.1.3 NUREG M/U pg B 3.6-17 Rev i1 B 3.6.1.3 NUREG M/U pg B 3.6-17 (Insert) Rev i1 B 3.6.1.3 NUREG M/U pg B 3.6-20 Rev Sa B 3.6.1.3 NUREG M/U pg B 3.6-20 Rev i1 B 3.6.1.3 NUREG M/U pg B 3.6-20 (Insert) Rev Sa B 3.6.1.3 NUREG M/U pg B 3.6 20 (Insert) Rev i1 B 3.6.1.3 NUREG M/U pg B 3.6-30 Rev Sa B 3.6.1.3 NUREG M/U pg B 3.6-30 Rev i1 3.6.1.3 JFDs pg 2 Rev Sa 3.6.1.3 JFDs pg 2 Rev i1 ,

3.6.1.3 NSHC pg 21 Rev Sa 3.6.1.3 NSHC pg 21 Rev i1 3.6.1.3 NSHC pg 22 Rev Sa 3.6.1.3 NSHC pg 22 Rev i1 I 3.6.1.3 NSHC pg 23 Rev i1 3.6.1.3 NSHC pg 24 Rev 11 3.6.1.4 ITS pg 3.6-14 Rev 0 3.6.1.4 ITS pg 3.6-14 Rev i1 3.6.1.7 ITS pg 3.6-18 Rev 5 3.6.1.7 ITS pg 3.6-18 Rev i1 3.6.1.7 ITS pg 3.6-19 Rev 5 3.6.1.7 ITS pg 3.6-19 Rev i1 3.6.1.7 ITS pg 3.6-19a Rev i 1 B 3.6.1.7 ITS pg B 3.6.1.7-3 P.ev 5 B 3.6.1.7 ITS pg B 3.6.1.7-3 Rev i1 B 3.6.1.7 ITS pg B 3.6.1.7-5 Rev 5 B 3.6.1.7 ITS pg B 3.6.l.7-5 Rev i1 B 3.6.1.7 ITS pg B 3.6.1.7-6 Rev 5 B 3.6.1.7 ITS pg B 3.6.1.7-6 Rev il

! 3.6.1.7 CTS M/U (3/4 6-50) pg i of 1 Rev 5 3.6.1.7 CTS M/U (3/4 6-50) pg 1 of 1 Rev i1 3.6.1.7 DOCS pg 4 Rev 5 3.6.1.7 DOCS pg 4 Rev i1

! 3.6.1.7 NUREG M/U pg 3.6-23 Rev 5 3.6.1.7 NUREG M/U pg 3.6-23 Rev I1 3.6.1.7 NUREG M/U pg 3.6-24 Rev 5 3.6.1.7 NUREG M/U pg 3.6-24 Rev i1 .

B 3.6.1.7 NUREG M/U pg B 3.6-44 Rev 5 B 3.6.1.7 NUREG M/U pg B 3.6-44 Rev 11 B 3.6.1.7 NUREG M/U pg B 3.6-45 Rev 5 B 3.6.1.7 NUREG M/U pg B 3.6-45 Rev ii !

B 3.6.1.7 NUREG M/U pg B 3.6-46 Rev 5 B 3.6.1.7 NUREG M/U pg B 3.6-46 Rev i1

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3.6.1.7 NSHC pg 5 Rev i1 3.6.1.7 NSHC pg 6 Rev 1i B 3.6.1.8 ITS pg B 3.6.1.8-2 Rev 0 B 3.6.1.8 ITS pg B 3.6.1.8-2 Rev 11 B 3.6.1.8 ITS pg B 3.6.1.8-3 Rev 0 B 3.6.1.8 ITS pg B 3.6.1.8-3 Rev 11 Rev 11 07/14/99

i Volume 7 SECTION3.6(cost'd)%M W ,

Remove Replace B 3.6.1.8 NUREG M/U pg B 3.6-50 B 3.6.1.8 NUREG M/U pg B 3.6-50 Rev i!

3.6.1.8 JFDs pg i Rev 5 3.6.1.8 JFDs pg i Rev 11 3.6.2.1 CTS M/U (3/4 6-17) pg 3 of 3 Rev 5 3.6.2.I CTS M/U (3/4 6-17) pg 3 of 3 Rev i1 3.6.2.1 DOCS pg 3 Rev 5 3.6.2.1 DOCS pg 3 Rev i1 3.6.2.I DOCS pg 4 Rev 5 3.6.2.1 DOCS pg 4 Rev i1 3.6.2.2 CTS M/U (3/4 5-8) pg i of 5 3.6.2.2 CTS M/U (3/4 5-8) pg 1 of 5 Rev i1 3.6 2.3 ITS pg 3.6-28 Rev 5 3.6.2.3 ITS pg 3.6-28 Rev i1 B 3.6.2.3 ITS pg B 3.6.2.3-3 Rev 5 B 3.6.2.3 ITS pg B 3.6.2.3-3 Rev i1 3.6.2.3 CTS M/U (3/4 6-19) pg 1 of 1 3.6.2.3 CTS M/U (3/4 6-19) pg 1 of 1 Rev 11 3.6.2.3 DOCS pg i Rev 0 3.6.2.3 DOCS pg i Rev 11 3.6.2.3 DOCS pg 2 Rev 0 3.6.2.3 DOCS pg 2 Rev i1 ,

3.6.2 3 DOCS pg 3 Rev 0 3.6.2.3 DOCS pg 3 Rev i1 b 3.6.2.3 NUREG M/U pg B 3.6-69 Rev 5 B 3.6.2.3 NUREG M/U pg B 3.6-69 Rev i1 3.6.2.4 ITS pg 3.6-29i Rev 1I 3.6.2.4 ITS pg 3.6-29ii Rev 11 B 3.6.2.4 ITS pg B 3.6.2.4-1 Rev i1 B 3.6.2.4 ITS pg B 3.6.2.4-2 Rev 11 B 3.6.2.4 ITS pg B 3.6.2.4-3 Rev 11 B 3.6.2.4 ITS pg B 3.6.2.4-4 Rev 11 3.6.2.4 CTS M/U (3/4 6-18) pg 1 of 1 Rev i1 3.6.2.4 DOCS pg i Rev i1 3.6.2.4 DOCS pg 2 Rev 1I 3.6.2.4 DOCS pg 3 Rev 11 3.6.2.4 NUREG M/U pg 3.6-37 3.6.2.4 NUREG M/U pg 3.6-37 Rev 11 3.6.2.4 NUREG M/U pg 3.6-38 3.6.2.4 NUREG M/U pg 3.6-38 Rev i1 B 3.6.2.4 NUREG M/U pg B 3.6-71 B 3.6.2.4 NUREG M/U pg B 3.6-71 Rev 11 B 3.6.2.4 NUREG M/U pg B 3.6-72 B 3.6.2.4 NUREG M/U pg B 3.6-72 Rev i1 B 3.6.2.4 NUREG M/U pg B 3.6-73 B 3.6.2.4 NUREG M/U pg B 3.6-73 Rev i1 B 3.6.2.4 NUREG M/U pg B 3.6-74 B 3.6.2.4 NUREG M/U pg B 3.6-74 Rev i1 3.6.2.4 JFD's pg i Rev 0 3.6.2.4 JFD's pg i Rev 11 3.6.2.4 NSHC pg i Rev 11 3.6.4.1 NUp" 3.6-47 Rev 5 3.6.4.1 NUREG M/U pg 3.6-47 Rev 1 i B 3.6.4.21. .2-2 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-2 Rev 1I B 3.6.4.2 IT5, 1.2 3 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-3 Rev i1 Rev11 07/14/99

l Volume 7 SECTION3.6 (cont'd)) x'- , ,

Remove Replace B 3.6.4.2 ITS pg B 3.6.4.2-4 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-4 Rev i1 B 3.6.4.2 ITS pg B 3.6.4.2-5 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2 5 Rev i1 l B 3.6.4.2 'fS pg B 3.6.4.2-6 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-6 Rev i1 3.6.4.2 CTS M/U (3/4 6-52) pg 2 of 3 Rev 5 3.6.4.2 CTS M/U (3/4 6-52) pg 2 of 3 Rev 11 i 3.6.4.2 DOCS pg 3 Rev 5 3.6.4.2 DOCS pg 3 Rev 11 3.6.4.2 DOCS pg 4 Rev 5 3.6.4.2 DOCS pg 4 Rev i1 3.6.4.2 DOCS pg 5 Rev 5 3.6.4.2 DOCS pg 5 Rev 11 l

B 3.6.4.2 NUREG M/U pg B 3.6-103 Rev 5 B 3.6.4.2 NUREG M/U pg B 3.6-103 Rev i1 1 B 3.6.4.2 NUREG M/U pg B 3.6-107 Rev 5 B 3.6.4.2 NUREG M/U pg B 3.6-107 Rev i1 B 3.6.4.2 NUREG M/U pg B 3.6-107 (Insen) Rev i1 3.6.4.2 JFD's pg i Rev 0 3.6.4.2 JFD's pg i Rev i1 ,

3.6.4.2 JFD's pg 2 Rev 11 3.6.4.2 NSHC pg 7 Rev 5 3.6.4.2 NSHC pg 7 Rev 11 3.6.4.2 NSHC pg 8 Rev 5 3.6.4.2 NSHC pg 8 Rev i1 3.6.4.3 ITS pg 3.6 41 Rev 5 3.6.4.3 ITS pg 3.6-41 Rev i1 l

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Primary Containment 3.6.1.1

) SURVEILLANCE REQUIREENTS (continued)

SURVEILLANCE FREQUENCY i

SR 3.6.1.1.2 Verify drywell to suppression chamber 18 months !

differential pressure does not decrease at a rate > 0.2 inch water gauge per Mg2 minute tested over a 10 minute period at i an initial differential pressure of ---- NOTE-- -

1 psid. Only required after two consecutive tests fail and continues until two consecutive tests pass 9 months SR 3.6.1.1.3 ---- -- .-- NOTE - ------ -- - --

Only required to be performed after

>i safety / relief valve operation with the suppression chamber average water M temperature = 160'F and reactor coolant

$5! $$.S$$!!S$$.$. !! !...............

M !

Perform an external visual examination of Once prior to k' the suppression chamber. entry into MODE 2 or 3 from MODE 4 )

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l FERMI UNIT 2 3.6 2 Revision 11 07/14/99

I' t

l Primary Containment

. B 3.6.1.1 BASES SURVEILLANCE REQUIREENTS (continued) are identified by other primary containment SRs. Two consecutive test failures, however, would indicate unexpected degradation: in this event, as.the Note indicates, increasing the Frequency to once every 9 months ,

is required until the situation is remedied as evidenced by passing two consecutive tests.

SR 3.6.1.1.3 N The primary containment suppression chamber can experience significant hydrodynamic loading during safety / relief valve -

Q (SRV) operation with the suppression pool average water l g

- temperature = 160*F and reactor coolant system pressure 9 > 200 psig. After SRV operation during these conditions, a :

M visual examination of the exterior surface of the I

~ suppression chamber will identify any abnormal conditions I k that may warrant further inspection and review for continued OPERABILITY. This examination is performed prior to

)

resuming operation in H0 DES where primary containment is required to be OPERABLE.

j REFERENCES 1. UFSAR, Section 6.2.

2. UFSAR. Section 15.6.5.

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

i i

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! FERMI UNIT 2 B 3.6.1.1 - 5 Revision 11 07/14/99 o

Spec m ewnou % bl l

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( Aho sq.SpecWieda. s.G.1,1) l (ktso sa. Seu19c4E 3 6.zt )

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continuedl

1. At least once per 5 minutes ouring testing which aods heat to the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105'F.

2. At least once per hour when suppression chamber average water }

temperature is greater than or equal to 95'F, by verifying:

a) Suppression chamber average water temperature to be less '

Su. than or equal to 110'F, and 5EtciSCg b) THERMAL POWER to be less than or equal to 1% of RATED THERMAL POWER after suppression chamber average water 3b'7+l temperature has exceeded 95'F for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. At least once per 30 minutes in OPERATIONAL CONDITION 3 following a 4

scram with suppression chamber average water temperature greater '

than or equal to 95'F, by verifying suppression chamber average t4 !

Q water temperature less than or equal to 120*F. j I

d. By an external visual examination of the suppression chamber after

$ O 4 ,.t.1, 3 safety /reisef valve operation with the suppression chamber average water temperature greater than or equal to system pressure greater than 200 psig nd reactor coolant h' Q

At--terst once per -I8-months-byla visua1 insoeetionff- tt.;-atcenibT3 q 3,g * ), j , l i n t e r4oe-a n d-ex t e r4 a n-*(--t h e-+u oprem en.-oh ambe r# L

/ g \ f. By verifying eight suppression pool water temperature instrumentation channels OPERABLE by performance of a:

$P4 M O n..) 1. CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

\*34.7.,1 / 2.

3.

CHANNEL FUNCTIONAL TEST at least once per 31 days, and CHANNEL CALIBRATION at least once per 18 months, with the water high temperature alarm Mpoint for 5105'F.

fg. By verifying both narrow range suppression chamber water level

} instrumentation channels OPERABLE by performance of a:

Q .

l.

2.

CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , CHANNEL FUNCTIONAL TEST at least once per 31 days, and 6p4ciflCdth- 3. CHANNEL CALIBRATION at least once per 18 months, j

l 3 .(, .1, 2 I With the water level alarm setpoint for: '

l. High water level 514'8"

2. Low water level 114'4" (TWMS Narrow Range) g g *g*g* g h. At least once per 18 m;nths by conducting a drywell-to-suppression chamber bypass leak test at an initial differential pressure of 1 psi and verifying that the differential pressure does not decrease by more than OJn inch at =ter ocr minute for a period of 10 minutes._fif /ny drywell-t -suppression hamber bypas leak t

[aatisAomeett/especified imit, the te schedule f subseo nt test 4 shall be rreviewed an approved by e Commissio fif two

' consecutive tests fail to meet the specified limit, a test thall be performed at least every 9 months until two consecutive tests meet the specified limit, at which time the 18. month test schedule may be resumed.

FERMI - UNIT 2 3/4 6-17 T

08 PAGE OF

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 PRIMARY CONTAINMENT A.5 CTS SRs 4.6.1.1.c and 4.6.1.1.d provide direction to comply with other Specifications. ITS format does not include such " cross references." Compliance with other Specifications is required without it being stated here. The removal of these " cross references" is a presentation preference of the ITS consistent with NUREG-1433. Therefore, this change is an administrative change with no impact on safety.

A.6 CTS 4.6.2.1.e requires a visual examination of the suppression chamber after SRV operation when the suppression pool teverature is 2160F and RCS pressure is > 200 psig. Should this event occur y-at these conditions, the required actions of CTS 3.6.2.1 i

-~

i (converted into ITS 3.6.2.1) will require the plant to be shutdown to Mode 4. As such, based on the requirements of CTS 4.0.4 and ITS SR 3.0.4 will require this CTS Surveillance (which silent on M

J any explicit limitation on completing the examination) to be M completed prior to entering Mode 2 or 3. Given this implicit -

limitation in CTS, the ITS SR 3.6.1.1.3 Frequency is stated as "once prior to entry into Mode 2 or 3 from Mode 4." This reflects (

an editorial presentation enhancement and, along with the locating of this SR in the Primary Containment Specification (ITS LC0 3.6.1.1). is an administrative change.

i j TECHNICAL CHANGES .f E E _ RESTRICTIVE M.1 CTS 3.6.1.2 and 3.6.2.1 Actions for primary containment and drywell-to-suppression chamber leakage above established limits only restrict reactor coolant heatup beyond 200*F (which would I

allow a startup and control rod withdrawal from cold conditions, i.e.. < 200*F). Furthermore, if primary containment leakage or drywell-to suppression chamber above established limits were discovered while operating. the CTS Actions are non specific as to r the appropriate required actions. One interpretation would be to h consider Primary Containment Integrity not met and enter the 1-hour Action of CTS 3.6.1.1. Under the same conditions, ITS

]

ec LC0 3.0.4 will not i: low a reactor startup to commence with V containment leakagr, outside limits: just as CTS requires.

However, a restrir, tion is added by ITS 3.6.1.1 Action B to require a plant shutdown to Mode 4. if leakage rates are discovered outside established limits and cannot be corrected within the times pruvided in ITS Action A. '

FERMI - UNIT 2 2 REVISION 11 07/14/99l l

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DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 - PRIMARY CONTAINMENT The 1-hour Completion Time provided in ITS Action A presents a restriction beyond CTS requirements (or consistent with the above Q

mentioned interpretation). While ITS 3.6.1.1 is potentially more b restrictive it provides appropriate Actions, commensurate with the type of leakage failure experienced, to ensure the plant is placed in a configuration consistent with the design basis.

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

\

M.2 CTS 3.6.1.5. Action, allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore structural !

integrity to within limits. ITS 3.6.1.1 presents the primary I containment structural integrity requirements in the Primary i Containment LCO. which provides an allowed Completion Time of l 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when structural conditions are not in compliance with -l requirements. This conservatively brings the allowed times for '

restoration for a loss of containment structural integrity into agreement with a loss of containment Operability. Furthermore, the potential confusion in applying the appropriate restoration time is eliminated. This is a more restrictive change with no '

negative impact on safety.

TECHNICAL CHMGES LESS RESTRICTIVE

" Generic" 1

LA.1 CTS 4.6.2.1.e requires a visual inspection of the suppression I chamber every 18 months. Visual examinations are a 10 CFR 50 ;

Appendix J. requirement prior to Type A leak rate testing (and as such, are required by ITS SR 3.6.1.1.1). This adequately prescribes the frequency for these visual examinations without the l l need for a Technical Specification requirement for more frequent examinations. Therefore. this more frequent inspection is relocated from Technical Specifications to the Technical Requirements Manual. These details can be adequately defined and controlled by the provisions of 10 CFR 50.59. This detail is not required to be in the ITS to provide adequate protection of the i public health and safety acceptable because it does not impact the requirement to maintain the primary containment Operable.

LA.2 CTS 3.6.2.1.b details the require,nent for drywell bypass leakage testing by stating the acceptance criteria as "the equivalent leakage through a 1-inch diameter orifice." ITS SR 3.6.1.1.2 provides the detailed acceptance criteria that this corresponds to. The " equivalency" is relocated to the Bases. These details FERMI UNIT 2 3 REVISION 11. 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 - PRIMARY CONTAINMENT can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the bypass leakage within limit.

TECHNICAL CHANGES - LESS RESTRICTIVE

Speci fic" L.1 CTS 4.6.2.1.h requires obtaining NRC review and approval of subsequent test schedules following any failure of a drywell to-suppression chamber bypass leak test. ITS does not retain the requirement for this request. but does retain the explicit requirement for increased testing (every 9 months) if two tests fail. Reporting of the failure of any bypass leak test is '

adequately addressed by appropriate compliance with 10 CFR 50.72(b)(2)(i) and 50.73(a)(2)(v)(D). 10 CFR 50.72(b)(2)(i) '

requires a verbal notification to the NRC in the event a principal safety barrier is seriously degraded. 10 CFR 50.73(a)(2)(v)(D) requires an LER to be submitted for any event or condition that could have prevented the fulfillment of the safety function needed to mitigate an accident. Compliance with these requirements will ensure that the NRC is informed. as appropriate, of significant test failures. Review of the acceptability of any subsequent revision to the normal test schedule is at the discretion of the NRC. including the Resident Inspector. Explicit approval is not deemed necessary in light of these controls. These details are not required to be in the ITS to provide adequate protection of the public health and safety because any necessary test schedule revisions will continue to be under the oversight of the NRC via onsite inspection. This approach provides an effective. level of regulatory control and provides for a more appropriate test scheduling process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement to promptly report significant safety compromises.

Furthermore. NRC and Detroit Edison resources associated with processing test schedule approvals will be reduced. This change l 1s a less restrictive change with no impact on safety.

l FERMI UNIT 2 4 REVISION 11. 07/14/99lh

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 - PRIMARY CONTAINMENT RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable ' content of ITS 3.6.1.1 consistent with the BWR STS.

NUREG 1433. Rev. 1.

1 O

i FERMI - UNIT 2 5 REVISIdN11, 07/14/99l

Primary Containment 3.6.1.1 (C7S)

,.) SURVEILLANCE REQUIREMENTS I RAi-7 SURVEILLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and l TE / l (n'i'ia>-

leakape rate testing except for primary 5 .0.2 not containment air lock testing, in pitca j g,(,, g,g a, .J

_accordance withAD cr 30, Appenai e-- .

sa py app ed exemptic (4Q,g, (asmoa .

T eakage r acceptance er erion is JwithI FR 5 ,

1.0 L ' ver, during t first unit 1 Appe xJ s startup,.fo owi testing rformed in fled accordan with 0 CFR Appendix J, s , pr'ov modifi by approved ex tions, the im- ons leak e rate acceptan criteria a -

<0 L for the T and Type C ests r+kt fri w e Conki{iM

< 0,.75 L, for Type A tes leakagt, Ro Tis 6ng froam __

o.'L SR 3.6.1.1.2 Verify drywell o suppression chamber (18monthsg differential ressure does not decrease h.4 2.l.h at a rate > inch water gauge per MlD minute tested over a 9 01 minute period at an initial differdni na pressure of - ----NOTE-----

41gpsid. Only required after two i consecutive tests fail and continues until two consecutive tests pass Q monthsg 5

N 7 '

IMSBTLT 3 3 4, l.1 - l / de

'T l

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4WR/ASIL- 3.6-2 itn 1, 0;/07/ w

^~ I Ol N k kWI

1 Primary Containment 3.6.1.1 m .

)

INSERT 3.6.1.1 1 SURVEILLANCE FREQUENCY l SR 3.6.1.1.3 -- --- --- -- -----NOTE ------ ------------ \

Only required to be performed after safety / relief valve operation with the ] .,

suppression chamber average water' temperature I M

2 160 F and reactor c601 ant system pressure

> 200 psig.

Perform an external visual examination of the Once prior to l

suppression chamber. entry into

! MODE 2 or 3

g from MODE 4 l l FERMI UNIT 2 Page 3.6 2 (INSERT) Revision 11. 07/14/99l

Primary Containment B 3.6.1.1 BASES SURVEILLANCE SR 3.6.1.1.2 (continued)

REQUIREMENTS considering it is prudent that this Surveillance be performed during a unit outage and also in view of the fact that component failures that might have affected this test P'E are identified by other primary containment SRs. Two consecutive test failures, however, would indicate J

, ' unexpected +7 M rj x .t i z t degradation; in this event, '8 ggp as the Note indicates, increasing the Frequency to once every(g monthspis required until the situation is remedied i E

W l

( f f,(p,/,[-2., as evidenced by passing two consecutive tests.

r _l 1

i REFERENCES 1.14FSAR,Section16.2{. .I 2 14fSAR, Section El /b'. 8,5 , Z -

3. 10 CFR 50, Appendix

(

q ey

..)

l I

0'.!E/4 TS- B 3.6-5 RevJ ns/n7 fos l

I

_, -% D ,

l Rev 5 3

l Primary Containment i B 3.6.1.1 g .

i INSERT B 3.6.1.1 2 SR 3.6.1.1.3

' hk I

The primary containment suppression chamber can experience d significant hy'drodynamic loading during safety / relief valve g (SRV) operation with the suppression pool average water s temperature 2 160*F and reactor coolant system pressure

> 200 psig. After SRV operation during these conditions, a

{ j visual examination of the exterior surface of the suppression chamber will identify any abnormal conditions g I that may warrant further inspection and review for continued OPERABILITY. This examination is performed prior to resuming operation in MODES where primary containment is required to be OPERABLE. l l

-)

)

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FERMI UNIT 2 Page B 3.6 5 (INSERT) Revision 11. 07/14/99 j

l JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.1 - PRIMARY CONTAINMENT NON BRACKETED PLANT SPECIFIC CHANGES P.1 Not used.

P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses.

P.3 Not used.

P.4 The ITS details of leakage rate tests are relocated to the Primary Containment Leak Rate Testing Program, which is being added to Section 5. Administrative Controls. This presentation is '

generally consistent with CTS presentation (which already includes an Administrative Controls Program for primary containment leak j rate testing). Additionally, this change is in accordance with (unapproved) Generic Change TSTF 52. application of 10 CFR 50 Appendix J. Option B.

1 P.5 The suppression pool bypass test tests a " boundary" that is j internal to the primary containment - literally not a part of the {

primary containment boundary. This change therefore, represents an editorial correction.

P.6 ISTS SR 3.6.1.1.1 Bases provides clarification that certain {

leakage tests (secondary containment bypass purge valve, and MSIV) do not impact the SR 3.f.1.1.1 requirement for 10 CFR 50.

Appendix J. Option B leakage testing. An additional leakage test n

in is included in this Bases list - hydrostatically tested lines.

This provides necessary clarification and completeness listing all additional leakage tests required by ITS Specification 3.6.1.3 V that are not intended to be covered by ITS SR 3.6.1.1.1. f 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 SR 3.6.1.1.3 is added to reflect CTS 4.6.2.1.d. This visual exam is removed from the NUREG based on NED0 30833, which is not T7 applicable to the Fermi design. As such, the CTS requirement is N retained. Given the visual exam is related to verification of the 9 primary containment boundary, it is retained as a surveillance for [

Primary Containment Operability.

,0 Q 1 FERMI UNIT 2 1 REVISION 11 07/14/99l 4

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l PCIVs I

( 3.6.1.3 l ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME l

l Qm

\

3 D. One or more secondary D.1 Restore leakage rates 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for W containment bypass to within limit. leakage on

! Y leakage rate. MSIV hydrostatically l leakage rate, purge tested line valve leakage rate, without a closed i hydrostatically tested system y line leakage rate, or

- EFCV leakage rate not M k within limit.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for secondary containment bypass leakage M

n d 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV hl leakage M

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

M 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for i leakage on 1

, \n hydrostatically a tested line on a l

@ closed system and EFCV leakage s

r jl E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i associated Completion p Time of Condition A. M g B. C. or D not met in Y MODE 1. 2. or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued) l FERMI - UNIT 2 3.'6 11 Revi sion~ 11. 07/14/99 l

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r PCIVs 3.6.1.3

~

ACTIONS (continued)

C0WITION REQUIRED ACTION COMPLETION TIME

^ F. Required Action and F.1 Initiate action to Immediately

=

'$l associated Completion Time of Condition A.

isolate RFR Shutdown Cooling System.

B. C. or D not met for gh) RHR SDC PCIV(s) required to be 2

Cl OPERABLE during MODE 4 or 5.

F.2 Initiate action to restore valve (s) to Immediately OPERABLE status.

SURVEILLANCE REQUIREENTS SURVEILLANCE FREQUENCY R

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

Not required to be met when the isolation valves for one purge or containment

/T) pressure control supply line and one W purge or containment pressure control exhaust line are open for inerting. de-inerting, pressure control. ALARA or air quality considerations for personnel entry. or Surveillances that require the valves ~to be open.

m hV Verify each drywell and suppression chamber purge system and containment 31 days 3 pressure control isolation valve is closed.

L(>

(continued)

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l FERMI UNIT 2 3.6 12 Revision 11 07/14/99 i-

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.10 Remove and test the explosive squib from 18 months on a each shear isolation valve of the TIP STAGGERED TEST System. BASIS

&l I

SR 3.6.1.3.11 Verify the combined leakage rate for all In accordance !

secondary containmer.t bypass leakage with the paths that are not provided with a seal Primary system is s 0.04 L, when pressurized to Containment

= 56.5 psig. Leakage Rate Testing Program and Inservice nl Testing Program d

SR 3.6.1.3.12 Verify combined MSIV leakage rate for all In accordance L four main steem lines is s 100 scfh when with the tested at = 25 psig. Primary Containment Leakage Rate Testing Program SR 3.6.1.3.13 - ........... --- .N0TE- ------.--......-

Only required to be met in MODES 1, 2 and 3.

n fl Verify combined leakage rate through In accordance hydrostatically tested lines that with the ~

h

%l penetrate the primary containment is within limits.

Primary Containment b Leakage Rate i Testing Program I

l l

! FERMI UNIT 2 3.6 15 Revision 11 07/14/99

PCIVs B 3.6.1.3 BASES.

LC0 (continued)

The normally closed manual PCIVs are considered OPERABLE when the valves are closed and blind flanges are in place, t or open under administrative controls. Normally closed automatic PCIVs. are required to have isolation times within limits and actuate on an automatic isolation signal. These passive isolation valves and devices are those listed in Reference 2. -

Purge valves with resilient seals, secondary containment bypass valves. MSIVs. EFCVs. and hydrostatically tested valves must meet leakage rate requirements in addition to -

the other PCIV leakage rates which are addressed by LCO 3.6.1.1. " Primary Containment," as Type B or C testing.

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

APPLICABILITY In MODES 1. 2. and 3. a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.1

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

i M ACTIONS The ACTIONS are modified by a Note allowing penetration flow l dl' path (s) to be unisolated intermittently under administrative 1 controls. These controls consist of stationing a dedicated i operator at the controls of the valve, who is in continuous 1 Q@c V

communication with the control room. In this way, the l penetration can be rapidly isolated when a need for primary j containment isolation is indicated. Due to the size of the '

primary containment purge line penetration and the fact that l those )enetrations exhaust directly from the containment I atmosp1ere to the environment, the penetration flow path

~~

l FERMI UNIT 2 B 3.6.1.3 -4 Revision 11. 07/14/99 i

PCIVs B 3.6.1.3

) BASES ACTIONS (continued) containing these valves is not allowed to be opened under administrative controls.

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

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

Required Actions.

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

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

A.1 and A.2 With one or more penetration flow paths with one PLIV inoperable except for leakage (i.e., secondary containment bypass leakage rate. MSIV leakage rate, purge valve leakage 4 ate, hydrostatically tested line leakage rate, and EFCV leakage rate) not within limit. the affected penetration flow paths must be isolated The method of isolation must A include the use of at leact one isolation barrier that cannot be adversely affected by a single active failure.

d D Isolation barriers that meet this criterion are a closed and de activated automatic valve. a closed manual valve. a blind flange, and a check valve with flow through the valve secured. For a penetration isolated in accordance with Required Action A.I. the device used to isolate the b penetration should be the closest available valve to the primary containment. The Required Action must be completed i

within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam

, N' lines). The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable considering the time required to isolate the penetration and the relative importance of supporting primary containment l FERMI UNIT 2 B 3.6.1.3 - 5 Revision 11 07/14/99

PCIVs B 3.6.1.3

~

' BASES

]'

ACTIONS (continued).

OPERABILI1Y during MODES 1, 2. and 3. For main steam lines, an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is allowed. The Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the main steam lines allows a period of time to restore the MSIVs to OPERABLE status given the fact that MSIV closure will result in isolation of the main steam A

( line(s) and a potential for plant shutdown.

For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path (s) must be verified to be isolated on a periodic basis. This is necessary to ensure that primary a containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated. Will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside primary containment" is appropriate because the devices are operated under administrative controls and the probability of their misalignment is low. For the devices inside primary containment, the time period specified " prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the devices and other administrative controls ensuring that device misalignment is an unlikely possibility.

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

Condition C provides the appropriate Required Actiong.

el Required Action A.2 is modified by two Notes. Note 1 d

W-applies to isolation devices located in high radiation areas, and allows them to be verified by use of s administrative means. Allowing verification by G administrative means is considered acceptable, since access t to these areas is typically restricted. Note 2 applies to

\ isolation devices that are locked, sealed, or otherwi:;e

( secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable since the function of locking, sealing, or FERMI UNIT 2 B 3.6.1.3 - 6 Revision 11, 07/14/99

PCIVs B 3.6.1.3

~

] BASES ACTIONS (continued) securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of

g. misalignment of these devices, once they have been verified to be in the proper position, is low.

' lL1 With one or more penetration flow paths with two PCIVs inoperable, except for leakage-(i.e., secondary containment bypass leakage rate, MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV -

leakage rate) not within limit, either the inoperable PCIVs must be restored to OPERABLE status or the affected penetration flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one' isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a ,

closed manual valve, and a blind flange, The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months !

Completion Time is consistent with the ACTIONS of LCO 3.6.1.1.

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two PCIVs.

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

C.1 and C.2 d With one or more penetration flow paths with one PCIV h inoperable, except for leakage (i.e., secondary containment bypass leakage rate. MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate..and EFCV h leakage rate) not within limit, the inoperable valve must be restored to OPERABLE status or the affected penetratfon flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation

t. barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve and a y

\ blind flange. A check valve may not be used to isolate the affected penetration. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is a reasonable considering the time required to isolate the ,

penetration and the relative importance of supporting i o(c primary containment OPERABILITY during MODES 1, 2. and 3.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for penetrations with a l

~ l

! FERMI - UNIT 2 B 3.6.1.3 - 7 Revision 11, 07/14/99 i I

PCIVs B 3.6.1.3

~

] BASES ACTIONS (continued) closed system is reasonable considering the relative stability of the closed system (hence, reliability) to act I as a penetration isolation boundary and the relative importance of supporting primary containment OPERABRITY during MODES 1, 2, and 3. The closed system must meet the requirements of Reference 4. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for EFCVs is also reasonable considering the instrument and the small pipe diameter of penetration (hence, reliability) to act as a penetration isolation boundary and the small pipe diameter of the affected penetrations. In the event the affected penetration flow .

A path is isolated in accordance with Required Action C.1, the d affected >enetration must be verified to be isolated on a periodic ) asis. This is necessary to ensure that rimary containment penetrations required to be isolated f llowing an accident are isolated. The Completion Time of once per

. 31 days for verifying each affected penetration is isolated is appropriate because the valves are operated under y administrative controls and the probability of their misalignment is low.

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

Conditions A and B provide the appropriate Required Actions.

Required Action C.2 is modified by two Notes. Note 1 applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the arobability of misalignment of these valves, once they have

>een verified to be in the proper position, is low. : Note 2 ap) lies to isolation devices that are locked, sealed,' or otlerwise secured in position and allows these devices to be

' verified closed by use of administrative means. Allowing verification by administrative means is considered Y acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.

! FERMI UNIT 2 B 3.6.1.3 - 8 Revision 11 07/14/99

PCIVs B 3.6.1.3

~

} BASES ACTIONS (continued)

I D.l o With one or more secondary containment bypass leakage rate (SR 3.6.1.3.11), MSIV leakage rate (SR 3.6.1.3.12), purge valve leakage rate (SR 3.6.1.3.6), hydrostatically tested line leakage rate (SR 3.6.1.3.13), or EFCV leakage rate (SR 3.6.1.3.9) not within limit, the assumptions of the safety analysis may not be met. Therefore, the leakage must be restored to within limit. Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de activated automatic valve, closed manual valve, or blind flange. When a penetration is isolated, the leakage rate for the isolated i penetration is assumed to be the actual pathway leakage o through the isolation' device. If two isolation devices are q used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices.

Q The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for leakage on hydrostatically tested lines and for secondary containment bypass leakage is reasonable considering the time required to restore the leakage by isolating the penetration and the relative N'

importance of leakage to the overall containment function.

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

Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for MSIV leakage allows a period of time to restore the MSIVs to OPERABLE status given the fact that the MSIV closure will result in isolation of the main steam line(s) and potential for plant shutdown. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time for purge valve leakage is acceptable considering the purge valves remain closed so that a gross breach of the containment does not exist. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for EFCV leakage is acceptable based on the instrument and small pipe diameter of the penetration (hence, reliability) to act as a penetration isolation boundary. .,

Q s l E.1 and_LZ If any Required Action and associated Completion Time cannot be met in MODE 1, 2. or 3. the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience. to reach the required plc1t conditions from full power conditions in an orderly manner and without challenging plant systems.

l FERMI UNIT 2 B 3.6.1.3 - 9 Revision 11 07/14/99

PCIVs B 3.6.1.3

~

) BASES SURVEILLANCE REQUIREENTS (continued) y Secondary containment bypass leakage is also considered part

l of L,.

'SR 3.6.1.3.12' The analyses in References 1 and 4 are based on leakage that is less than the specified leakage rate. Leakage through all four main steam lines must be s 100 scfh when tested at a P (25 >sig). This ensures that MSIV leakage is properly accountec for to assure safety analysis assumptions. 1 regarding the MSIV LCS ability to provide a positive e pressure seal between MSIVs. remain valid. This leakage test is performed in lieu of 10 CFR 50. Appendix J. Type C test requirements, based on an exemption to 10 CFR 50. .

Appendix J. As such. this leakage is not combined with the Type B and C leakage rate totals. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.13 a

Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the a number of valves per penetration, not to exceed 3 gpm when o (= 62.2 psig). Additionally, a combined M tested leakageatrate1.1lim P,it of s 5 gpm when tested at 1.1 P

% (a 62.2 psig) is applied for all hydrostatically tested

-Q PCIVs that netrate containment. The combined leakage rates must demonstrated in accordance with the leakage rate test Frequency required by Primary Containment Leakage Rate Testing Program.

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

In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1. 2.

and 3. However, specific leakage limits are not applicable in these other MODES or conditions.

l FERMI . UNIT 2 B 3.6.1.3 '.6 Revision 11 07/14/99 l

i Spcc,Rc 4ts., 3.s.I.3

( Als. s ee Specified:n f.s.t .t)

CONTs1NHENT SYS'Evi (hiso fe e. Specifica%n f. 7) 11MITING CONOTTION rop oprocT10N (Continueo -

ACTION: (Continued)

o. ine cc.::ne ieanage rate for ;rmary c:ntainment penetrations and

.g"" primary containment isolation valves subject to Type B and C tests in accoreance with the Primary Containment Leakage Rate Testing 6Fecif.cdf o4 Program, except for main steam line isolation valves

and primary f", y I containment isolation valves which are hydrostatically tested, Qasts to less than or equal to 0.60 La, and

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

d. ) The combined leakage rate for all containment isolation salves in y -

fcppy p 4 ' hydrostatically tested lines which penetrate the primary containment {0, Jets,3,asn or penalp gp and g-

e. The leakage rate of any hydrostatically tested linehetratino _ $ ,

primary containmentti isss T,nay a wm pry avi.6 vaive s) N i

/the gamDer of conta nt isol tratio r lafs ation/ ption valves ner n Q V 3 gem der pen SURVEfl1aNCE REOUTREMENTS i n 4.6.1.2 Perform required primary containment leakage rate testing in

,1 / ,7 accordance with6.8.5.g.**

the Primary Containment Leakage Rate Program described in Specification b See l' Spreifica tio n l 3.(, l .\

k

', S 8. 3 6 , ( <3, l2 Freyency l

~

S(L 3 6 . I. 5,13 Fnpany 1 4 l \

1

%D: SR 3lo.l.%l\ h Aukvn D & N I&

Setou w % o me w 9 m ( d a y l

ge e,

Exemption to Appendix J of 10 CFR Part 50 l 6fcc&lcAfiw *Except for LPCI Loop A and B Injection Isolation valves, which are l

$ 5- hydrostatically tested in accordance with Specification 4.4.3.2.2 in lieu {

of titis requirement. ,

FERH1 - UNIT 2 3/4 6-3 Amendment Ifo'. Jp2,108

_j Ra/ H e t

PAGE I 0F 09 8ev R

QEcoPtotrie4 34,l.3 A .

) CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM QMITINGCONDITIONFOROPERATION sgg,g3,( 3.6.1.8 The drywell and suppression chamber purge system '; ...w., N.......

^^ ind. : ' 2' '-" """-Q may be in operation with the supply and exhaust '-

isolationorvalves deinertin pressure in one supply control. Nitrogen line andVENTINGone exhaust

/ makeupline andopen for inerting, pressure contro l, I

2:

N,.a so a,p,pgp tg pinch valvg

. /....; g.. .ti... .... ..P

i

(, f Q APPLICABILITY: OPERATIONAL CONDITIONS 1,g2 and 3. j l g,I.lgg:

ADe ArTroNS NorEt y Ac,yjegs gory a )

.g g i a.

hAf 4c77aAbr mioTF 3 >

With a drywell and suppression chamber purge system supply and/or W

)

@f3Mb exhaust isolation valve open, except as permitted above, close the, valve (s) or otherwise isolate the penetration (s) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD OC N b SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

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

4.6.1.8.2, restore the inoperable valve (s) to OPERABLE status f% within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months er be in at least HOT SHUTDOWN within the next 12 % e4

} M od b hours and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

lf (A00; AcnorJ B }

L .2.

SURVEftlANCF REOUIREMENTS 5 4 % 1 3 .1 4.6.1.8.1 [Before beina opened hr purge / vent operation E- d SET 51 the in fJ pTE - drywell ano suppression enamDer purge supply and exhaust butterfly isolation 7 valves shall throwgh-! be,verified T: T., w " : . ; . not

. . . .to ., .have

. . ; .'. been

. open

- i:::for 255purge d:,;." / vent op:eratio L.I E

~4.6.1.8.2 At least once per[92 days}

N NO*4 10 . .0, ation for each ? ......, ;.0

.;d 20 're, :-d : '. n ' :' drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals sha_1.1 be :

demonstrated OPERABLE by verifying that_the measured leakage rate ' '-" '- J

{ ;;.;.: ;. p.= ', " - ; :::r----- '^ t

~

f( J.42,3s / _* Primary containment nitrogen VENTING and pressure control is pemitted I through the 1-inch valves :.d i: r:t :djart 'a the 90 Mu : per 255 dr~

w -

1 4 FERMI - UNIT 2 3/4 6-14 Amendment No 58 PAGE [0 - 0F 09 f

r C. . ,

Sptt urocATIou 3.G.I.'b -

Q-CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS 4.6.3.1 ach primary contai isolation valve shall demonstrated j OPERA 8 prior to returning t valve to service after sintenance, repair o repl nt work is perfo on the valve or its as ciated actuator. con o /R,l or r circuit by cyclin the valve through at le t one complete cycle f W1 travel and verifyina ha i=^1='iao +4== *- 8 o o~

A gg g g,g,3,g 4.6.3.2 Each primary containment'autosptic isolationivalve shall be demonstrated OPERABLE (uvrtwrc0L" '"" " e ore"9- hat least once per 18 months by verifying that on a containment isolation est signal each automati q(l isolation valve actuates to its isolation position, ciual a s; mig,

.g j,qq,f,f4.6.3.3 The isolation time of each primary containment (poweroper4 Lee automatic valve shall be determined to be within its limit when tested

l pursuant to Specification 4.0.5.

i l

54 5*0'f'3'9 : 4.6.3.4 Each reactor demonstrated OPERA instrumentation 8LE at least once line excess per 18 monthsflow check valve by verifying shall that the valvbe '

' Q IOW* (fg3 4c1c'iD -

t j

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

k l J

M 5 4.l,5 4 a. At least once per 31 days by verifying the continuity of the explosive charge. ,p 434 g-g 4.l

~

M W' 'g b. At lea Q once per 18 months ist Tenst o5e_explosi~ela'lve[hy such that 'reInov ng tTe' the explosive exp~losive squib in hl Ydib 6oDi x_plejivnvalyeytil be tested at least onc,e_per 90 pgnths _

nitiatino the exo es We soui6~ fri, y.a.-......., i v, ww3 1 expl ed squib sha' be from the sa manufactured ba h as the one tred or from nother batch wh h has been certi ed by ha ing at least e of that bate successfully fire . No squ all remain in se beyond the piration of its s elf-life perating life as applicable. f --

PAGF T OF 09 Rev5i

SPgctPt @md 3. <,. l. 3 REACTOR COOLANT SYSTEM 3/4.4.7 MAIN STEAM LINE ISOLATION VAtVES tIMITING CONDITION FOR OPERATION LCO 3.G.I.3 3.4.7 Two main steam line isolation valves (MSIVs) per main steam line shall M 3' M *3*I be OPERABLE with closing times greater than or equal to 3 seconds and less than or equal to 5 seconds. 1 ho h4 Nm I)

APPLICABIt'TY: OPERATIONAL CONDITIONS 1, 2, and ,

ACTION: *9 ACT104 Acmont MawsMOTE 3 4q 2.h) .

g y 4 a. With one Ecr more1MSIVs inoperable: Add MTioM 6 L. 2.

1. { Maintath at least one MSIV OPERABLE in each affected main steae (lir.e that is ODen/fiid within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , either:

g o... . u. 4. -...m m . g , , ; . 2:my r .....- e g,q b) Isolate the afdected main steam line by use of a t ga (Beactivated M5 10in the closed position. ,ll 1 kgg g 2. Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months k I and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

( \

(.. __

g Y

SURVFillANCF RFOUTRFMFNTS -f

'U ' 4.4.7 Each of the above required MSIVs shall be cemonstrated OPERABLE by verifying full closure between 3 and 5 seconds when tested pursuant to k

Specification 4.0.5.

l I

FERMI - UNIT 2 3/4 4 24 Amenoment No. 83

~_.

Rev11 ll C

PAGE _0F 09 fev Si i

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs necessarily apply. Since the clarifications are consistent with the intent and interpretation of the CTS, this change 15 considered administrative with no impact on safety.

A.10 CTS 3.6.3 Actions b.1 and b.2 detail specific mcchods of restoring inoperable EFCVs. Since the specific Operability criteria

^

associated with EFCVs is that they actuate to restrict flow (which is essentially a e,ualitative leakage rate r'.quirement). EFCV are D also included in ITS Action D for leakage not within limit. For h simplicity in presentation, ns 3.6.1.3 Action D combines the actions for all the various PCIV leakage rate failures into a Q

single action to " restore leakage rates to within limits.*' This is equivalent to the CTS options to return to Operable status, or isolate the instrument line. As such, this change is considered administrative only, i

A.11 Not used. l1 k

l y

i i

so =

FERMI - UNIT 2 3 REVISION 11 07/14/99l

DISCUSSION OF CHANGES f3 ITS: SECTION 3.6.1.3 PCIVs V

LA.5 CTS 3,6.1.2 LC0 items d and e, and Actions d and e contain explicit acceptance criteria for the hydrostatic leakage test limit. ITS SR 3.6.1.3.13 maintains the required hydrostatic n leakage test, however, the specific acceptance criteria are to relocated to the Bases. These details can be adequately defined g and controlled in the Bases which require change control in y accordance with ITS 5.5.10. Bases Control Program. These details L are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the equipment Operable.

LA.6 CTS 4.6.3.2 requires an automatic isolation valve test, but restricts performance of this test to "during Cold Shutdown or Refueling." ITS SR 3.6.1.3.8 requires this same test, but removes i details regarding requisite plant conditions and scheduling.

These details do not impact the requirement to maintain the valves Operable, and the ITS SR continues to ensure that all automatic PCIVs function properly. Therefore, this change will not have any 9 negative impact on safety. Removal of this restriction was I recommended by and supported in Generic Letter 91 04, and is consistent with the ISTS NUREG 1433. The ITS Bases continue to k

\ acknowledge that, at least for many of the PCIVs it is prudent to conduct the testing during outages: as such, this aspect of the i CTS restriction is relocated to the ITS Bases, which require change control in accordance with ITS 5.5.10, Bases Control '

Program.

LA.7 CTS 4.6.3.3 requires determination of the isolation time of power operated as well as automatic PCIVs. ITS SR 3.6.1.3.5 (in conjunction with approved generic change TSTF-46) requires only the determination of the isolation time for automatic PCIVs. The requirement for Ctermination of the isolation time for non-automatic power operated PCIVs is relocated to the IST Program, which requires changes be made in accordance with 10 CFR 50.55a.

The relocation of this testing will not impact the function of :

these valves, or the periodic verification of their Operability.

As such there is no adverse impact on the health and safety of the public.

O' FERMI - UNIT 2 7 REVISION 11 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs O.

V LR.1 CTS SR 4.6.3.1 requires a demonstration of operability after maintenance or repair on an isolation valve. The change removes this explicit requirement form Technical Specifications.

Verifying proper Operability including stroke time, of these valves after maintenance on these valves is normal maintenance and operating practice. In addition. the requirement to verify the correct stroke time of these valves per the IST Program is required by ITS SR 3.6.1.3.5. Consequently. Operability of these valves is specifically required, and periodically verified.

Therefore removal of the requirement to verify operability of the valve after maintenance is considered acceptable. The relocation of CTS SR 4.6.3.1 maintains consistency with NUREG 1433.

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

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

b LR.2 Not used. l LR.3 Not used. l LR.4 Not used. l l O

l TECHNICAL CHANGES LESS RESTRIGIlyE

" Specific" j L.1 CTS 3.6.1.8 and 4.6.1.8.1. time limits on opening primary containment purge valves while aligned to SGTS, are replaced with specific criteria for opening. In conjunction with this, the I surveillance frequency to monitor compliance is revised from

before being opened" to a nominal 31 days (which is typical of other valve lineup SRs). These criteria are also applied to the 1-inch valves (as a more restrictive change discussed here for

l. completeness). The time limits were based on engineering judgment Y and/or early plant operating experience. and not based on any analytical requirements. ITS 3.6.1.3 limits on when the valves are permitted to be open are provided in the Note to SR 3.6.1.3.1.

The new limits will allow the valves to be open for inerting and de inerting. ALARA or air quality considerations for personnel entry, as well as for Surveillances that require the valves to be g open. Thus, use of the purge system will still continue to be minimized and limited in extent. The operating history indicatas FERMI UNIT 2 8 REVISION 11 07/14/99l

DISCUSSION OF CHANGES

/~ ITS: SECTION 3.6.1.3 - PCIVs L}J that these valves are only opened for the specified reasons and for cumulative periods that are generally less than the current allowed cumulative times. In addition, these valves are fully qualified to close in the required time under accident conditions.

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

L.2 CTS 3.6.1.8 and CTS 3.6.3 Actions for inoperable containment l isolation valves, and CTS 3.4.7 Actions for inoperable MSIVs. a which require maintaining one isolation valve OPERABLE, would not be met in the event both valves in a penetration are inoperable.

In this event, an immediate shutdown (per CTS 3.0.3 for 3.6.1.8, CTS 3.6.3 Action a. or CTS 3.4.7 Action a.2, "otherwise ") is required. ITS 3.6.1.3, Action B provides 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for restoration, prior to commencing a required shutdown. This 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period is consistent with time allowed for an inoperable containment, and is therefore an appropriate allowance.

t L.3 CTS 3.6.3 Action b allows only 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore EFCVs to Operable status or to isolate the associated instrument line flow &

. O path. Furthermore CTS 3.6.3 Actions result in an immediate l

shutdown for penetrations that have a single PCIV that is l inoperable. ITS extends the restoration time for these single Q{

valve penetrations to either 4 or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . b

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

! Discussion of Change "A.10" for administrative changes to the presentation) allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the instrument line j flow path, and allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Each of these instrument lines j at Fermi is designed with a small diameter, have an installed ;

restricting orifice, and terminate at an instrument transmitter !

or similar device (which serves as another boundary).

Furthermore. an assumed instrument line break, with the failure of the EFCV. would still result in a response within the bounds of the safety analysis. k

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

- containment boundary afforded by the closed system. The majority of these single valve penetrations also terminate FERMI - UNIT 2 9 REVISION 11. 07/14/99 s

)

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs 4

7 below the minimum level of the suppression pool such that they l j

are expected to retain a water seal (fission produce barrier) throughout the accident.

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

i L.4 Not used.

L.5 Not used. l L.6 CTS 4.6.1.1.b and 4.6.1.1.b.1, require periodic verification that the isolated penetration remains closed. ITS 3.6.1.3, Notes 1 and D '

Q 2 to Required Actions A.2 and C.2, and Note 1 to SRs 3.6.1.3.2 and V 3, allow for administrative verification when the_ isolation device is in an area with limited access due to high radiation or is locked, sealed, or otherwise secured in the closed position.

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

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

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

O FERMI - UNIT 2 10 REVISION 11 07/14/99 ( k

I DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs L.7 ' CTS 4.6.1.8.2 requires leak testing the purge valves with resilient seals once per 92 days. ITS 3.6.1.3.6 requires this testing every 184 days, with the added limitation of "once within 92 days after opening the valve." Since the re closing of an opened purge valve that has resilient seals is a major factor in deterioration of the sealing capability, extending the leak test from 92 days to 184 days for purge valves that have not been l opened is deemed acceptable. Furthermore, plant specific I experience with purge valves that have not been opened f demonstrates the continued expected leak tightness of these valves ;

when tested at the current 92 day frequency. Therefore, extending the frequency to 184 days (in accordance with NUREG 1433) does not involve a significant impact on safety.

.L.8 CTS 4.6.1.1.b requires the periodic verification of the closed status of non-automatic PCIVs. If this requirement can not be met, the Actions of 3.6.1.1 require restoration in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to commencing a shutdown. ITS 3.6.1.3 provides these SRs as part of the PCIV. specification, and results in restoration times of from 4 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to commencing a shutdown. These extended Completion Times are consistent with NUREG-1433 (as modified by 3- approved TSTFs), and are in recognition of the limited impact on the overall containment function and the reasonableness of a limited time to affect repairs prior to commencing a plant shutdown transient. p(n CTS 4.6.3.4 requires testing to verify that each EFCV " checks L.9 flow." ITS SR 3.6.1.3.9 (consistent with NYREG 1433) requires verification that each EFCV " restricts flow." While actual

(

implementation, practice, and interpretation is unchanged by this revision, the CTS wording " checks flow" could be interpreted to require a zero flow acceptance criteria, while the ITS wording

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

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

FERMI UNIT 2 11 REVISION 11 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 PCIVs J

L.10 CTS 3.6.3 Action a.3 explicitly lists some, but not all, possible acceptable isolation devices that may be used to satisfy isolating a penetration with an inoperable isolation valve. Many penetrations are designed with check valves as acceptable isolation barriers. With forward flow in the line secured, a check valve is essentially equivalent to a closed manual valve.

Therefore, the action has been modified to provide a more explicit list of acceptable isolation devices. which includes a check valve with flow secured. Since the result of the action continues to be an acceptably isolated penetration for continued operation and is consistent with the intent of the CTS action, the change does not involve a significant impact on safety.

L.11 CTS 4.6.1.1.b and 3.6.3 Action a.3 contain a requirement for a manual valve (which is closed to isolate a penetration) to be locked. CTS 3.4.7 Action a.1.b) requires use of a deactivated MSIV which, in the case of the third MSIV, is a type of " locked" Q

manual valve. With a penetration closed using a manual valve, a $

passive barrier is established, i.e., one not subject to a single E active failure. ITS 3.6.1.3 Actions. ITS SR'3.6.1.3.2. and SR 3.6.1.3.3 do not detail the locking (or deactivating) of manual s valves used to isolate penetrations. Regulatory control of .

l changes to these requirements (e.g., Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate ;

j protection of the public health and safety since Technical j Specifications continue to require that position and since the safety significant position of the valve is adequately assured.

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

9 L.12 Not used. lj L.13 CTS 3.6.1.8 and 3.4.7 required purge valve penetrations and MSIV penetrations respectively to be isolated in the event the associated PCIV is inoperable. Similarly. CTS 3.6.3 provides requirements for all PCIVs (including' purge valves and MSIVs), but I

includes an allowance to " reopen on an intermittent basis under administrative control" any penetrations isolated to comply with the Actions. Consistent with the CTS 3.6.3 allowance, this

),!.

explicit allowance is provided in ITS 3.6.1.3 Actions Note 1.

This will have minimal impact on safets since the change resolves

._ an inconsistency between the CTS 3.6.5 allowance and the CTS 3.6.1.8 and CTS 3.4.7 implicit lack of the same allowance. The t resolution is consistent with NUREG-1433 provisions.

FERMI UNIT 2 12 REVISION 11 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.3 - PCIVs O- !

RELOCATED SPECIFICATIONS None.

IECHNICAL SPECIFICATION BASES The' CTS Bases for this Specification.have been replaced by Bases that reflect -

the format and applicable content of ITS 3.6.1.3 consistent with the BW STS.

NUREG 1433. Rev. 1.

l l

77, O

FERMI - UNIT 2 13 REVISION 11 07/14/99l w

PCIVs 3.6.1.3 Insert 3.6.1.3 2

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

i Insert 3.6.1.3 3 l CONDITION REQUIRED ACTION COMPLETION TIME D. One or more secondary D.1 Restore leakage rate 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for leakage on /3.(..t.7.h '

containment bypass to within limit. hydrostatically tested \Acma5/

leakage rate, MSIV line without a closed l

leakage rate, purge system valve leakage rate, hydrostatically M tested line leakage rate, or EFCV leakage 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for secondary &c.a.4) rate not within containment bypass limit. leakage M

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

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for purge /3-(*L*8 valve leakage (4'"#

M 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for leakage "h on hydrostatically tested line on a closed system and EFCV [343h leakage \Mbf FERMI UNIT - 2 Page 3.6-10 (INSERT) REVISION 11. 07/14/99 ll' i

PCIVs 3.6.1.3

,, SURVEILLANCE REQUIREMENTS (continued) .

I SURVEILLANCE FREQUENCY

]tt SR 3.6.1.3. 7 \ \

_g-- .

/

,_. _.., .. ... . v =s6 u n . .www 4

' ' ' . :-f ?_' -

e

%e"ce.iteMellLese!_t:f--i=**-

e 'y

.;t r :: :-it--it 9 5". 3.5.1.1.1 / i M

p 5-*- + r= wit' 10 C"" % ,

. : T;;d 5, _e;r:::_ -

' I d Verify the combined leakage rate for all hork secondary containment bypass leakage-

/ pathsfis S $ L,} when pressurized to T--

S

--NOT - 2) 3.0.

s not Vided h.4^

W 2i psig)r.

9 0 04 appli ble W. J RakSfsit In accordance

+fcfrII*w W,omt, with , ,, ,

fel ..- leakap 0kE5Mnj [ endi J, T frvgram and "ge fi 1 pj lMay vice,95h03 3_ ,[ng, J 3

( Pro w e -

Di2 to -

SR 3. 6.1.3 J5 Verif eakage ratt, is ----

TE-- - .%.t.L.c-

__ s' Hscfh whenftested at S .0.2 Cohbacd 2- Epsig. J g,g 47g,73 not G'l 1(/

D' V (64<4 m D nes j i_S$

.2 . #

@..' Q,. In accordance.

I* with I4iu. Fria w y M i.a

f ' r }wm A

f

^= 4 aw; fief-pakge. cakTas6n3 regram L J uy 79-,evea ,

e % ssuus s0

t- -

(continued) a'n/ M TS- 3.6-17 Rev 1, Oi/M/95-(U\/ fev 51 1

[ t l PCIVs B 3.6.1.3 l BASES

                                                                                                               'h  I l
                                                                                                                              )

LC0 3.6.1.7, " Reactor Building-to-Suppression Chamber Vacuum , (continued) Breakersy* /The valves covered by this LC0 are listed with I their astociated stroke times in Reference 2.

                                      - marum11v einned Efve == ca==m-a nornami r %

_x. .;i1:. 4::;;-_;1..i...

                                            ;     t:   ..i ..i:tnti=

c:u.:,arar.treu

= i; u;..

u ..r... .N.. j F Ng f.4 fn==tivited t

f =x,,,,;,,,,,,,;_

                                              - :n 1:;nn,          !d is, ti.ir .r..uen,p d

In.tntic K T

                                                                                      .. ir,teet. These                 s passive isolation valves and devices are those listed in            -      l L6 S.C.l.3 "l7 _"             Reference 2.

Ah2]oNuO k Purge valves with restilent seals, secondary byps:s vaTves, 1 f,1 NSIVs, and hydrostatically tested valves must meet addM4ene4 leakage rate requirements >e JIther PCIV leakage I te are addressed by LCO 3.6.1.1, /* Primary Contai_nme " gg as ype B or C testing, gg g l This LCO provides assurance that the PCIVs will perform l their desigr.ed safety functions to minimize the loss of I reactor coolnt inventory and establish the primary I containment boundary during accidents. I l APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radicactive material to primary containment. In MODES 4 l g and 5, the probability and consequences of these events are i

      )                              reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE-=d th: prin ry urtei s..;.t rm v. ..i... ... ..et-P. '),   n; ;f t; i; :n k d ;l n;d in MODES 4 and 5. Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.1, " Primary Containment Isolation l                                     Instrumentation." (This does not include the valves that isolate the associated instrumentation.)

h

                                                                                                                     'g     ,

ACTIONS The ACTIONS are modified by a Note allowing penetratio'n flow [.3 path (s)) fen;pt fer p.r ; .i; : ;:tMT to be g unisolatedintermittentIyunderada.inistrativecontrols. l I These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous y 6 (continued) 4""/t STS B 3.6-I7 Re" 1, 04/07/95= l Wiv 11 \\ fev E

PCIVs B 3.6.1.3 Insert B 3.6.1.3 17 The normally closed manual PCIVs are considered OPERABLE when the valves are closed and blind flanges are in place, T or open under administrative controls. Normally closed d. automatic PCIVs. are required to have isolation times within limits and act'uate on an automatic isolation signal. ( n 3 i t FERMI UNIT 2 Page B 3.6 17 (INSERT) REVISION 11 07/14/99l

PCIVs B 3.6.1.3 BASES ACTIONS A.1 and A.2 (continued) { O' allows them to be verified by use of administrative means. Allowing verification by administrative means is considered

              /NSER.T ,            acceptable, since access to these areas is typically                       j restrictec.# Therefore, the probability of misalignment of' b U I'bl                  these devices, once they have been verified to be in the 4

proper position, is low. Ad

                    '                                                                                      3 r                      With one or more penetration flow paths with two PCIVs               1 g

[ /A/S M (g g,(,,,(,3- g 2. j inoperable,+either the inoperable PCIVs must be restored to OPERABLE status or the affected penetration flow path must be isolated within I hour. The method of isolation must include the use of at least one isolation barrier that ( cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The I hour Completion Time is consistent with the ACTIONS of LCO 3.6.1.1. Condition B is modified by a Note indicating this Condition r l 1s onlysapplicable to penetration flow paths with two PCIVs. - 1 For penetration flow paths with one PCIV, Condition C provides the appropriate Required Actions. 1 l g Y - C ""d C ? p,6 $blSGT'3 & l,3- % o l With one or re penetration flow paths with one PCIV lE inoperable, the inoperable valve must be restored to g OPERABLE status or the affected penetration flow path must <w be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely l affected by a single active failure. Isolation barriers s I that meet this criterion are a closed and de-activated

       /W N 3 3,(,,(,3 "Ik automatic valve, a closed manual valve, and a blind flange.

A check valve may not be used to isolate the affected '

                                                                                                          'E
                                            ..      5;                ie        tk         o 72         oursjis reasonable    cons,idering the relative stability 1

fde i tne closed system (hence, reliability) to act as a T< penetration isolation boundary and the relative importance

             & pmeroRms           of supporting primary containment OPERABILITY during w; & 4 closed b                                                                        (continued) 8WR/ m                                  B 3.6-20                    h 1, c4/c7/;:i y l[     k fev L I

PCIVs B 3.6.1.3

l Insert B 3.6.1.3-11 Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative me6ns is considered acceptable since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. G in lii W Insert B 3.6.1.3-12

                                      -(2 places) except for leakage (i.e., secondary containment bypass leakage rate, MSIV leakage rate, purge valve leakage rate, hydrostatically tested line leakage rate, and EFCV leakage x              rate) not within limit Insert B 3.6.1.3 16 The Completion Time of 4 hours is reasonable considering the       ,

time required to isolate the penetration and the' relative - importance of supporting primary containment OPERABIL,ITY during MODES 1, 2. and 3. -' k l FERMI UNIT 2 Page B 3.6 20 (INSERT) REVISION 11, 07/14/99l

I PCIVs B 3.6.1.3 , i BASES 1 3 1

 <. . /               SURVEILLANCE         SR   3.6.1.3.       (continued)

REQUIREMENTS required. The replacement charge for the explosive squib shall be from the same manufactured batch as the one fired g , f w b g y re a n or from another batch that has been certified by having one Nof the batch successful' y fired.3 The Frequency of'18 months l

tr* Son [ica, bad (M on a STAGGERED TEST BASL5 is considered adequate given the e,ypyafim of If5 administrative controls on replacement charges and the g pfe, .ec frequent checks of circuit continuity (SR 3.6.1.3 ofuch'nj lah j[

                 ,                  ( SR        3.6.1.3.     -

g fell', This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than th pecified ,; leakage rate. This prevides assurance that t assumptions in the radiological evaluations of Reference are met. The leakage rate of each bypass leakage path is assumed to be the maximum pathway leaka the two isolation valves)ge (leakage through the worse ofunless the pene by use of one closed and de-activated automatic valve, closed manual valve, or blind flange. In this case, the leakage rate of the isolated bypass leakage path is assumed to be the actual pathway leakage through the isolation g /cQ(selaM ) device. If both isolation valves in the penetration are closed, the actual leakage rate is the lesser leakage rate LtdW, *a#gf.

of the two valves. T : ::'t:f ' -"--+i'vi-a =a-i - -

9 fma6 y1tm K.L.., % _'_,_ :. f.L t: M ::-d 'a- +h6 sh fi = 3 Q-

 'J                                pq ) g ; nJ;.           ;      ,. 5 ;; '- '=0-            14=i+e     -+"'                         t f

p gtg ( qr.__...ii;.. ... _;_xf:-- equire.d byg..e^+T^

                                             -;t..

i+' t--di 1)dhe Frequency is.6. r.. k

                                                                     ;0,, .";;:-f'- 2. r 6... ...
                                                                                                 --fi    d ky -
                                                                                              . j;;,.p.;7; ;;n."'}  ,

q g.... - , uv. - .yysi.ui, . . . . . . . . . . .......,.....yy....-

L $ 3,(,,l 6 g _, Ty;; 0 tut. This SR simply imposes additional 9 r - t- : = =iun

                                      % acceptance criteria. #et: :

_tSt ! th:t it;;. isiv.; e,e e..ly r;;;in d t: : n t thi:- p.5 w > : u m 1. 2. =: :. u = x.= - nr.d' t M. , i;.. a..d. :..; ... ';, . . , , ... , ,,. . . ;.. ; ud nd;r.;;T; einsp; retM=n: :rt :: Mett are nur^ r;;. ..J. 5 .- TucJe/_ + & ass leakage is ered part of L,. 4tci;.;;ri note; ceniairm p 4 _ 'Ahn :;nt =1?; - :--t;d) .) PM is (continued) OZ/4 US B 3.6-30 a.= 1, 01/07/95 d 6/ N Av G. llI

r JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433

      .                           ITS: SECTION 3.6.1.3   PCIVs

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

d. The Bases Background includes a clarifying discussion regarding L test vent and drain connections. This clarification was included.

in the Fermi 2 CTS Bases for section 3/4 6.1.1 and is transferred into the ITS. ( P.3 Bases changes are made' to reflect changes made to the Specification. Refer to the Specification change JFD for additional detail. P4 Editorial change made for clarity and consistency between Bases - and the Specification. - Additionally, the Bases discussion of normally closed PCIVs is modified. This editorial preference is based on incomplete and misleading discussion of these valves. This 'does not modify the requirements or the interpretation of those requirements, The LCO Bases are intended to provide a few details regarding i OPERABILITY. These details are not all-encompassing, but only T E serve to outline salient features (in this case of PCIV OPERABILITY). The paragraph discussing normally closed PCIVs attempts to define OPERABILITY of these valves, but makes statements that are not true in all cases. There are lines with g normally closed PCIVs where the PCIV is an automatic isolation valve (e.g.. ECCS test return lines). These valves are NOT required to be deactivated and secured in their closed positioned l to be OPERABLE. Also, blind flanges are a separate isolation boundary, and do not support OPERABILITY of other normally closed PCIVs. Furthermore. OPERABILITY of normally closed PCIVs is not contingent on the status of any associated closed system. ,-

 .               In conjunction with elimination of the erroneous discussions, this paragraph is modified to provide sufficient OPERABILITY detail for normally closed PCIVs. Furthermore, for the Fermi-specific                      '

design, there are no automatic PCIVs that are required to be j normally deactivated and secured in the closed position. J

                                                                                        ,t l
                                                                                                 \

FERMI UNIT 2 2 REVISION 11 07/I4/99l l 1 a

1 i i NO SIGNIFICANT HAZARDS EVALUATION i ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.6.1.3 "L.12" Labeled Comments / Discussions) O I Not used, l 1 l

.\

l I I I l ee. ' f FERMI UNIT 2 21 REVISION 11 07/14/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 - PCIVs

    ..s.,                                                                                          .

TECHNICAL CHANGES - LESS RESTRICTIVE g (Soecification 3.6.1.3 "L.12" Labeled Comments / Discussions) y Not used. l I 1 l 6 88 *

FERMI UNIT 2 22 REVISION 11 07/14/99l

N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.3 PCIVs TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.6.1.3 "L.13' 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? l The proposed change would allow the temporary intermittent opening of penetrations with inoperable PCIVs while under strict administrative control. This change does not affect the PCIV design or function, and failure of a PCIV is not identified as the initiator of any event. ,

Therefore, this proposed change does not involve an increase in the probability of an accident previously evaluated. g The significance of the change to allow the temporary opening of the penetration is minimized through administrative controls and resolves an T inconsistency (where one Specification allows the activity and an other is silent). The consequences resulting from the combination of: 1) the frequency of experiencing a inoperable PCIVs such that temporarily opening the penetration is required: 2) the brief period the penetration would be opened: 3) the dedicated individual to accomplish re closure: and 4) the probability of occurrence of an event that could produce significant consequences; is not considered to be significant. Additionally. providing the ability to eliminate the potential consequences of the transient of plant shutdown (due to inability to intermittently open the penetration) further minimizes the overall consequences of the change. The allowance is proposed to have strict administrative control which will provide assurance that any associated potential consequences are minimized. Therefore. these proposed changes do not involve a significant increase in the consequences of an accident previously evaluated. FERMI UNIT 2 23 REVISION 11 07/14/99 !

E p 4. l H .._. NO SIGNIFICANT HAZARDS EVALUATION

              '"<                              ITS: SECTION 3.6.1.3   PCIVs
         ~;.

TECHNICAL-CHANGES - LESS RESTRICTIVE (Soecification ~ 3.6.1.3 "L.13" Labeled Comments / Discussions)

2. Does the change create the~ possibility of a new or different kind of accident from any accident p{eviously evaluated? -

The proposed change does not involve any physical changes to plant-

                       . systems, structures, components (SSC) or changes in normal plant operation. Further, brief periods of loss of containment integrity are acknowledged in the existing license: Specification 3.6.1.1 allows 1 hour to restore losses in containment integrity prior to requiring a plant shutdown. '.Therefore, these changes will not create the
                       ~ possibility'of a new or different kind of accident from any accident previously evaluated.                                                        g

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

                       ' The design, function, and Operability requirements for the PCIVs are unchanged with this proposed revision. Containment leak rate limits are O                  unaffected. The proposed change to allow the temporary opening of the penetration is not considered to be a significant reduction in the margin of safety. .The combination of: 1) the frequency of experiencing        ,

a inoperable PCIVs such that temporarily opening the penetration is ! required: 2) the brief period the penetration would be opened: 3) the l dedicated individual to accomplish re closure: and 4) the probability.of j occurrence of an event: are not representative of a significant i reduction in the margin of safety. l 1 LO FERMI UNIT 2 24 REVISION 11. 07/14/99l au..e

Primary Containment Pressure 3.6.1.4

   )    3.6 CONTAINMENT SYSTEMS 3.6.1.4 Primary Containment Pressure Primary containment pressure shall be = 0.10 psig and                   3 s +2.0 psig.                                                            I
    @ l LC0 3.6.1.4 APPLICABILITY:      MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME , ! A. Primary containment A.1 Restore primary 1 hour i pressure not within containment pressure limit, to within limit. l B. Required ac tion and B.1 Be in MODE 3. 12 hours associatea Completion i Time not met. 8 51 I B.2 Be in MODE 4. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.4.1 Verify primary containment pressure is 12 hours within limit. I l FERMI UNIT 2 3.6 14 Revision 11 07/14/99

q Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7

                                                                                                               ~
'I          3.6 CONTAINMENT SYSTEMS 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers l LCO 3.6.1.7         Each reactor building to suppression chamber vacuum breaker                       '

shall be OPERABLE.

),

APPLICABILITY: MODES 1, 2, and 3. ACTIONS 2

            .....................................N0TE-----       ------ ----- --              --- - -       --

Separate Condition entry is allowed for each line. l CONDITION REQUIRED ACTION COMPLETION TIME A. One or more lines with A.1 Close the open vacuum 72 hours one reactor building- breaker. ', to suppression chamber vacuum breaker not i closed. k B. One or more lines with B.1 Close one open vacuum 2 hours i y two reactor building- breaker. ) 1 to suppression chamber ; vacuum breakers not i v closed. ' ' h C. One line with one or more reactor building-to suppression chamber C.1 Restore the vacuum breaker (s) to 72 hours OPERABLE status. vacuum breakers n fl inoperable for opening. 4 y 4 (continued) l FERMI UNIT 2 3.6 18 Revision 11 07/14/99

l. L 1 i Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7

  -]
                                                                                                             ~

ACTIONS (continued) C0lOITION REQUIRED ACTION COMPLETION TIME D. Two lines with one or D.1 Restore all vacuum 1 hour 4 more reactor building- breakers in one line

        %            'to suppression chamber                 to OPERABLE status.

b vacuum breakers. inoperable for opening. 8 l Required Action and l E. E.1 Be in MODE 3. 12 hours Associated Completion Time not met. atil l- E.2 Be in MODE 4. 36 hours

   'T            SURVEILLANCE REQUIREENTS SURVEILLANCE                                 FREQUENCY SR  3.6.1.7.1-    ---    - -- --

NOTES--- - - - -

1. Not required to be met for vacuum breakers that are open during Surveillances.

i l 2. Not required to be met for vacuum - i breakers open when performing their intended function, i Verify each vacuum breaker is closed. 14 days SR 3.6.1.7.2' Perform a functional test of each vacuum 31 days breaker. (continued) ,s

           .l FERMI      UNIT 2                            3.6-19               Revision 11. 07/14/99

p, l' i Reactor Building-to Suppression Chamber Vacuum Breakers ' 3.6.1.7 l )- SURVEILLANCE REQUIREENTS - (continued) SURVEILLANCE FREQUENCY 1 ( SR 3.6.1.7.3 Verify the opening setpoint of each 18 months l vacuum breaker is s 0.5 psid. 1 1 I i i I

                                                                               . _ .              l g ! FERMI   UNIT 2                      3.6 19a             Revision 11    07/14/99

t Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7

 ):        BASES
                                                                                             ~

APPLICABLE SAFETY ANALYSES (continued) The results of these two cases show that the external vacuum breakers, with an opening setpoint of 0.5 psid are capable of maintaining the differential pressure within design limits. The reactor building to suppression chamber vacuum breakers satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). f A LC0 All reactor building to suppression chamber vacuum breakers. - two on each line, are required to be OPERABLE to satisfy the assumptions used in the safety analyses. The requirement ensures that the two vacuum breakers (vacuum breaker and air Q operated butterfly isolation valve) in each of the two lines from the reactor building to the suppression chamber

     %                      airspace are closed (except during testing or when t                        performing their intended function). Also, the requirement b                        ensures both vacuum breakers in each line will o>en to relieve a negative pressure in the suppression c1 amber.

I APPLICABILITY In H0 DES 1. 2. and 3. a DBA could cause pressurization of primary containment. In MODES 1. 2. and 3, the Suppression i Pool Spray System is required to be OPERABLE to mitigate the effects of a DBA. Excessive negative pressure inside n i primary containment could occur due to inadvertent 2l initiation of this system. Therefore, the vacuum breakers oc are required to be OPERABLE in MODES 1. 2. and 3. when the jl Suppression Pool Spray System is required to be OPERABLE. to mitigate the effects of inadvertent actuation of the Suppression Pool Spray System. 1 Also, in MODES 1, 2. and 3. a DBA could result in excessive negative differential pressure across the drywell wall caused by the rapid depressurization of the drywell. The ! event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with , steam. Subsequent condensation of the steam would result in ' depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES 1, 2. and 3. l

l FERMI UNIT 2 B 3.6.1.7 -3 Revision 11. 07/14/99

l l I Reactor Building to Suppression Chamber Vacuum Breakers 1 B 3.6.1.7 f

BASES ACTIONS (continued) the fact that the leak tight primary containment boundary is being maintained. DA 4 i With two lines with one or more vacuum breakers inoperable i for opening, the primary containment boundary is intact. 4 However, in the event of a containment depressurization, the 4 function of the vacuum breakers is lost. Therefore, all ig vacuum breakers in one line must be restored to OPERABLE

      ,                       status within 1 hour. This Completion Time is consistent           -

w with the ACTIONS of LC0 3.6.1.1 which requires that primary i Q containment be restored to OPERABLE status within 1 h'ur. o l l E.1 and E.2 vl If all the vacuum breakers in one line cannot be closed or restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 3 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems. SURVEILLANCE SR 3.6.1.7.1 REQUIREMENTS l Each vacuum breaker is verified to be closed to ensure that j a potential breach in the primary containment boundary is i not present. This Surveillance is performed by. observing i local or control room indications of vacuum breaker position ; or by verifying a differential 3ressure of 0.5 psid is ' maintained between the reactor )uilding and suppression chamber. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience. Two Notes are added to this SR. The first Note allows reactor-to suppression chamber vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening l FERMI UNIT 2 B 3.6.1.7 - 5 Revision 11 07/14/99

          .i Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7
                                                                                             ~
  ')         BASES.

SURVEILLANCE REQUIREENTS (continued) vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers. The second Note is included to clarify that vacuum breakers open due to an actual differential pressure are not considered as failing

                          ,  this SR. 4 SR 3.6.1.7.2 Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position. This ensures that the safety               '

analysis assumptions are valid. The 31 day Frequency of this SR was developed based upon Inservice Testing Program ! requirements to perform valve testing at least once every j 92 days. A 31 day Frequency was chosen to provide I additional assurance that the vacuum breakers are OPERABLE. SR 3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption

   ,                         regarding vacuum breaker full open differential pressure of s 0.5 psid is valid. This verification may be performed by measurement of the equivalent force to move the pullet. 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 tw reactor at power. The 18 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of           i other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.        ,

REFERENCES 1. UFSAR. Section 6.2.

~~

p l FERMI UNIT 2 B 3.6.1. 7 - 6 Revision 11, 07/14/99

1 S'fEttF~ icNrtorJ 34 /.7

                                                                                                                               ~
..                                                                                           A.I                                   ,

1 CONTAINMENT SYSTEMS REACTOR BUILDING - SUPPRESSION CHAMBER VACUUM BREAKERS LIMITING CONDITION FOR OPERATION LL. O

      '3 fo 3 7      3.C.4.2 All Reactor Bhilding - suppression chamber vacuum breakers shall be p               OPERABLE [ana closeaj                                                                                         !
             ,y APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

g a.

                                /Aed:Acmd5              NOTF)

With one Reactor Building _- suppression chamber vacuum breaker M dc: nom C inoperable for opening (but knawn to >e closeaIrestore the E inoperable vacuum breaker to OPERABLE status within 72 hours or be d , D O4 g in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours. l 4 @ ,a A Bl b- with oa' R**ctor Sui 1 dias - suppr*55 ion ch'=b'r vacuu= brk'r oa'a-isolate the associated vacuum breaker line by closing the isolation I' 3' -- valve within 2 hours; restore the open vacuum breaker to the closed position within 72 hours or be in at least HOT SHUTDOWN within the ( next 12 hours and in COLD SHUTDOWN within the following 24 hours. f

c. Wit the position alcator et any eactor Building suppre ion g,l c mber vacuum ker inoperabl restore the inoperabl positio ndicator to ;RABLE status wi in 14 days or verify e vacuum

) '

breaker t e closed at least nee per 24 hours by v al inspect n. Otherwise, dec .re the vacuum breaker operable or b a in a east HOT SHUTDOWM - hin the next 12 hour nd in COLD $ (S N within the foi ing 24 hours.f 4 i SURVEILLANCE RE001REMENTS , 4.6.4.2 Each Reactor Building - suppression chamber vacuum breaker shall be: '1 54 3,G.t.'7 1 -e- Verified closed at least once per 7 days D L,7.

b. Demonstrated OPERABLE: NC I'2-/

At least once per 31 days by: lb ,l ,

1. i S A '$ 4 I 7 L a) Cycling vacuum breaker through at least one complete test cycle of full travel. .

(b) Verij#ing the position ind tor UVLKMLL DyfDserving] 7exper tedc valve movement ing the cycling /est r

2. At least once per 18 months by: IQ a) Demonstrating that the force required to oDen each -

M h I 7*.3 vacuum breaker does not exceed $he/eoutv>1ent AD 1 3 lk 0.5 psid.

                                         @       Yt:=1 W:::tt:O--

er ing tne positiop inaicator OPERABLE b/performan of CHANNEL CALIBRA/ ION.j

~~~

,s FERMI - UNIT 2 3/4 6 50 Rd 11 I PAGE I 0F 01 Revf'

CISCUSSION OF CHANGES ITS: SECTION 3.6.1.7 REACTOR BUILDING TO SUPPRESSION CHMBER VACUUM BREAKERS

LL.2 CTS 4.6.4.2.a requires that the vacuum breakers be closed at all times: with no explicit allowance to be open when performing their intended function (i.e., when relieving vacuum), and no allowance for opening.during performance of required Surveillances. ITS SR 3.6.1.7.1 has two Notes: Note 1 stating that the vacuum , breakers can be opened when performing required Surveillances, and n ) Note 2 stating that vacuum breakers can be open when performing their intended function. These additions provide specific ITS h direct'on, which is consistent with the intent of maintaining

              " operable" vacuum breakers. . These allowances will not affect the    W h

vacuum breaker ability to perform its intended functions of V relieving vacuum or of providing an isolated containment barrier in the event of positive containment pressure. Therefore. these changes introduce no negative impact on safety. L.3 CTS 3.6.4.2 provides actions for one inoperable vacuum relief line. ITS LC0 3.6.1.7 Actions are modified by a Note, which provides clarification that. for the purpose of the associated LCO. " Separate Condition entry is allowed for each line." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each vacuum breaker line with an inoperable vacuum breaker. Complying with the Required Actions will allow for continued operation: subsequent inoperable vacuum 4 g breaker (s) in another line are governed by subsequent Condition h entry and application of associated Required Actions. Along with this. ITS Action D is included to assure a rapid plant shutdown in the event both vacuum relief lines have inoperable vacuum breakers. The CTS required shutdown in the event both vacuum relief lines are inoperable is dictated by LC0 3.0.3. .The shutdown required by ITS Action D and E is similar, but does not include the intermediate requirement to be in Mode 2 in 7 ho!urs. These changes result in a less restrictive requirements. 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 3.6.1.7 consistent with the BWR STS. NUREG 1433. Rev. 1. FERMI UNIT 2 4 REVISION 11 07/14/99l c

l I Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 l

 --        3.6 CONTAINMENT SYSTEMS                                                                   I6) -

3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers ,4,tj, LC0 3.6.1.7 Each reactor building-to-suppression chamber vacuum breaker shall be OPERABLE.

                                                                                                         'a4.

k APPLICABILITY: MODES 1, 2, and 3. ACTIONS 4 NOTE -- - - - Separate Condition entry is allowed for each line. { g,3 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more itnet with A.1 Close the open vacuum 72 hours one reactor building- breaker. ' (Acnod b) to-suppression chamber vacuum breaker not 4 closed. s

                                                                                              -eI'

8. One or more lines with B.3 Close one open vacuum b,5 two reactor building- breaker.

houh to-suppression chamber , vacuum breakers not (/}cT)odb) I closed. I C. One line with one or C.1 Restore the vacuum 72 h9urs i s more reactor building- breaker (s) to C1104 4/ I to-suppression chamber OPERABLE status. j. vacuum breakers ! inoperable for opening. $ 4 E (continued) i WRf4-3TS 3.6-23 he-2-r- 04/07/35 ! l

                                                                                       ' ~ ~

Rau bf

I l Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 g ACTIONS (continued) - CONDITION REQUIRED ACTION COMPLETION TIME D. Two h 11nes D.1 Restore all vacuum I hour i 3 with one or more breakersin(onek / p pg [,3h reactor building-to- line to OPERABLE T / w suppression chamber status. _ vacuum breakers inoperable for g opening. E. Required Action and Associated Completion E.1 Be in MODE 3. 12 hours hitsAJah Time not met. Alg)

                                                                                    /T cwW A           b\/

E.2 Be in MODE 4. 36hoursf' J k SURVEILLANCE REQUIREMENTS

  .                               SURVEILLANCE                             FREQUENCY SR 3.6.1.7.1     -      --

NOTES --

1. Not required to be met for vacuum breakers that are open during Surveillances. 000 A N

2. Not required to be met for vacuum breakers open when performing their intended function.

Verify each vacuum breaker is closed. 1(days 4,(,,y,1, Ah SR 3.6.1.7.2 Perform a functional test of each vacuum days t),(,,y,1, b ,l breaker. (continued) O!51/4 373 3.6-24 Rev+, S4/si f95 r Rev11 Rev 5'

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7

     .       BASES J

r3 - ' , ' J APPLICABLE capable of maintaining the differential pressure within SAFETY ANALYSES design limitr, (continued) The reactor building-to-suppression chamber vacuum breakers

p. satisfy Criterion 3 o ' M 'C' W 00"--"

cfRfail,Co9%63 Ykio o A M LC0 All reactor %ilding-to-suppression chamber vacuum brea rsg i4 C i are required to be OPERABLE to satisfy the assumptions used in the safety analyses. The requirement ensures that the is a b -twesvacuus breakers (vacuum breaker and str operated

                      =
                              ' butterflyfvalve) in each of the two lines from the reactor l3

OE1 building to the suppressior. chamber airspace are closed (except during testing or when performing their intended [

function . Also, the requirement ensures both- vacuum y ' breakeri)in each line will open to relieve a negative pressure in the suppression chamber. APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of ll primary containment. Pool Spray System is required to be OPERABLE to mitigate theIn effects of a DEA. Excessive negative pressure inside primary containment could occur due to inadvertent - q initiation of this system. Therefore, the vacuum breakers are required to be OPERABLE in MODES 1, 2, and 3, when the k ("i j SuppressionPoolSpraySystemisrequiredtobeOPERABLE,to{ mitigate the effects of inadvertent actuation of the Suppression Pool Spray System. Also, in MODES 1, 2, and 3, a DBA could result in excessive negative differential pressure across the drywell wall l caused by the rapid depressurization of the drywell. The i event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES 1, 2, and 3.

In MODES 4 and 5 the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining reactor (continued) 0'.*/4 Y B 3.6-44 Re 1, 04/0?lE

'                                                                                       .-    $2111    hh gu 5~ l

1 Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 NU . l u - APPLICABI'LITY building-to-suppression chamber vacuum breakers OPERABLE is (continued) not required in MODE 4 or 5. 6 ACTIONS A Note has been added to provide clarification that, for the g purpose of this LCO, separate Condition entry is allowed for each penetration flow path. Iq AJ / With one or more vacuum breakers not closed, the leak tight primary containment boundary may be threatened. Therefore, l76, n the inoperable vacuum breakers must be restored to OPERABLE t'3 tue +- t' :;:: : o ic: N closed)within 72 hours. 3

                .             The        hour Completion Time is consistent with requirements C14.;           for inoperable suppressiodhamber-te-drywell vacuum            ,

breakers in LC0 3.6.1.B. "SuppressioiEichamber-to-Drywell Vacuum Breakers." The 72 hour Completion Time takes into i account the redundancy capability afforded by the remaining , breakers, the fact that the OPERABLE breaker in each of the 'q lines is closed, and the low probability of an event occurring that would require the vacuum breakers to be OPERABLE during this period. V L N J El L 9 With one or more lines with two vacuum breaker not closed, I primary containment integrity is not maintained. Th one open vacuum breaker must be closed within ho J efore,l This Completion Time is ermt::t ;th 16 27;;,e of N E oir INE S - a f'( ~ t un- ' T4tGMbit botsed m engMccing d jvQeseO L L1 - - g With one line with one or more vacuum breakers inoperible j for opening, the leak tight primary containment boundary is b intact. The ability to mitigate an event that causes a containment depressurization is threatened, however, if both h vacuum breakers in at least one vacuum breaker penetration are not OPERABLE. Therefore, the inoperable vacuum breaker (continued) BWR/4 STS B 3.6-45 Rev 1, 04/07/95 w - hv 5-

Reactor Building-to-Suppression Chamber Vacuum Breakers i B 3.6.1.7 BASES

ACTIONS Q (coniinued) lf must be restored to OPERABLE status within 72 hours. This is consistent with the Completion Time for Condition A and k the fact that the leak tight primary containment boundary is being maintained. j Ed i With two 'n _..e] lines with one or more vacuum breakers i inoperable for opening, the primary containment boundary is intact. Howeve s in the event of a containment 4 depressurization, the function of the vacuum breakers is % lost. Therefore, all vacuum breakers in oneEline must be restoredtoOPERABLEstatuswithinIhour(. This Completion Time is consistent with the ACTIONS of LC0 3.6.1.1, which ( requires that primary containment be restored to OPERABLE N status within I hour. h 4 E.1 and E.7

                                                                                     }    S If all the vacuum breakers in Honegline cannot be closed or             !

restored to OPERABLE status wi;hin the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be ( O brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenaing plant systems. SURVEILLANCE SR 3.6.1.7.1 REQUIREMENTS Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker pssition l orbyverifyingadifferentialpressureof(0.5ypsidis maintained between the reactor building and suppression ' chamber. The 14 day Frequency is based on engineering (continued) l l 3""./' 0'0- B 3.6-46 L ;, G4/07/95

                                                                               @v1T       j Qg

l [ I i J JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.7 - REACTOR BUILDING TO SUPPRESSION CHAE ER VACUUM BREAKERS

                       ~
        @N BRACKETED PLANT SPECIFIC CHANGES 1

P.1 These changes are made to NLREG-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, j l P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. P.3 Not used. - N P.4 Not used. 8 P.5 The reference to the IRC Policy Statement has been replaced with a l4 more appropriate reference to the Improved Technical Specification

                    " split" criteria found in 10 CFR 50.36(c)(2)(11).                              '

i e l l l l l l l FERMI - UNIT 2 1 REVISION 11 07/14/99l L

l l NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.7 - REACTOR BUILDING TO SUPPRESSION CHAMBER VACUUM BREAKERS

i TECHNICAL CHANGES - LESS RESTRICTIVE j (Soecification 3.6.1.7 "L.3" 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. 4

1. Does the change involve a significant increase in the probability or' w consequences of an accident previously evaluated? In This change allows the actions to apply separately to each vacuum relief I line and to provide an explicit action in the event both vacuum relief lines are inoperable. The vacuum breakers are not assumed to be an

 ,           initiator of any previously analyzed accident. Thercfore, this change does not involve a significant increase in the probability of an accident previously evaluated. The change involves only the specific             ;

intermediate transitions during a required plant shutdown and does not ' affect the function and operability criteria for the vacuum breakers. As such, the vacuum breaker is expected to continue to perform its ; intended and assumed safety function, and therefore this change does not l involve a significant 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?

The proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated. FERMI - UNIT 2 5 REW 10N 11, 07/14/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.7 - REACTOR BUILDING TO SUPPRESSION CHAPEER VACUUM BREAKERS TECHNICAL CHANGES LES$ RESTRICTIVE (Soecification 3.6.1.7 "Ll3" I aheled Comments / Discussions) l

       ' 3.      Does this change involve a significant reduction in a margin of safety?    4 N-    i The change will not result in a significant reduction in a margin of        to safety because it involves only the specific intermediate transitions       Q during a required plant shutdown and does not affect the function and       y operability criteria for the vacuum breakers. As such, the vacuum breaker is expected to continue to perform its intended and assumed safety function. > Therefore, this change does not involve a significant reduction in the margin of safety.                                                I I

1 i I. FERMI' UNIT 2 6 REVISION 11. 07/14/99l 1 '. i

Suppression Chamber-to Drywell Vacuum Breakers B 3.6.1.8 APPLICABLE Analytical methods and assumptions involving the SAFETY ANALYSES sup>ression chamber-to-drywell vacuum breakers are presented in teference 1 as part of the accident response of. the primary containment systems. Internal (su)pression chamber to drywell) and external (reactor )uilding-to-suppression chamber) vacuum breakers are provided as part of the primary containment to limit the negative differential pressure across the drywell and suppression chamber walls that form part of the primary containment boundary. The safety analyses assume that the internal vacuum breakers - are closed initially and are fully open at a differential pressure of 0.5 psid (Ref.1). Additionally. 3 of the 12 internal vacuum breakers are assumed to fail in a closed position (Ref.1). The results of the analyses show that the design pressure is not exceeded even under the worst ) case accident scenario. The vacuum breaker opening differential pressure set)oint and the assumption that 9 of 12 vacuum breakers open w1en required are a result of the requirement placed on the vacuum breakers to limit excessive water level variation in the portion of vent discharge line

   ,                        submerged in the suppression pool.

The suppression chamber to drywell vacuum breakers satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 All vacuum breakers are required to be OPERABLE for opening and are.also required to be closed (except during testing or when the vacuum breakers are performing their intended design function). The vacuum breaker OPERABILITY requirement provides assurance that the drywell to-suppression chamber negative differential pressure remains ; below the design value. The requirement that the vacuum ! breakers be closed ensures that there is no excessive bypass ' leakage should a LOCA occur. j APPLICABILRY In MODES 1. 2. and 3. the Suppression Pool Spray System is i required to be OPERABLE to mitigate the effects of a DBA. g yl Excessive negative pressure inside the drywell could occur due to inadvertent actuation of this system. The vacuum l FERMI - UNIT 2 B 3.6.1.8 - 2 Revision 11 07/14/99

Suppression Chamber to-Drywell Vacuum Breakers B 3.6.1.8 BASES APPLICABILITY (continued) breakers, therefore, are required to be OPERABLE in MODES 1 2, and 3. when the Suppression Pool Spray System is required M'l to be OPERABLE, to mitigate the effects of. inadvertent actuation of the Suppression Pool Spray System. Also, in MODES 1, 2, and 3, a DBA could result in excessive negative differential pressure across the drywell wall, caused by the rapid depressurization of the drywell. The event that results in the limiting rapid dearessurization of the drywell is the primary system rupture t1at purges the drywell of air and fills the drywell free airspace with - steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES 1, 2, and 3. In MODES 4 and 5, the probability and consequences of these events are reduced by the pressure and temperature limitations in these MODES: therefore, maintaining suppression chamber-to drywell vacuum breakers OPERABLE is not required in MODE 4 or 5. I ACTIONS L1 With one of the required vacuum breakers inoperable for i opening (e.g., the vacuum breaker is not open and may be l stuck closed or not within its opening setpoint limit, so that it would not function as designed during an event that depressurized the drywell), the remaining eleven OPERABLE vacuum breakers are capable of providing the vacuum relief function. However, overall system reliability is reduced, and since normal periodic functional testing of the vacuum breakers is deferred to MODE 4 (SR 3.6.1.8.2), additional ' undetected failures could result in an excessive suppression chamber to drywell differential pressure during a DBA. Therefore, with one vacuum breaker inoperable. 72 hours is allowed to restore the inoperable vacuum breaker to OPERABLE status. The 72 hour Completion Time is considered acceptable due to the low probability of an event in which i the remaining vacuum breaker capability would not be adequate. , l j FERMI - UNIT 2 B 3.6.1.8 - 3 Revision 11, 07/14/99

Suppression Chamber-to-Drywell Vacuus Breakers B 3.6.1.8 BASES APPLICABLE The suppression chamber-to-drywell vacuum br rs satisfy SAFETY ANALYSES g (continued) Criterion 3/oo{f cfg th:3(,g

                                                     "?: .";1';y g y, St& :"
                                   ,                      (re require [4v)

LC0 ...L- l? M thr' f.l _ openinerl :. Z' ::Q;;2bvacuum breaTers www ti ort.nABLE for

                                            ;"4~~ & ': t: i:e ;;; -an--
                        ;;:-" .4 i:x .u.4 ne required to be closed (except during

[ddhalso C --- = testing or when the vacuum breakers are perfoming their intended design function). The vacuum breaker OPERABILITY requirement provides assurance that the drywell-to-

               .       suppression chamber negative differential pressure remains below the design value. The requirement that the vacuum breakers be closed ensures that there is no excessive bypass leakage should a LOCA occur.

APPLICABILITY In MODES 1, 2, and 3, the Suppression Pool Spray System is required to be OPERABLE to mitigate the effects of a DBA. 0gs Excessive negative pressure inside the drywell could occur M due to inadvertent actuation of this system. The vacuum CR' breakers, therefore, are required to be OPERABLE in MODES 1 i 2, and 3, when the Suppression Pool Spray System'is required I to be OPERABLE, to mitigate the effects of inadvertent

c. actuation of the Suppression Pool Spray System.

Also, in MODES 1, 2, and 3, a DBA could result in excessive negative differential pressure across the drywell wall, caused by the rapid depressurization of the drywell. The event that results in the limiting rapid depressurization of the drywell is the primary system rupture that purges the drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES I, 2, and 3. In MODES 4 and 5, the probability and consequences ^of these events are reduced by the pressure and temperature i limitations in these MODES; therefore, saintaining suppression chamber-to-drywell vacuum breakers OPERABLE is not required in MODE 4 or 5. (continued)

    """/ STS                               B 3.6-50                    L 1, ^'/07/;3-
                                                                              ~

j REll N

JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.8 SUPPRESSION CHMBER-TO DRYWELL VACUUM BREAKERS NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NLREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Additional rewording, reformatting. l 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 change JFD for additional detail. P.4 Fermi CTS contains expanded detail regarding determination of the 6 l closed status of vacuum breakers. This detail is relocated to the Bases for SR 3.6.1.8.1. As such, the SR 3.6.1.8.1 Bases regarding q non reliable or faulty position indication, and means for h verifying closed status in this event, are revised for clarity. y Since reference to alternate methods of verification are included W in more detail in SR 3.6.1.8.1 Bases, similar (but less detailed) information is removed from Required Action B.1 Bases and replaced b with a reference to the detail provided in the SR 3.6.1.8.1 Bases. y i P.5 N Not used. 9 P.6 NUREG 1433 LC0 3.6.1.8 recognizes the allowance for vacuum breakers to be open if performing their intended function (an exception to the normal requirement for them to be closed). With the Fermi-2 CTS , conversion, a simplified presentation of the LC0 is warranted l (because there is not a different number of vacuum breakers reguired operable from that required to be closed). With this simplification, j the exception is appropriately located with the Surveillance (SR 3.6.1.8.1 Note 2). This is an editorial change only, consistent with the Writer's Guide conventions. P.7 The reference to the PRC 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).
                                                                            ~

FERMI UNIT 2 1 REVISION 11, 07/14/99l

5 f ecificabrt. S G. 2 I 0f.so se,c, sfecLGedtort. S d. l . I )

    ]                                                                        (A(50 See Sp ecM cadion 3,6. L 2}
  ~

CONTA"letENT SYETEMS SURVE' LLANCE REQUIREMEKf5 (Continuedi

1. At least once per 5 minutes during testing which adds heat to GTt 3. (,. 2.. l. I the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105T.

                                    , 2.      At 1gast once per hour when suppression chamber average water g,g                     temperature is greater than or equal to 95T, by verifying:

Suppression chamber average water temperature to be less A.\ a) _ _ thma ar -1 to 110T. and

                                                )     THElglAL POWER to ba less than or equal to 1% of RATED THERMAL POWER after suppression chamber average water           b.3 temperature has exceeded 957 for more than 24 hours.

g -

c. At least once per 30 minutes in OPreATIONAL C0lWITION 3 followine a

      } pgrea             h           scram un m ,,,.iesston chamber average water temperature greater L D .'L.                       or equal to 957, by verifying suppression chamber avera08j             b*I               '

ater temperature less than or eoual to 1207. -

d. jByanexternalvisualexaminationofthesuppressionchamberafter ":P-safety / relief valve operation with the suppression chamber averago water temperature greater than or equal to 1607 and reactor coolant -

                                                                                                                       $c.L
                                                                                                                     ,cg",3 4

system pressure greater than 200 psig. g e. At least once per 18 months by a visual inspection of the accessible interior and exterior of the suppression chamber. c6 ression pool ater temperature N I [f. By veri ing eight ins ntation annels OPERAB y performa gnof a: ' jj (q t CHANNE ECK at less ce per 24 h urs. [rv l i 3.

                                         . C        FUNCTIONAL EL CALIBRA T at least at least e per 31 e e per 18 and
                                                                                                   . with the )

j <$Q-water high temperature alarm catanint f o r < 105'F . /

g. y verifying both narrow range suppression chamber water level instrumentation channels OPERABLE by performance of a:

1. CHANNEL CHECK at least once per 24 hours, bgc oh CHANNEL FUNCTIONAL TEST at least once per 31 days, and

                     @C"}.f 2.3.

ec CHANNEL CALIBRATION at least once per 18 months. 36.N i

                                   / With the water level alarm setpoint for:

1. High water level 5 14'8' ,

Low water level 1 14'4" (TWMS Narrow Range) {2.

h. [At least once per 18 months by conducting a drywell to suppression i chamber bypass leak test at an initial differential pressure of 1 psi and verifying that the differential pressure does not decrease by more than 0.20 inch of water per minute for a period of

        $6Dn c,0Q0n                    10 minutes. If any drywell-to-suppression chamber bypass leak test fails to meet the specified limit, the test schedule for subsequent CCIV                        tests shall be reviewed and approved by the Commission. If two consecutive tests fail to meet the soecified limit, a test shall be
               'g,\                    performed at least every 9 months until two consecutive tests meet
        $i                             the specified limit, at which time the 18 month test schedule may be resumed.

FERMI - UNIT 2 3/4 6 17 Rev 11 0 PAGE 3 0F 03 gevf

DISCUSSION OF CHANGES ITS: SECTION 3.6.2.1 - SUPPRESSION P0OL AVERAGE TEMPERATURE LA.1 CTS 3.6.2.1, Action c and d. and surveillance 4.6.2.1.f. establish, Actions and Surveillance Requirements for the lE instrumentation used to monitor suppression pool temperature. This instrumentation performs an alarm only or indication-only function, performs no automatic function and is not assumed in any event that depends on operator action. Alarm only and indication-only functions do not necessarily relate directly to the Operability of the related systems. ITS 3.6.2.1 require that the suppression pool temperature be maintained, but do not specify the g requirements for the instrumentation. These requirements are relocated to the TRM, where changes are controlled by 10 CFR 50.59. These requirements are not necessary to be in the Technical Specifications to provide adequate protection of the public health and safety since the Technical Specifications continue to mandate maintenance of suppression pool temperature to less than 95*F. TECHNICAL CHANGES - LESS RESTRICTIVE "Speci fic" L.1 CTS 4.6.2.1.c requires verification at least once per 30 minutes that suppression chamber average water temperature is s 120 F following a scram when suppression chamber average water temperature is 2 95*F. ITS 3.6.2.1, Required Action D.2. requires this verification every 30 minutes only if suppression pool temperature is > 110*F. Not starting the verification of temperature at 30 minute . intervals until the temperature is

                      > 110 F is acceptable because the intent is to ensure that suppression pool average temperature does not exceed 120"F.     ,

Operator knowledge of plant conditions that could result in tapid heating of the suppression pool and the ITS requirement to monitor the temperature every 30 minutes once the temperature is > 110*F provides a very high degree of assurance that operators will identify the condition and take appropriate action before the suppression pool temperature exceeds 120 F. L.2 Not used. l j M FERMI UNIT 2 3 REVISION 11 07/14/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERAT1JRE L.3 CTS 3.6.2.1 a.2 and a.3 present requirements inconsistent with the intended limitations on suppression chamber water temperature. CTS 3.6.2.1.a.2 limits the temperature to s 95 F only when in Mode 1 or 2 with thermal power > lt RTP: allowing a 110*F limi.t when s It RTP. CTS 3.6.2.1.a.3 imposes a 95'F limit during Mode 3 (which is always s it RTP), and does not allow the post scram exception for a 120 F limit when an MSIV is open. Therefore, the CTS only allow the 110'F limit during the brief period in Mode 2 but s 1% RTP. ITS 3.6.2.1 allows the 110 F limit at all times s It RTP. Also with this change CTS 4.6.2.1.2.b), which presents a surveillance to verify thermal power to be s it RTP when temperature is >95'F for 24 hours, is eliminated. Since the ITS requires temperature to be restored to s 95'F within 24 hours, or power reduced to s 11 RTP, no periodic confirmation that this action is being complied with is deemed necessary in the ITS. j Historically, the STS that the Fermi original license was based i on, the majority of other licenses issued with STS based Technical Specifications, and the NRC approved and issued STS NUREG 1433. l all allow the 110*F limit during all of Mode 3 (i.e., at all times s it RTP). These precedents support the engineering judgement that allowing the temperature limit to increase from 95 F to 110 F during all operation at s 11 RTP, and increased frequency of verifying that power remains s it RTP will not result in any significant impact on safety. RELOCATED SPECIFICATION _$ None 3 FERMI - UNIT 2 4 REVISION 11 07/14/99l

pec.t FacAWDAI 8 0.%*1 3 (Mso m SMkeKm 3 S.2-)

FMER$ENCYCORE,CDQLINilSYSTEMS 3/4.5.3 5UPPAESSION CHAMBElt LINITING c0NDfT10N FDR OpFRATION

                      .5.3 The suppression chamber shall be OPER58LE:                                       44./

LCO 3.G.t.2-

a. In OPERAT10NAL CONIITIONS 1. 2. and.3 with Ea cafliainau watafvolumo4D

         '                           at leasts ucc50 FK eeuw&1enVteia level or@ (-Z inches indication),                                                                ,

b. bPERATIONAL CONDITIONS 4 and 5* with a contained volume of at least 64,550 ft', equivalent to a level of f*0* (. 66 inches indication),

except that the suppression chamber' level may be less than the Ilmit pg. or may be drained provided that:

                                                                                                                   .q speciscakA                1. No operations are performed that have a potential for draining gn                           the reactor vessel,

2. The reactor mode switch is locked in the Shutdown or Refuel i position, I

3. The condensate storage tank water level is at least 19 ft., and j

4. The core spray system is OPERA 8LE per Specification 3.5.2 with an OPERABLE flow path capable of taking suction from the condensate storage tank and transferring the water through the !

   ,                                       spray sparger to the reactor vessel.
                                                                                            $ss ut 55 2 APPLICABILITY: OPERATIONALCONDIT10N5tl._2,3){,and5 ACTION:                                         b / CB 3,G,2. 2-In OPERATIONA COND T10N 1. 2. or 3 with the suppression chamber water ACTla9 Aa.            invei iess than,the above iinit, restore the water ievei to within the A          limit within      our or be in at least HOT SHUTDOWN within the next 12 ACT10f) U             hours and in@IDLD             SHUTDOWN within the following 24 hours,

b. In OPEliATIONAL CONDITION 4 or 5* With the suppression chamber water s.at level less than the above limit or drained and the above required conditions not satisfied, suspend CDRE ALTERATIONS and all operations

     ; Specihusb                ' that have a potential for draining the reactor vessel and lock that t

i g gg,g reactor mode switch in the Shutdown position. Establish SECONDARY i CONTAlfelENT INTEGRITY within 8 hours.

       \
         \,         'The suppression chamber is not required to be OPERA 8LE provided that the N       reactor vessel head is removed, the cavity is flooded, or being flooded from the suppression pool, the spent fuel pool gates are removed when the cavity is flooded, and the water level is maintained within the limits of SpeciflCations 3.9.8 and 3.9.9.

w

                 , FERMI - UNIT 2                               3/4 5 8                       Amendment No.131 e

PAGE / OF 05

RHR Suppression Pool Cooling 3.6.2.3 ) 3.6 CONTA7iNMENT SYSTEMS

3.6.2.3 F.esidual Heat Removal (RM) Suppression Pool Cooling I LCO 3.6.2.3 Two RR suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIOPS CONDITION REQUIRED ACTION COMPLETION TIME . A. One RHR suppression A.1 Restore RHR 7 days pool cooling subsystem suppression pool inoperable. cooling subsystem to OPERABLE status. B. Two RHR suppression B.1 Restore one Rm 8 hours pool cooling suppression pool subsystems inoperable. cooling subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion hl Time not met. Mg! C.2 Be in MODE 4. 36 ho'u'rs i l l FERMI UNIT 2 3.6 28 Revision 11 07/14/99

RHR Suppression Pool Cooling B 3.6.2.3 ] BASES ACTIONS (continued) overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period. L1 With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within - 8 hours. In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation h function. The 8 hour Completion Time is based on this loss k of function and is considered acceptable due to the low Q probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the RHR suppression pool cooling subsystem to operate. C.1 and C.2 If the Required Action and associated Completion Time cannot

.?-

be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be k brought to at least MODE 3 within 12 hours and to MODE 4 l within 36 hours. The allowed Completion Times are l reasonable, based on operating experience, to reach the i required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS i Verifying the correct alignment for manual, power operated, and automatic valves in the RHR sup)ression pool cooling mode flow path provides assuraice t1at the proper flow path exists for system o)eration. This SR does not apply to valves that are locted, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is l FERMI UNIT 2 B 3.6.2.3 - 3 Revision 11 07/14/99

eCIYlCckb/c /2. S* $. S. b l CONTAINMENT SYSTEMS SUPPRESSION P0OL COOLING - LIMITING CONDITION FOR OPERATION l.dO' 3.6.2.3 The suppression pool cooling mode of the residual heat removal _(RHR) system shall be OPERABLE withyndependent[ loops, Jeach loop consisting of: fa. ne OP LE.RHR mp, and [ M. OPERABL low path pable of irculatin ater f a the g} ( suppress n chamber rough an AMR heat exchanger. g APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. - ACTION: 7da S [./

                               -ar     With one suppression pool cooling loop inop_erable restore the A c,fl,g 4          inoperable loop to OPERABLE status withinO2 hour _ Dor be in at

, least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN l

                  /}c [po s C          within the following 24 hours.

4r With both suppression pool cooling loops inoperable, be in at gj,, 3 least HOT SHUTDOWN within 12 hours and in C_0LD__ SHUTDOWN

within the next 24 hours, j es/ ore one RNR Acto,w C se,,p,essi.n 7.ot conting u dsyJf% d* OPERABLC .5l4l.US SURVE1LLANCE RE00 REHENTS ,

                                                                                                                 $$$lA Slam
                        -4.6.2.3 - The suppression pool cooling mode of the RHR system shall e l                          demonstrated OPERABLE:                                                  or ea rl 4 e a lig.ed

tA e cor.-ettfocityn

! a,- At least once per 31 days by verifying that each valve (manual, '

          . $k 3.dr,1+3 I               power-operated, or automatic) in the flow path that is not locked, /

sealed, or otherwise secured in position, is in its correct j position & 3 S R 3. /,

L 3.1 & By verifying that each f the requit ed RHR pumps develops a flow of at least 10,000 gpm on recirculation flow through the RHR heat exchanger and the suppression pool when tested pursuant to Specification 4.0.5. g iN

                           'Wh     ~r both HR'subsyste         r(inoperable,) finable t     ttMn COLD-DOWN        quired             CTION, maint1Tn reacto      ant trmperature as ow as. ctical b         of alternatt.Af6at removal me ods.

FERMI - UNIT 2 3/4 6-19

                                                                                                  ..                          j Rev 11           ,

PAGE I 0F 01 a

DISCUSSION OF CHANGES ITS: SECTION 3.8.2 AC SOURCES SHUTDOWN 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 l actual or interpretational). . Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BlR) Standard Technical Specifications NUREG 1433.-Rev. 1. A.2 ITS 3.8.2. Action A (corresponding to CTS 3.8.1.2. Action a), has been modified by a Note requiring entry into applicable Conditions ' and Required Actions of .ITS LCO 3.8.8 (Distribution Systems) when one required division is de energized. This Note is necessary because AC power sources are considered a support system to the Distribution System: therefore. ITS LCO 3.0.6 would allow taking Actions for the AC Sources only. However, in the case of an inoperable electrical power source such that a distribution system was de energized, additional Actions may be required to assure continued safe operation. Rather than specify those additional Actions in the sources Specifications, direction is provided to apply the Actions of the supported Distribution System. This is an administrative change with no impact on safety because the new requirement is consist 9t with 'a reasonable interpretation of CTS. l A.3 CTS LCO 3.8.1.2 Actions detail the requirements for less than the required AC electrical power sources Operable. ITS LCO 3.8.2 has separated the Actions into two Conditions: Condition A addresses one required offsite circuit inoperable; and Condition B addresses one or both required EDGs inoperable. Reformatting these requirements provides greater clarity for the TS user. This C change is consistent with NUREG 1433. : 4 e.

    'A.4         Not used.                                                            l[

o FERMI UNIT 2 1 REVISION 11. 07/14/99l a ,

DISCUSSION OF CHANGES ITS: SECTION 3.8.2 AC SOURCES SHUTDOWN LA.2 CTS 3.8.1.2 Action a for the inop3rability of a required AC source, requires su'spension of " crane operations over the spent fuel pool ." These " crane operation" issues are relocated from the CTS (as in the case of. CTS 3.9.7. " Crane Travel Spent Fuel Storage Pool"), based on the administrative controls of heavy r-loads (which are in accordance with Fermi 2 positions.on NUREG- g 0612 and Generic Letter 80 113). Therefore, the Actions g associated with crane operation following a loss of power sources have been relocated to the UFSAR consistent with other heavy-loads issues. Relocation to UFSAR maintains consistency with NUREG 1433. Changes to the UFSAR will be controlled by the provisions of 10 CFR 50.59. These dei. ails are not required to be in the ITS to provide adequate protection of the public health and safety since the requirement for power source Operability and restoration remains in the Technical Specifications. LA.3 Not used. lhM LA.4 Not used. l l l l l l l l l l l l FERMI UNIT 2 4 REVISION 11. 07/14/99l L

DISCUSSION OF CHANGES ITS: SECTION 3.6.2.3 - RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL COOLING 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 Not used. l A.3 CTS 4.6.2. 3.a requires verification every 31 days that a manual, power operated or automatic valve in the suppression pool cooling flow path that is not locked, sealed or otherwise secured in position, is in its correct position. The lineup for ECCS Operability requires the RHR System in a lineup other than that necessary to perform the suppression pool cooling function. In addition, the suppression pool cooling function is manually actuated (requiring reposition of valves and starting of the RHR pump by the operator). In the CTS. this is recognized and interpreted that "in the correct position" allows the valves to be in a non accident position provided they can be realigned to the correct position. In ITS, the words "in the correct position" mean that the valves must be in the accident position, unless they can be automatically aligned on an accident signal. If so, then they can be in the non-accident position. Therefore, for the Suppression Pool Cooling System and other manually actuated systems. the additional words "or can be aligned to the correct position" have been added to clarify that it is permissible for valves to be in the non accident position and thefsystem still be considered Operable. This is an administrative change with no impact on safety because it is consistent with a reasonable interpretation of the existing requirements. FERMI - UNIT 2 1 REVISION 11 07/14/99l t

I L l DISCUSSION OF CHANGES

l. ITS: SECTION 3.6.2.3 - RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION P00L COOLING TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.6.2.3. footnote "*" to Action b, states that "Whenever both RHR subsystems are inoperable if unable to attain COLD SHUTDOWN as required by this ACTION. maintain reactor coolant temperature as low as practical by use of alternate heat removal methods."

l This footnote is deleted because it does not establish any additional restrictions on plant operation. Furthermore, this footnote could be interpreted as a relaxation of the requirement to achieve Cold. Shutdown. The ITS 3.4.8. Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown. Action to be in Mode 4 within 35 hours when no RHR systems are Operable adequately prescribes the requirement to make efforts to " maintain reactor ' coolant temperature as low as practical." If conditions are such that Mode 4 cannot be attained the Actions remain in effect. requiring that efforts to reach Mode 4 continue. Elimination of the potential relaxation is a more restrictive change with no impact on safety. TECHNICAL CHANGES - LESS RESTRICTIVE

      " Generic" LA.1         CTS LC0 3.6.2.3 includes details relating to system design, function, and Operability for the suppression pool cooling mode of the residual heat removal system. ITS 3.6.2.3 includes only a requireent for Operability and moves details of system design and specific Operability requirements to the Bases. This is acceptable because these details do not impact the ITS requirement to maintain the system Operable. These details can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bases Control Program. The design features and system configuration are also described in the UFSAR.

Changes to the plant controlled documents are controlled in i accordance with 10 CFR 50.59. l

I f l l FERMI - UNIT 2 2 REVISION 11 07/14/99 i e _

o DISCUSSION OF CHANGES ITS: SECTION 3.6.2.3. RESIDUAL HEAT REMOVAL-(RHR) SUPPRESSION POOL COOLING TECHNICAL CHANGES - LESS RESTRICTIVE

     Speci fic" L.1           CTS 3.6.2.3, Action a. requires restoration of an inoperable suppression pool cooling loop within 72 hours. Under the same conditions. ITS 3.6.2.3. Required Action A.1, allows 7 days to restore an inoperbble suppression pool cooling subsystem. This change makes the allowable out of service time for an inoperable suppression pool cooling subsystem consistent with the allowable out of service time for an inoperable LPCI subsystem. This change is acceptable because even with one inoperable suppression pool cooling subsystem. the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling        ,

function. However, the overall reliability is reduced because a single failure in the Operable subsystem could result in reduced primary containment cooling capability. Therefore, this change has a negligible affect on safety. L.2 CTS 3.6.2.3. Action b. requires that the reactor be in Mode 3 within 12 hours and mode 4 within 36 hours if both suppression pool cooling loops are inoperable. Under the same conditions. ITS 3.6.2.3. Required Action B.1. allows 8 hours to attempt to restore at least one inoperable suppression pool cooling subsystem to Operable status before a plant shutdown must be initiated. The additional 8 hours allowed to attempt restoration provides the benefit of potentially avoiding a plant transient (reactor shutdown and cool down) with less than the full complement of emergency systems. This change has minimal impact on safety because of the low probability of a DBA during this additional 8 hour period. RELOCATED SPECIFICATIONS - None IECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.6.2.3 consistent with the BWR STS. NUREG 1433. Rev. 1. FERMI UNIT 2 3 REVISION 11 07/14/99l

RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS L 1 (continued) cooling capabilities afforded by the OPERA 8LE subsystem and the low probability of a DBA occurring during this period.

      '/ABEtt T I
                      .         1 and               -

y,k If the Rootired Action and associated completion T'me$ di l Leadtten J1cannot be met f. 6;,, . .,,,. . . .: M ;m . ', < mm.suseress.ian vooLt.eenaa ==s yseeer area I N d 'Rhe plant must De Drought to a MODE in W11ch the %@ LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are . reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an I orderly manner and without challenging plant systems. l l SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to

 ]
 .s valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is                                      ;

acceptable since the RHR suppression pool cooling mode is I manually initiated. This SR does not require any testing or ! valve manipulation; rather, it involves verification that ' those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an I event requiring initiation of the sys'em is low, and the ' subsystem is a manually initiated system. This Frequency (continued) SWR /4-STS---- B 3.6-6g , _ , , . , , , , , , , , , N h Cu C l

F 1 l i l \ l 1 I l ! RHR Suppression Pool Spray

   ,                                                                                  3.6.2.4
                                                                                              ~

3.6 CONTAINMENT SYSTEMS 4 3.6.2.4 Residual Heat Removal (RE) Suppression Pool Spray LCO 3.6.2.4 Two RHR suppression pool spray subsystems shall be OPERABLE. l l APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression A.1 Restore RHR 7 days pool spray subsystem suppression pool inoperable. spray subsystem to OPERABLE status. B. Two RHR suppression B.1 Restore one RHR 8 hours

pool spray subsystems suppression pool l

inoperable. spray subsystem to OPERABLE status. l l C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. Bg! l C.2 Be in MODE 4. 36 hours i I l l 1 l FERMI UNIT 2 3.6 291 Revision 11 07/14/99

RHR Suppression Pool Spray , 3.6.2.4

i l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray 31 days I subsystem manual, power operated. and automatic valve in the flow path that is j not locked. sealed, or otherwise secured I in position is in the correct position or ! can be aligned to the correct position.

i SR 3.6.2.4.2 Verify each RHR pum) develops a flow rate In accordance

                           = 500 gpm through t1e heat exchanger and      with the suppression pool spray sparger while          Inservice operating in the suppression pool spray       Testing Program mode.
 )

l l l l l l FERMI LINIT 2 3.6 29ii Revision 11 07/14/99 b

RHR Suppression Pool Spray B 3.6.2.4

i B 3.6 CONTAINMENT SYSTEMS B 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray BASES BACKGROUND Following a Design Basis Accident (DBA), the RHR Suppression Pool Spray System removes heat from the suppression chamber airspace. The suppression 2001 is designed to absorb the sudden input of heat from t1e primary system from a DBA or a rapid depressurization of the reactor pressure vessel (RPV) through safety / relief valves. The heat addition to the suppression pool results in increased steam in the suppression chamber, which increases primary containment pressure. Steam blowdown from a DBA can also by) ass the suppression pool and end up in the suppression clamber airspace. Some means must be provided to remove heat from the suppression chamber so that the pressure and temperature inside primary containment remain within analyzed design limits. This function is provided by two redundant RHR suppression pool spray subsystems. The purpose of this LC0 is to ensure that both subsystems are OPERABLE in applicable MODES. i Each of the two RHR suppression pool sptcy subsystems contains two pumps and one heat exchanger which are manually initiated and independently controlled. The two subsystems perform the suppression pool spray function by circulating water from the suppression pool through the RHR heat exchangers and returning it to the suppression pool spray spargers. The spargers only accommodete a small portion of the total RHR pump flow; the remainder of the flow returns to the suppression pool through the suppression pool cooling return line Thus, both suppression pool cooling and suppression 001 spray functions are performed when the Suppression Poo Spray System is initiated. IRHR service water, circulating through the tube side of the heat exchangers. exchanges heat with the suppression pool water and discharges this heat to the RHR reservoir. Either RHR suppression pool spray subsystem is sufficient to condense the steam from small bypass leaks from the drywell to the suppression chamber airspace during the postulated DBA. l l FERMI UNIT 2 B 3.6.2.4 - 1 Revision 11 07/14/99 I

1

j RHR Suppression Pool Spray

   ,                                                                             B 3.6.2.4
                                                                                           ~

BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break loss of coolant accidents. The intent of the analyses is to demonstrate that the pressure reduction capacity of the RHR Su)pression Pool Spray System is adequate to maintain tie primary containment conditions within design limits. The time history for primary containment pressure is calculated to demonstrate that the maximum pressure remains below the design limit. The RHR Suppression Pool Spray System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 In the event of a DBA, a minimum of one RHR suppression pool spray subsystem is required to mitigate potential bypass leakage paths and maintain the primary containment peak pressure below the design limits (Ref.1). To ensure that these requirements are met, two RHR suppression pool spray subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool spray subsystem is OPERABLE when one of the RHR pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE. APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining RHR suppression pool spray subsystems OPERABLE is not required in MODE 4 or 5. P ACTIONS A_J With one RHR suppression pool spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE RHR suppression pool spray subsystem is adequate to perform the primary containment by) ass leakage mitigation function. However, the overall relia)ility is reduced because a single J l FERMI UNIT 2 B 3.6.2.4 - 2 Revision 11 07/14/99 y

RHR Suppression Pool Spray B 3.6.2.4

BASES ACTIONS (continued) failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation ca) ability. The 7 day Completion Time was chosen in light of t1e redundant RHR suppression pool spray capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period. IL1 With both RFR suppression pool spray subsystems inoperable. at least one subsystem must be restored to OPERABLE status within 8 hours. In this Condition, there is a substantial loss of the )rimary containment bypass leakage mitigation function. T1e 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available. C.1 and C.2 If the inoperable RHR suppression pool spray subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and H00E 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 I orderly manner and without challenging plant systems. I SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS i Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed. or otherwise secured in l position since these valves were verified to be in the l correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonarcident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or l FERMI UNIT 2 B 3.6.2.4 - 3 Revision 11 07/14/99 j

RHR Suppression Pool Spray B 3.6.2.4 BASES SURVEILLANCE REQUIREMENTS (continued) valve manipulation: rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Frecuency of 31 days is justified because tile valves are operatec under procedural control, improper valve position l would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the i subsystem is a manually initiated system. This Frequency I has been shown to be acceptable based on operating I experience. SR 3.6.2.4.2 ' Verifying each RHR pump develops a flow rate a 500 gpm while o>erating in the sup]ression pool spray mode with flow ' t1 rough the heat exc1 anger ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by Section XI of the ASME Code (Ref. 2). This test confirms one point on the puma desigii curve and is indicative of overall aerformance, Suc1 inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is [in accordance with the Inservice Testing Program. REFERENCES 1. UFSAR, Section 6.2.

2. ASME, Boiler and Pressure Vessel Code, Section XI. !

l FERMI UNIT 2 B 3.6.2.4 -4 Revision 11. 07/14/99 L )

6PECiFiCATION 8.6,7.Y CONTAlt9ENT SYSTEMS SUPPRESSION POOL m -t M, R, I p's, LINfTING CONDfTION FOR 0PERATION ~ ao s.wz.4 )

                       -Mr:t-r-The suppression pool @4vwe11A1iraidmode of the residual _ heat ___

removal (RHR) system shall be OPERABLE with twaynaep dent) loops, Joacn oop unmung

a. One OPERABLE RHR ump, and b An OPERABLE f W path capable of re irculating water on the suppression amber through an RH heat exchanger a the uppression y 1 and drywell sor snarsert /M/

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. Ell [3:

With one suppression pool (and/or-dryweH-serey}1oop inoperable, restore the inoperable loop to OPERABLE status ithin 7 days or be

[CD6td h in at least HOT SHUTDOWN within the next 12 hour nd in COLD SHUTDOWN within the following 24 hours, g,l r

                                 -tr. With both suppression pool n#v1          -- i; y--iD loops inoperable, restore at least one loop to           LE status within 8 hours or he
                       /)f-T209 3        in at least HOT SHUTDOWN within the next 12 hours and in COLD                         ;

s SHUTDOWN

within the following 24 hours.

p pg g SURVEILLANCE REOUIREMENTS i 4.6.2.2 The suppression pool iind Jrywell M M aod the RHR system shall be demonstrated OPERABLE: g,/

a. At least once per 31 days by verifying that each valve (manual,

                   $R 3.G.'2,t/, f       power-operated, or automatic) in the flow path that is not locked,nj'ose of this LCO separate Condition entry is allowed for eac1 penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate com>ensatory actions for each inoperable SCIV. Complying wit 1 the kequired Actions may allow for continued operation, and subsequent inoperable SCIVs are governed by subsecuent Condition entry and application of associated Requirec Actions.

The third Note ensures ap)ropriate remedial actions are taken, if necessary, if t1e affected system (s) are rendered inoperable by an inoperable SCIV. A.1 and A.2 i In the event that there are one or more penetration flow paths with one SCIV inoperable, the affected penetration flow path (s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic SCIV a closed manual valve. and a blind flange. For penetrations isolated in accordance with FERMI UNIT 2 B 3.6.4.2 -3 Revision 11, 07/14/99

o I SCIVs-B 3.6.4.2 1

 ]        BASES ACTIONS (continued)

Required Action A.1. the device used to isolate the

                           - penetration should be the closest available device to secondary containment. The Required Action must be               '

completed within the 8 hour Completion Time. The specified time period is reasonable considering the time required to l 1solate the penetration, and the probability of a DBA, which requires the SCIVs to close, occurring during this short time is very low. For affected penetrations that have been isolated in accordance with Required Action A.1, the affected -

                             >enetration must be verified to be isolated on a periodic
                             > asis. This is necessary to ensure that secondary containment penetrations required to be isolated follovi.ng an accident, but no longer capable of being automatically isolated..will be in the isolation position should an event occur. The Completion Time of once per 31 days is appropriate because .Ae valves are operated under administrative contrds and the probability of their misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves verification that the affected penetration remains isolated.
       ^l                   Required Action A.2 is modified by two Notes. Note 1 applies to devices located in high radiation areas and allows them to be verified closed by use of administrative controls. Allowing verification by administrative controls n                       is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of b                   misalignment, once they have been verified to be in the -

s proper position is low. Note 2 applies to isolation Q devices that are locked, sealed, or otherwise secured in g) position and allows these devices to be verified closed by (c l use of administrative means. Allowing verification by administrative means is considered acceptable, since'the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently i repositioned. ! 1L1 With two SCIVs in one or more penetration flow paths inoperable. the affected penetration flow path must be " isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. UNIT 2 B 3.6.4.2-4 Revision 11 07/14/99

 ~h l FERMI L

SCIVs B 3.6.4.2 s .

     )       BASES                                                                                       i l

ACTIONS (continued) Isolation barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve, and a , blind flange. The 4 hour Completion Time is reasonable I considering the time required to isolate the penetration and the probability of a DBA which requires the SCIVs to close, occurring during this short time, is very low. The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of - two penetrations. C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 i does not apply. To achieve this status, the plant must be trought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the : 3 ' required plant conditions from full power conditions in an orderly manner and without challenging plant systems. D.1. D.2. and D.3 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply. If applicable. CORE ALTERATIONS and the movement of irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable. I actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a ves:;e1 draind6wn and i g the subsequent potential for fission product release. ' w Actions must continue until OPDRVs are suspended. ! 1 M' The Required Actions have been modified by a Note stating ' Q that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5. LCO 3.0.3 would not specify any action. If moving fuel while in MODE 1. 2. or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

      /J j FERMI   UNIT 2                       B 3.6.4.2 - 5               Revision 11. 07/14/99

[ SCIVs B 3.6.4.2

     ).         BASES j

l SURVEILLANCE SR 3.6.4.2.1 REQUIREENTS i

         &                      This~ SR verifies that each secondary containment manual D                     .1 solation valve and blind flange that is not locked, sealed, D                    or otherwise secured and is required to be closed during
          %                     accident conditions is closed. The SR helps to ensure that C-                        post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position.               .

Since these SCIVs are readily accessible to personnel during normal operation and verification of their msition is relatively easy, the 31 day Frequency was closen to

         %                      provide added assurance that the SCIVs are in the correct positions. This SR does not apply _ to valves that are

3) locked, sealed, or otherwise secured in the closed position Q since these were verified to be in the correct position upon locking, sealing, or securing.

Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during I MODES 1. 2, and 3 for ALARA reasons. Therefore, the i probability of misalignment of these SCIVs, once they have ; been verified to be in the proper position, is low. ' A second Note has been included to clarify that, SCIVs that , are open under administrative controls are not. required to l meet the SR during the time the SCIVs are open. t n SR 3.6.4.2.2 O Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate y OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that ; assumed in the safety analyses. The isolation time and ' Frequency of this SR are in accordance with the Inservice Testing Progr6;n. l FERMI UNIT 2 B 3.6.4.2-6 Revision 11. 07/14/99 =

5Pkeenekrrod MM 2-CONTAINMENT SYSTEMS M.I SECONDARY CONTAINMENT AUTOMATIC ISOLATION DAMPERS LIMITING CONDITION FOR OPERATION LCO -0.0.0.2 lhe secondary containment ventilation system automatic isolation g, g ,g dampers C.- . ir. T.:;;e 3.;.L.0-7 shall be OPERABLE Giu. ..e;.;.e.. :m:: :r9 U A.I Qhr : ::;.;;; :: -enrr:rn: "!.M .:.:.: 7-APPLICABILITY: OPERATIONAL E NDITIONS 1, 2, 3 and *. FnDD McTE 1} QL,'l ACTION: ' nes Notr z.} 4eo aers 3 -- A .3 h lbI Witho[neormoreof_the>seconarycontainme ventilatt system automatic ' isolation dampers at: : - ::M: :. .:.: noperable fmaintam at seast one2 l.1 Osolation damper OPERABLE in eacn a"tecteo penetration that is openfand within 8 hours either: , _j g g,y g x L "ed r r r in:;;.;M : i:;:r':l t: OP:FM'_E :t:t_;, cr- . 1

b. Isolate each affected penetration by use of at least one deactivated !

6.aisak 4chon damper secured in the isolation position, or p Isolate each affected penetration by use of at least one closed A.i c. manual valve or blank flange. Otherwise, in OPERATIONAL CONDITION 1, 2, or 3 be in at least HOT ; rc~ Amm c, SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the ! following 24 hours, Otherwise, in Operational Condition *, suspend handling of irradiated fuel i ActoeJ D in the secordary containment, CORE ALTERATIONS and operations with a i potential far draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable. SURVEILLANCE REOUTREMENTS _ 4.6.5.2 Each secondary containm t ventilation system automatic isolation damper Q.;e a n, ..u.- i.;.;.: p all be demonstrated OPERABLE:

a. Prior scement work i performed on the da er or its associa _d ir] LR*I returning th damper to service aft r maintenance, re or r act tor, control or power circuit by cyc ng the damper thr gh at I le st one complete yele of full travel dverifyinothe<ecified) ,b 4 latinn t w e ~

1 fR 3.(,.V.1 3 b. G i m m - .. u .m m- at least once per 18 months by g verifyingactuates damper that on toa containment isolation its isolation position. acWte t,rsignal each dimu la kd is(lation R'5

c. By verifying the isolation time to be within its limit when tested M h*U L pursuant to Specification 4.0.5.

                       *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations witn a potential for draining the reactor vessel.

FERMI - UNIT 2 3/4 6-52' .-

  ,    /                                                                                                                      ,t PAGE          c0      0F        03                               b5I

(.

DISCUSSION OF CHANGES

                                      .ITS: SECTION 3.6.4.2   SCIVs                                 1 TECHNICAL CHANr#R       1Ftt RES1RICTIVE
        " Generic" LA.1          CTS Table 3.6.5.2-1, and various references to it in CTS LCO 3.6.5.2, will be relocated from the Technical Specifications to the Technical Requirements Manual (TRM). The specific relocation     l of component lists, and their isolation times from Technical         m Specifications is consistent with the direction of Generic Letter      b 9108, " Removal Of Component Lists From Technical Specifications."

Relocation of the list of valves and associated maximum isolation time to the TRM maintains the consistency with NUREG 1433. These ly details can be adequately defined and controlled by the provisions - of 10 CFR 50.59. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the requirement for valve Operability remains in the Technical Specifications. LA.2 CTS 4.6.5.2.b requires an automatic isolation valve test, but restricts performance of this test to "during Cold Shutdown or Refueling." ITS SR 3.6.4.2.3 requires this same test, but the details regarding requisite plant conditions and scheduling is deleted. These details do not impact the requirement to maintain the valves Operable. and the ITS SR continues to ensure that all b ; automatic PCIVs function properly. Therefore, this change will

not have any negative impact on safety. Removal of this restriction was recommended by and supported in Generic Letter 91-k 04, and is consistent with the ISTS NUREG 1433. Tne ITS Bases continue to acknowledge that, at least for many of the PCIVs. it is prudent to conduct the testing during outages: as such, this aspect of the CTS restriction is relocated to the ITS B'ases, which require change control in accordance with ITS 5.5.10. Bases ;

Control Program. LR.1 CTS SR 4.6.5.2.a requires a demonstration of Operability after l maintenance or repair on an isolation valve. The proposed change ' removes this requirement from Technical Specifications. Verifying l proper Operability, including stroke time, of these valves after l maintenance on these valves is normal maintenance and operating practice. In addition. the requirement to verify the correct l stroke time of these valves per the IST Program is required by ITS '

     ,              SR 3.6.4.2.2. . Consequently. Operability of these valves is
                   - periodically verified and removal of the explicit requiremnt e   to               '

verify Operability of the valve after maintenance is considered FERMI UNIT 2 3 REVISION 11 07/14/99l w

l f i ,' DISCUSSION OF CHANGES l ITS: SECTION 3.6.4.2 - SCIVs acceptable. The removal of CTS SR 4.6.5.2.a maintains consistency with NUREG 1433. Regulatory control of changes to these . requirements (e.g.. Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and safety since these details do not impact the requirement to maintain the equipment Operable. q h LR.2 Not used. l v TECHNICAL CHANGES - LESS RESTRICTIVE

  Speci fic" L.1           ITS 3.6.4.2 includes an explicit allowance for intermittently opening closed Secondary Containment Isolation Valves under administrative control as is allowed in the CTS for primary containment isolation valves. The allowance is included in Actions Note 1 and SR 3.6.4.2.1 Note 2. As described in the Bases for ITS 3.6.4.2 Actions, administrative controls that allow this exception consist of stationing a dedicated operator, who is in communication with the control room, at the controls of the isolation device. In this way the penetration that is opened to support an necessary operational activity can be rapidly isolated when a need fo:' secondary containment isolation is indicated.

Therefore, this less restrictive change has minimal impact on plant safety. L.2 CTS 3.6.5.2 Actions for inoperable secondary containment isolation dampers, which requires maintaining one isolation damper Operable, would not be met in the event both dampers in a penetration are inoperable. In this event, an immediate shutdown (per CTS 3i.6.5.2 "otherwise " Action) is required. ITS 3.6.4.2. Action B. provides 4 hours for isolation, prior to commencing a required I shutdown. This 4 hour period is consistent with time allowed for an inoperable secondary containment, and is therefore an appropriate allowance. l l i l

DISCUSSION OF CHANGES ITS: SECTION 3.6.4.2 - SCIVs s. I CTS 4.6.5.1.b.3 addresses the monthly verification of secondary A L.3 containment isolation with non automatic valves. By virtue of being associated with CTS 3.6.5.1, any failure of this < surveillance results in applying either a 4 hour restoration (in MODES 1. 2, and 3) or an "immediate" restoration (other required { - condition). ITS combines all penetration isolation valve D requirements in ITS 3.6.4.2 and allows an 8 hour restoration. Furthermore. ITS Actions apply an allowance for separate Condition entry (Actions Note 2). These relaxations provide consistent treatment for. secondary containment penetrations with inoperable isolation devices. Since these Actions have been found acceptable for inoperable automatic isolation valves, these changes will not Y - introduce any unacceptable impact on safety. 3 N

           - L.4        Not used.                                                              g L.5        CTS 4.6.5.1.b addresses the monthly verification of secondary containment isolation with non automatic valves. ITS SR 3.6.4.2.1 requires this same monthly verification, but excludes valves that are locked, sealed, or otherwise secured in the closed position.

s. Excluding these valves from the monthly verification is acceptable based on the controls inherent in locking, sealing or securing the Q .

valve after verifying it to be closed. Since the valve is reasonably assured of being closed when required. this change has y no negative impact on safety. RELOCATED SPECIFICATIONS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.6.4.2 consistent with the BWR STS. NUREG 1433. Rev. 1. ( s FERMI UNIT 2 5 REVISION 11 07/14/99l i

SCIVs B 3.6.4.2 BASES APPLICABLE established by SCIVs is required to ensure that leakage from SAFETY ANALYSES the primary containment is processed by the Standby Gas (continued) Treatment (SGT) System before being released to the environment. Maintaining SCIVs OPERA 8LE with isolation times within limits ensures that fission products will remain trapped inside'.ftscondarf) bytheSGTSystemp(containmentsothattheycanbetreat,, rior to discharge to the environment. O[.( SCIVs satisfy Criterion pf0 1%%3 of ".; "::C .N'ky St.t.d.. LC0 SCIVs fem a part of the>$econdaryy' containment boundary. The SCIV safety function < s related to control of offsite , radiation releases re fram DBAs 44*fpr5*h D . The power operated usiivaives are considered OPERABLE when their isolation times are within limits and the valves actuate on an automatic isolation signal. The valves covered by this LCO, along with their associated stroke _ times, are listed in Reference 3. g,gg j,g,y g pi g The nomally closed isolation valves or/ blind ~ considered OPERABLE when manual valvesWare clos s are open in b h

     .T              f,5          accordance with appropriate administrative cont , ,

r . . _ _ _ . .m . . . . . - su ,_

       .)                         posit       , and blind flan
                                                                     .........in are in place. Th          passive... . , . . . .J m isol on valves or dev es are listed in Re rence 3. f APPLICABILITY       In MODES I, 2, s d 3, a DBA could lead to a fission product release to the primary containment that leaks to the 9econdary)< containment. Therefore, the OPERABILITY of SCIVs is required.

In MODES 4 and 5, 'the probability and consequences. of these events are reduced due to pressure and temperature-limitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant radioactive releases can be postulated, such as during operations with a potential for draining the reactor vessel (0PDRVs), during CORE (continued) s.h * >Is 8 3.6-103 h; 1, Mj07ln

 ~
                                                                                                         - Rsn ll Rev5' I l

l SCIVs B 3.6.4.2 BASES (continued) D

 ./                                                                   Wlock.a), caaled, W             ~

SURVEILLANCE SR 3.6.4.2.1 @ Mgs.s u M ed REQUIREMENT % i f This SR verifies that each secondary gg;a anual l Le ! isolation valve and blind flange that 1stequired to be ; closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids-or gases outside of theTE~econdary)(containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in.$recondargeontainment that are capable of being mispositioned are in the correct position. SincetheseSCIVsarereadilyaccessibletopersbnnelduring normal operation and verification of their position is relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct I/tJSenr ] positions.f ,i 8 3 bN*b

    ,~                         Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high 4

h radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES I, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these SCIVs, once they have been verified to be in the proper position, is low. A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. SR 3.6.4.2.2 g t, Verifying that the isolation time of each power operatedand=-

automatic SCIV is within limits is required to ;

demonstrate OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are Tin accordance with the Inservice Testing Program e M i.ys). f (continued)

          @R/41T:;                               B 3.6-107                   Rev 1, v4&if95--

J Jev11 l N 1

r.- l l, 1 I SCIVs B 3.6.4.2 l Insert B 3.6.4.2 2 1 This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position since these were verified to be in the correct position upon locking, sealing, or securing. l l

I I l FERMI UNIT 2 Page B 3.6 107 (INSERT) REVISION 11 07/14/99l l

JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.4.2 SCIVs NON BRACKETED PLANT SPECIFIC CtMfd5 P.1 'Not used. P.2 Not used. P.3 Not used. P.4 The Bases Background reference to DBAs is general - not specific only to LOCAs. whien is what Reference 1 entails. Eliminating reference to the UFSAR Section for LOCA safety analyses will have no impact on the Bases content or understanding. P.5 The Bases discussion of normally closed SCIVs is eliminated. This , editorial preference is based on incomplete (and therefore potentially misleading) discussion of these valves, as well as an inconsistent level of detail when compared to other isolation devices. Elimination of this detail does not modify the requirements or the interpretation of those requirements. The LCO Bases are intended to provide a few details regarding OPERABILITY. These details are not all encompassing. but only serve to outline salient features (in this case of SCIV OPERABILITY). The paragraph discussing abnormally closed SCIVs I attempts to define OPERABILITY of these valves but makes I statements that are not true in all cases. There maybe lines with l normally closed SCIVs where the SCIV could be an automatic isolation valve. These valves are NOT required to be " deactivated and secured in their closed position" to be OPERABLE. Also, blind 4 3 flanges are addressed as part of the secondary containment boundary, and do not support OPERABILITY of normally closed SCIVs. Even with elimination of the erroneous discussions. this paragraph provides no necessary detail regarding OPERABILITY, and:can be deleted without loss of information useful to the Operator in determining OPERABILITY. It is nct deemed necessary to expound on any OPERABILITY criteria for normally closed SCIVs. 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).

FERMI UNIT 2 1 REVISIONT1 07/14/99l u

1 JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.4.2 - SCIVs GENERIC CHANGES' s C.1 TSTF 45: NRC approved change to NUREG 1433. i C.2 TSTF 46: NRC approved change to NUREG 1433. 4 4 1 l l 1 l j n. FERMI UNIT 2 2 REVISION 11 07/14/99l L

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 - SCIVs TECHNICAL CHANGES - LESS RESTRICTIVE \m (Specification 3.6.4.2 "L.4" Labeled Comments / Discussions) 4 l Not used. k 1

l i i e ein

FERMI UNIT 2 7 REVISION 11 07/14/99l m

T-i- f i NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 SCIVs

l TECHNICAL CHANGES - LESS RESTRICTIVE (Specification 3.6.4.2 "L.4" Labeled Comments / Discussions) l' l ' h

Not used. k k i l l i l 1 1 FERMI UNIT 2 8 REVISION 11. 07/14/99l u

E t. SGT System 3.6.4.3 i

                                                                                                         ~
         )       ACTIONS CONDITION                  REQUIRED ACTION               COMPLETION TIME 1

Immediately C. (continued) C.2.1 Suspend movement of irradiated fuel assemblies in secondary containment. M C.2.2 Suspend CORE Immediately ALTERATIONS. ,I C.2.3 Initiate action to Immediately suspend OPDRVs. l l D. Two SGT subsystems- D.1 Enter LC0 3.0.3. Immediately inoperable in MODE 1,

      .1              2, or 3.

E. Two SGT subsystems - - NOTE -- -- ---- inoperable during LC0 3.0.3 is not applicable. Q movemnt of irradiated fuel assemblies in the secondary E.1 Suspend movement of Immediately E@ containment, during irradiated fuel CORE ALTERATIONS, or assemblies in during OPDRVs. secondary , containment. - M (continued)

l FERMI - UNIT 2 3.6 41 Revision 11 07/14/99 a

O' . JVoldme9 SECTION3.8se ;f '

                                                                                    , s.
                                                                                            ~

Remove Replace 3.8.1 ITS pg 3.8-3 Rev 7 3.8.1 ITS pg 3.8-3 Rev i1 3.8.1 ITS pg 3.8-5 Rev 0 3.8.1 ITS pg 3.8-5 Rev i1 3.8.1 ITS pg 3.8-6 Rev 7 3.8.1 ITS pg 3.8-6 Rev i1 3.8.1 ITS pg 3.8 7 Rev 0 3.8.1 ITS pg 3.8-7 Rev ii B 3.8.1 ITS pg B 3.8.1-16 Rev 7 B 3.8.1 ITS pg B 3.8.1-16 Rev 11 B 3.8.1 ITS pg B 3.8.1 17 Rev 7 B 3.8.1 ITS pg B 3.8.1-17 Rev i1 B 3.8.1 ITS pg B 3.8.1-18 Rev 7 B 3.8.1 ITS pg B 3.8.1 18 Rev i1 3.8.1 DOCS pg 1 Rev 0 3.8.1 DOCS pg 1 Rev i1 3.8.1 DOCS pg 4 Rev 7 3.8.1 DOCS pg 4 Rev i1 3.8.1 DOCS pg 6 Rev 0 3.8.1 DOCS pg 6 Rev i1 3.8.1 DOCS pg 7 Rev 0 3.8.1 DOCS pg 7 Rev 11 3.8.1 DOCS pg 9 Rev 7 3.8.1 DOCS pg 9 Rev i1 3.8.1 DOCS pg 12 Rev 0 3.8.1 DOCS pg 12 Rev i1 3.8.1 NUREG M/U pg 3.8-7 Rev 0 3.8.1 NOREG M/U pg 3.8-7 Rev i1 3.8.1 NUREG M/U pg 3.8-12 Rev 0 3.8.1 NUREG M/U pg 3.8-12 Rev i1 3.8.1 NUREG M/U pg 3.8-13 Rev 7 3.8.1 NUREG M/U pg 3.8-13 Rev i1 B 3.8.1 NUREG M/U pg B 3.8-26 Rev 0 B 3.8.1 NUREG M/U pg B 3.8-26 Rev 11 3.8.2 DOCS pg i Rev 0 3.8.2 DOCS pg i Rev i1 3.8.2 DOCS pg 4 Rev 7 3.8.2 DOCS pg 4 Rev i1 3.8.2 DOCS pg 5 Rev 7 3.8.2 DOCS pg 5 Rev i1 l l l l Rev 11 07/14/99 b

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREENTS SURVEILLANCE FREQUENCY > SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit. SR 3.8.1.2 --- - - - -

                                                         -NOTES -          --           - --

l 1. All EDG starts may be preceded by an n engine prelube period and followed by N a warmup period prior to loading.

2. A modified DG start involving id'11ng -

and gradual acceleration to k synchronous speed may be used for this SR as recommended by the manufacturer. Verify each EDG starts and achieves steady 31 days state voltage = 3740 V and s 4580 V and frequency = 58.8 Hz and s 61.2 Hz. SR 3.8.1.3 - - -

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

1. EDG loadings may include gradual loading as recommended by the manufacturer.

        -                      2.      Momentary transients below the load T                                  limit do not invalidate this test.
     ~
     $                         3.      This Surveillance shall be conducted on only one EDG at a time.                                 .

l Verify each EDG is synchronized and loaded 31 days and operates for = 60 minutes at a load '

                               = 2500 kW.

(continued) 4 [ FERMI . UNIT 2 3.83 Revision 71 07/14/99 m

AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.9 Verify each EDG does not trip and voltage 18 months is maintained s 4784 V during and following a load rejection of = 2850 kW. SR 3.8.1.10 -- -

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

All EDG starts may be preceded by an engine prelube period. Verify on simulated loss of offsite power 18 months signal:

a. De energization of emergency buses:

b. Load shedding from emergency buses; and

c. EDG auto starts and:

1. energizes permanently connected i loads in s 10 seconds.

I

2. energizes auto connected shutdown loads through load sequencer.

3. maintains s"udy state voltage

                                       = 3740 V ano

4580 V.

4. maintains steady state frequency

                                       = 58.8 Hz and s 61.2 Hz and

5. supplies permanently connected and .

auto connected shutdown loads for

                                       = 5 minutes.                               :

(continued) j l l k l FERMI UNIT 2 3.8 5 Revision 11. 07/14/99

n AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) l SURVEILLANCE FREQUENCY SR 3.8.1.11 --- - --........ NOTE- .--- - -- - - - All EDG starts may be preceded by an i engine prelube period. I Verify on an actual or simulated Emergency 18 months Core Cooling System (ECCS) initiation l signal each EDG auto starts and: i

a. In s 10 seconds after auto start and during tests, achieves voltage j = 3740 V and frequency a 58.8 Hz: '

m

   &                          b. Achieves steady state frequency s                                = 58.8 Hz and s 61.2 Hz, and voltage W                                = 3740 V and s 4580 V: and l                       c. Operates for a 5 minutes.

I SR 3.8.1.12- Verify each EDG*s automatic trips are 18 months o bypassed on an actual or simulated gl emergency start signal except: k a. Engine overspeed;

b. Generator differential current:

c. Low lube oil pressure:

d. Crankcase overpressure: and i

e. Failure to start.

(continued)

        ! FERMI    UNIT 2                                 3.8 6                   Revision 11    07/14/99 i

AC Sources-0perating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.13 .--.--..-- ..-

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

Momentary transients outside the load range

                      .do not invalidate this test.

Verify each EDG operates for = 24 hours: 18 months

a. For all but the final = 2 hours. loaded a 2500 kW and s 2600 kW: and

b. For the final = 2 hours of the test loaded = 2800 kW and s 2900 kW. .

SR 3.8.1.14 - ---- -- ------ NOTES - -- - - --- --

1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated a 2 hours loaded a 2500 kW or until operating temperatures have stabilized.

2f Momentary transients below the load limit do not invalidate this test. Ek

2. All EDG starts may be preceded by an engine prelube period.

Verify each EDG starts and achieves: 18 months

a. In s 10 seconds, voltage = 3740 V and frequency = 58.8 Hz: and

b. Steady state voltage = 3740 V and -

5 4580 V and frequency = 58.8 Hz and s 61.2 Hz. (continued) l FERMI UNIT 2 3.8 7 Revision 11.- 07/14/99 L.

I AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing. SR 3.8.1.12 This SurveillaTe demonstrates that EDG non critical

o protective fur >;tions (e.g., high jacket water temperature) 7 are bypassed e. an actual or simulated emergency start (LOCA

   -                    or loss of offsite power) signal and critical protective k                    functions (engine overspeed, generator differential current, low lubricating oil pressure crankcase overpressure, and failure to start) trip the EDG to avert substantial damage to the EDG unit. The non critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition.

This alarm provides the operator with sufficient time to react appropriately. The EDG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the EDG. The 18 month Frecuency is based dn engineering judgment, takes into consiceration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. . SR 3.8.1.13 .- Regulatory Guide 1.108 (Ref. 9). paragraph 2.a.(3), requires demonstration once per 18 months that the EDGs can start and run continuously at full load capability for an interval of not less than 24 hours-22 hours of which is at a load equivalent to the continuous rating of the EDG, and 2 hours of which is at a load equivalent to 110% of the continuous duty rating of the EDG. Fermi 2 has taken an exception to this requirement and performs the 22 hour run at approximately 90% of the continuous rating (2500 kW-l FERMI - UNIT 2 B 3.8.1 - 16 Revisi n 11 07/14/99 i ~

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 2600 kW). and performs the 2 hour run at approximate 1.y the continuous rating (2800 kW 2900 kW). The EDG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2. and for gradual loading, discussed in SR 3.8.1.3. are applicable to this SR. n Although no power factor requirements are established by this SR. the EDG is normally operated at a power factor b( between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is an operational limitation to ensure circulating currents are minimized. A G load band is provided to avoid routine overloading of the - EDG. Routine overloading may result in more frequent ; teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY. The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3): takes into consideration plant conditions required to perform the Surveillance: and is intended to be consistent with expected fuel cycle lengths. This Surveillance has been modified by a Note. The Note states that momentary transients due to changing bus loads do not invalidate this test. SR 3.8.1.14 This Surveillance demonstrates that the diesel engine can restart from a hot condition. such as subsequent to shutdown from normal Surveillances, and achieve the minimum required voltage and frequency within 10 seconds and maintain a steady state voltage and frequency range. .The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5). This SR is modified by two Notes. Note 1 ensures that the n test is performed with the diesel sufficiently hot. The p requirement that the diesel has operated for at least 2 hours near full load conditions prior to performance of W 3 this Surveillance is based on manufacturer recommendations for achieving hot conditions. Routine overloads may result Dl in more frequent teardown inspections in accordance with l FERMI UNIT 2 B 3. 8.1 - 17 Revisio 11. 07/14/99

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREENTS (continued) vendor recommendations in order to maintain EDG OPERABILITY. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all EDG starts to be preceded by an engine prelube period to minimize wear and' tear on the diesel during testing. SR 3.8.1.15 i As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and load transfer from the EDG to the offsite source can be made and that the EDG can be returned to standby status when offsite power is restored. It also ' ensures that the auto start logic is reset to allow the EDG to restart and reload if a subsequent loss of offsite power occurs. The EDG is considered to be in standby status when the EDG is shutdown with the output breaker open, the load sequence timers are reset, and is able to restart and reload on a subsequent bus under voltage. The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into consideration plant conditions desired to perform the Surveillance. SR 3.8.1.16 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the EDGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the EDG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delaysr are not violated. Reference 2 provides a summary of the automatic I loading of ESF buses. The Frequency of 18 months is consistent with the l l recommendations of Regulatory Guide 1.108 (Ref. 9). l paragraph 2.a.(2): takes into consideration plant conditions required to perform the Surveillance: and is intended to be i consistent with expected fuel cycle lengths. _ i i g l FERMI UNIT 2 B 3.8.1 - 18 Revision 11. 07/14/99 I l

DISCUSSION OF CHANGES ITS: SECTION 3.8.1 AC SOURCES 0PERATING 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 l NUREG 1433. Rev. 1. i A.2 CTS 3.8.1.1. Action b allows not performing the EDG start if , common mode failure is ruled out. The CTS also details various l potential causes of EDG inoperability. which would not require demonstration of start capability of the remaining Operable EDGs. 1 The potential causes listed are only some of the causes that could ' be ruled out as potential common mode failures (thereby a'llowing avoidance of additional EDG starts). Since the CTS Action more l generally allows demonstration of the absence of any potential common mode failures, in lieu of an actual EDG start test, the specific list of potential causes is considered an unnecessary partial list. ITS 3.8.1 Required Actions B.3.1 and B.3.2. present these requirements without the specific list of possible l common mode failure causes. Since the technical requirements i remain unchanged, this is considered a presentation preference ! only, p T A.3 Not used. lg A.4 Not used. 36

FERMI UNIT 2 1 REVISION 11. 07/14/99l L

DISCUSSION OF CHANGES

.                       ITS: SECTION 3.8.1    AC SOURCES 0PERATING TECHNICAL CHANGES     LESS RESTRICTIVE
    " Generic" LA.1        CTS LC0 3.8.1.1 provides details defining the two offsite AC power sources, and design features of the EDGs (i.e.. " separate and independent." " Division I and Division II, each consisting of two emergency diesel generators " and "A separate fuel' transfer pump"). The details relating to system design function, and Operability are not necessary in the ITS. These details are p

relocated to the Bases, which maintains the consistency with D NUREG 1433. The definition of Operability, the Bases outline of 6 Operability details (which requires change control in accordance with ITS 5.5.10. Bases Control Program), and the surveillance requirement for the fuel oil transfer pump (ITS SR 3.8.1.6). ' provides sufficient control of these details. These details are not required to be in the ITS, and ITS LCO. to provide adequate protection of the public health and safety, because these' details do not impact the requirement to maintain the equipment Operable. LA.2 CTS SR 4.8.1.1.2.a.4 details the options for the start signals that can be used for the monthly EDG start. These details are relocated to the Bases. The relocation of this information maintains the consistency with NUREG 1433. This is acceptable because these details do not impact the requirement to start the EDG. These details can be adequately defined and controlled in the Bases, which require change control in accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health-and safety since the requirement for EDG Operability remains in the Technical Specifications. LA.3 Not used. - l1 i l FERMI UNIT 2 4 REVISIO 11. 07/14/99l l u

DISCUSSION OF CHANGES ITS: SECTION 3.8.1 AC SOURCES 0PERATING l provide adequate protection of the public health and safety, because these details do not impact the test requirement or the requirement to maintain the equipment Operable. LA.7 CTS 4.8.1.1.2.e.2 requires an EDG load rejection to not exceed one of two values, stated in relation to EDG design and operating parameters. These two possible values for the overspeed trip point are fixed by the design of the EDG unit. The appropriate value (i.e., the most limiting) is presented in the ITS (SR 3.8.1.8) as a single value for the generator frequency. eliminating the ne'ed to evaluate the two options. This presentation relocates the. underlying basis for the accepted value from the Technical Specifications, to the Bases. This change is. acceptable because there is no difference in the requirement: the - requirement to perform a load rejection test with a load equivalent to the largest single load is maintained in Technical Specifications. The underlying basis for the acceptance criteria will be maintained in the Bases which require change control in accordance with the ITS 5.5.10. Bases Control Program. Relocating this surveillance detail maintains consistency with NUREG 1433. These details are not required to be in the ITS to provide adequate protection of the public health and safety, because these details do not impact the test requirement or the requirement to maintain the equipment Operable. LA.8 Not used. 1 lE FERMI UNIT 2 6 REVISION 11 07/14/99l L _

I I DISCUSSION OF CHANGES

 .                       ITS: SECTION 3.8.1      AC SOURCES-OPERATING

! M.9 CTS SR 4.8.1.1.2.e.9 requires the maximum auto connected load to I each EDG be verified. This design detail for the auto connected l

              -loads is not retained in ITS: it is relocated from CTS since it is adequately defined and controlled in the TRM. This detail is not       l     .

necessary to be in ITS to ensure the Operability of the EDGs. q f Relocating this surveillance maintains consistency with NUREG-1433. The definition of Operability, and the 10 CFR 50.59

                                                                                        /f l

approval process for design and TRM changes, are adequate to lv ensure the.EDG loading is maintained within acceptable design , limits. These details are not required to be in the ITS to I provide adequate protection of the public health and safety since the' requirement for EDG Operability remains in the ITS. . l LA.10 CTS SR 4.8.1.1.2.e.12. to verify the EDG lockout features prevent 1 EDG starting only when required, is relocated to the Fermi l Technical Requirements Manual (TRM). If an EDG lockout feature prevents the EDG from operating during an accident, this will still be identified.during the LOOP LOCA, and LOCA/ LOOP EDG Surveillances (ITS SRs 3.8.1.10. 3.8.1.11. and 3.8.1.17) which are performed at the same periodicity as the " lockout" Surveillance. Since the condition requiring the lockout is one that reflects EDG inoperability, failure of a lockout feature to i l properly lockout an EDG does not, in itself, impact EDG Operability. Relocating this surveillance maintains consistency with NUREG 1433. Changes to the Fermi TRM are controlled by the provisions of 10 CFR 50.59. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the requirement for EDG Operability remains in the Technical Specifications. LA.11 Not used.- LA.12 CTS SR 4.8.1.1.2.g.2 details the requirement to perform a pressure test on the EDG fuel oil system piping. This requireme'nt is relocated to the ISI NDE Program. The CTS pressure test of the fuel oil system is covered by ASME Code Section XI Article IWD 5000. As a result, adequate controls exist to allow relocation of this requirement to the ISI-NDE Program. Relocating this surveillance maintains consistency with NUREG 1433. Changes to the ISI NDE Program require revisions to be controlled by 10 CFR 50.55a. These details are not required to be in the ITS to

   -             provide adequate protection of the public health and safety since the requirement for EDG Operability remains in the Technical Specifications.
                                                                         ~'

FERMI UNIT 2 7 REVISIO 11. 07/14/99l

4 1 DISCUSSION OF CHANGES ITS: SECTION 3.8.1 AC-SOURCES OPERATING-N LR.5 ' Not used. l1 k 4 O k ew* FERMI UNIT 2 9 REVISION 11 07/14/99l k

r 1 DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES 0PERATING frequency limits must be met for the EDG output breaker to close onto a dead bus. This verification that the minimum voltage and frequency limits are net within the proper time is sufficient to ensure the EDG can perform its design function. Therefore, maximum voltage and frequency limits associated with the 10 second start criteria are eliminated. When the start test is performed, and it does not result in the EDG being automatically tied to a dead bus, a voltage or frequency overshoot can occur (the loading tends to minimize the overshoot). This overshoot could be such that the voltage or frequency is momentarily high outside the band. This condition, however, is not indicative of an inoperable EDG, provided that steady state voltage and frequency can be maintained. (Note, the steady state - limit reauirements have not been changed.) Therefore, eliminating the maximum voltage and frequency limits for the ITS SR 3.8.1.7 and SR 3.8.1.11 10 second acceptance criteria does not result in any impact on safety. L6 CTS SRs 4.8.1.1.2.a.5. and 4.8.1.1.2.e.8 including its associated footnote *, require a specific load range for EDG testing. ITS is modified by Notes (SR 3.8.1.3 Note 2. SR 3.8.1.13 Note, and D SR 3.8.1.14 Note 1) allowing that " momentary transients below the -p load limit do not invalidate this test." Momentary transients may 1 l occur for various reasons during loading, unloading, and steady state operation of the EDG. However, these transients are quickly

                                                                             &    l restored to within the limits and do not reflect an inability of the EDG system to fulfill its function. Therefore, these transients should not be considered as a failure of the Surveillance.

L.7 CTS SR 4.8.1.1.2.b.1 requires removing accumulated water from the l EDG day tanks every 31 days, as well as "after each occasion when the diesel is operated for greater than 1 hour." The additional ! frequency of "after operated for I hour" is deleted. The fuel oil storage tank is similarly maintained free of accumulated water, therefore no water would be expected to be transferred as a result of a 1 hour EDG run. As such, condensation is the expected method of water accumulation within the fuel oil day tank, which is a time dependent process, not a process dependent on the transfer of fuel oil during EDG operation. Therefore, retaining the monthly removal and elimination of this extra frequency does not result in any impact on safety. FERMI UNIT 2 12 REVISIONkl. 07/14/99l 6

Ar, Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.3 --

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

1. loadings may include gradual l loading as recomended by the manufacturer, y,g g,, , 7 llo j Momentary transients _ d: 1 the load j;m. ngs.do not invalidate this test. '

q ) g

3. This Surveillance shall be conducted 1

                                                                                                        -y on only one          at a time.

1 cr

                  ".      Iin . 3R asiall ' p ww.vwv       v,  . . .

C

                        'innediatel          llow, witho      hutdown,                                        1 a succes          performan     of SR 3.8.1.                                        '
                         ~ SD ?...!.7 O9.\

Verify eac is synchronized and loaded fu ayww;fi;d in- I and operates for 2 60 minutes at a load Ta' - 3.0.; ' I 2 kW ad+ff006Hdh - - - - ,, ,,

g/ gyy SR 3.8.1.4 Verify each day tank { : ......._ tL 31 days (V.1f l.I.2. A.I)

                 -1:xati contaig 2                  gal of fuel oil.

([co 3.7././,b) SR 3.8.1.5 Check for and remove accumulated water from each day tank fa-d =;;- - dwet-tenh). $31kdays/4.1'1.12. b *l\

                                                                                          \            /

i SR 3.8.1.6 Verify uel oil transfer system days e operatestoRautomaticallyktransferfuel , Fl 11124.3 oil from storage tan gs(to the day tan 4 - y m- - = ,

                                                                                    .(continued)

D'JR/4-STS- 3.8-7 Rev-1704/07/95-- 0Gb

AC Sources-Operating 3.8.1 SURVEILLANCE RE0UIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1. ---- - - - - - - -NOT E--- ------- - '--- II, Th Surveil nee shall t be perfo d f i MODE 1, or 3. er, credit y be aken for nplanned av ts that s isfy

                 ,   this SR.

Verify eac 's automatic trips are g8 months

                                                    ;- -is ?:: ef bypassed on (c ^-- t
         ,g          n't_;; :*-M r t'e rgancy har                                g g,,,9
                     ;; .;.. . ; .t .;;;L an actual or simulated -Ecr+9                                M
                     =' it ;.. .... -:ignalgexcept:

a. Engine overspeed; ian4 .- )

b. Generatordifferentialcurrenk;

c. Low lube oil pressure;

d. -High-[rankcase re; and

e. .2tzetdilure (continued) l l

l l l i MMTS-' 3.8-12 -Rev-h-04/07/95-h Y_ - - - - . l

l 4 AC Sources-Operating 3.8.1

      . SURVEILLANCE REQUIREMENTS (continued)                                                            < CTS SURVEILLANCE                                             FREQUENCY SR 3.8.1Jg3         ------------------NOTES-------------------

1. Momentary transients outside the load Doc, L.Q

                                    ,-.---g           u m r range M o not                                   .

invalidate this test. 2 This urveill ce shall 6t be h per ormed in dit may DE 1 or taken f vents t t satisfy his SR.

                                                                         . Howeve ,

unplann 1 Verify each.DG eperati=g :t : p=:r f::ter h['18monthsK l

                   . ... WO_91- operates _f_or 2 24 hours-                                                                        1 (aji M the bal 1,2 nov es)                          2                                 4A I.I.24,I a .-    tor ^.791Fnoursloaded 2                        kW and 5               kW; an       --  -=                                                        -

WLt 2d 1

b. To ;u -" ni hours of the test I loaded 2 kW and s kW.

29 SR 3.8.1. ----------- ------- NOT E S------------------- I4

1. This Surveillance shall be performed I ithin 5 minutes of shutting down the 4F t l 2 C. 93 V) l G after the G has operated onded 2 kW and.: Qg;g ,g i P.\ u esm s.x .:.

Momentary transients outstP ;f load St M i'ed i d I limi do not invalidate this be. ) l

2. All G starts may be preceded y n gg g,g g' j engine prelube period.

(9.2.s.l.2.o 4 *) y each starts and achieves JPJB monthsK, 5 seconds, voltage 2 (3740}< V and ,*7,e,g nd frequency 2 JJ8.8) Hz and I M84$ volh p 1 3MpVAndfr p y (continued) 1Sz.s Hz. ; ud , [,\ 4

b. Ady skA g 1

SWR /4-STS 3.8-13 Rev-Ir-04/07/95-Wb

                                                                                                                #ev7

1 AC Seurces-Operating B 3.8.1 e BASES

SURVEILLANCE 5R 3. 8/1 ?i2 (continue . REQUIREMENTS

per'4ruance of this / rveillance could otentially catise

l

                               ;urbations to        e electrical distr ution systesp/that                       '
                .            uld challenge        ntinued steady s         e operation 36d, as a result, p nt safety systems              credit may y taken for

__ unplanned ev ts that satisfy t, a KD SR 3.8.1. * *^^ C Y # " 9 oSC fewe & L This Surveillance demonstrates that DG non-critical protective & gg gD functions (e.g..JighJacketwatertemperature)trebypassed I,. g on aikicca iniu J :-it signal and critical protective functions (engine overspeed, generator differential current, l IEliBlow lubricating oil pressure) trip the DG to avert

c r"g g,55g, .uvstantial damage to the DE unit. The non-critical trips are bypassed during DBAs and provide an alars on an abnormal i Anh*MM engine condition. Thic alars provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG. l Theigl8 mont Q Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at thet,38 monthKFrequency. Therefore, the Frequency was cone'uded to be acceptable from a reliability standpoint. f The SR modified by a Notif. The reason ortheNoteist/t i

                      ' perfo         ng the Surve111ancs would remove            required DG fron(

serv e. Credit may be t'aken for unp1 ed events that sat fy this SR. viewer's Note: T above MODE re rictions may be eleted 4 f'3 f it can be demonstrated to the s aff, on a plant s ecific basis, that perf ing the SR wi the reactor in ~ . y of the restricted MOD applicable: can satisfy th following criter , as l

a. perfo nce of the SR w 1 not render any afety syst

_ or c onent inoperab - (continued) CWR/4-STS-- B 3.8-26 Rev--l r-04/07/95- _. Revfl

INSERT THIS PAGE IN FRONT OF VOLUME 11 C : Volume 11' : CTS MARKUP COMPILATIONr '

o Remove Replace 3/4 4 24 (3.6.1.3 CTS M/U) pg 9 of 9 Rev Sa 3/4 4-24 (3.6.1.3 CTS hW) pg 9 of 9 Rev i1 3/4 4-26 (3.4.8 CTS M/U) pg 1 of 2 3/4 4 26 (3.4.8 CTS AW) pg 1 of 2 Rev i1 3/45-2(3.5.1 CTS M/U)pg 4 of 10 3/4 5-2 (3.5.1 CTS M/U) pg 4 of 10 Rev i1 3/4 5-8 (3.6.2.2 CTS M/U)pg i of 5 3/4 5-8 (3.6.2.2 CTS M/U) pg 1 of 5 Rev i1 3/4 6-3 (3.6.1.3 CTS M/U) pg 5 of 9 Rev Sa 3/4 6-3 (3.6.1.3 CTS M/U) pg 5 of 9 Rev i1 3/4 6-14 (3.6.1.3 CTS M/U) pg 6 of 9 Rev Sa 3/4 6-14 (3.6.1.3 CTS M/U) pg 6 of 9 Rev i1 3/4 6-17 (3.6.1.1 CTS M/U) pg 8 of 8 3/4 6-17 (3.6.1.1 CTS M/U) pg 8 of 8 Rev i1 i '

3/4 6-17 (3.6.2.1 CTS M/U) pg 3 of 3 Rev 5 3/4 6-17 (3.6.2.1 CTS M/U) pg 3 of 3 Rev i1

 .-                                                3/4 618 (3.6.2.4 CTS M/U) pg I of 1 Rev i1    ,

3/4 6-19 (3.6.2.3 CTS M/U) pg 1 of 1 3/4 6-19 (3.6.2.3 CTS M/U) pg 1 of 1 Rev i1 3/4 6-21 (3.6.1.3 CTS hW) pg 8 of 9 Rev Sa 3/4 6-21 (3.6.1.3 CTS M/U) pg 8 of 9 Rev 11 3/4 6-50 (3.6.1.7 CTS M/U) pg 1 of I Rev 5 3/4 6-50 (3.6.1.7 CTS M/U) pg 1 of 1 Rev i1 3/4 6-52 (3.6.4.2 CTS M/U) pg 2 of 3 Rev 5 3/4 6-52 (3.6.4.2 CTS M/U) pg 2 of 3 Rev i1 3/4 8-15a (3.5.2 CTS hW) pg 8 of 8 Rev 7 3/4 815a (3.5.2 CTS M/U) pg 8 of 8 Rev i1 i i Rev 11 07/14/99 b

                                                                                                                             > G 2.I 5 f ecificxbort-ft. S* , lei
            ~

h o ge,g, Q fCh.h' C A tso see p ec.i 6 celion M 2.4

     ']                                                                                                                                      l CONTA letFNT TYETDtS SURVE LLANCE REQUIREMDffS (Conti==di

1. At least once per 5 minutes during testing whicn aeds neat to GR,'5.(,,*2,,l.I the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105T, p 2. At least once per hour when suppression chamber average water temperature is greater than or equal to 95T. by verifying:

Q3 ri,, Suppression chamber average water temperature to be less A.\ a) _ thra ar --"=1 to 11D*F. and THEMAL POWER to be less than or equal to is of RATED

THEMAL POWER after suppression chamber average water b.3 temperature has exceeded 95T for more than 24 hours. At least_ once per 30 minutes in OpfaATIONAL CnunlT10N 3 followine a pirega c. ser un suppression chamber average water temperature greater L g' l D .'2 or equal to 957, by verifying suppression chamber averagej ater temperature less than or eoual to 120*F. -

d. j By an external visual examination of the suppression chamber after safety / relief valve operation with the suppression chamber average I water temperature greater than or equal to 160*F and reactor coolant $ e.!.

4 lc( 00 system pressure greater than 200 psig.

           @              e.          At least once per 18 months by a visual inspection of the accessible g e c$y,,                    , interior and exterior of the suppression chamber.

I

   .s
      \                   f.          By veri ing eight ins         ntation ression pool ater temperature annels OPERAB      y performan     of a:         ]           iM l        gr)

CHANNE ECK at less ce per 24 h . Lo-

       'l
                                          . C        FUNCTIONAL       T at least     e per 31 e      and
                                                                                                     . with the )j i

3. EL CAllBRA at least e per IB k water high temperature alam <=+na4nt fer < 1057. /

g. y verifying both narrow range suppression chamber water level instrumentation channels OPERABLE by performance of a:

1. CHANNEL CHECK at least once per 24 hours, g ge., CHANNEL FUNCTIONAL TEST at least once per 31 days, and een f 2. 3. CHANNEL CAllBRATION at least once per 18 months, NechC"k.

3.6.22, / With the water level alarm setpoint for:

1. High water levei 114'8' Low water level 1 14'4' (TWMS Marrow Range)

(2. ,

h. [At least once per 18 months by pr. ducting a drywell-to suppression :

chamber bypass leak test at an initial differential pressure of

1 psi and verifying that the differential pressure does not decrease by more than 0.20 inch of water per minute for a period of 5e0 g, o)kn 10 minutes. If any derwell to suppression chamber bypass 1.at test fails to meet the specified limit, the test schedule for subsequent CC tests shall be reviewed and approved by the Commission. If two consecutive tests fail to meet the specified limit, a test shall be h p ,\ Derformed at least every 9 months until two consecutive tests meet N the specificd limit, at which time the 18 month test schedule may be I

resumed. FERMI UNIT 2 3/4 6 17 Rev11 i PAGE 3 0F 03 &v f E

I 96(,(FiCAllot\j 8.6.78 i CGfTAlletENT SYSTEMS SUPPRESE10N POOL L SP {f ' LIMITING rnunITION FOR-0PERATION ~ uo 3.c a4 suppression pool @4vwellMraBoode ) 4.2.i~The of the residual heat ,

removal (RHR) system shall be OPERABLE with tysnae eng loops,feacn op 6umming o .

a. One OPERABLE RHR ump, and An OPERABLE f path capable of re irculating water on the I b

suppression amber through an RH heat exchanger a the uppression col and drywell sor snareers. / O*/

                                                                                                                      .t APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

E.T.10H:

                   -et    With one supprpssion pool [and/v, eval' ;;r;d loop inoperable.

restore the inoperable loojFto OPERABLE statu thin 7 days or be [CD6N h in at least HOT SHUTDOWN within the next 12 hour nd in COLD SHUTDOWN within the following 24 hours. g,l

                   -tr. With both suppression pool        evi m-- il y --31 oops inoperable, restore at least one loop t UPERKILE status within 8 hours or be MTOM d            in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN

within the following 24 hours.

p pg g SURVEfttANCE REQUIREMENTS the RHR system shall 4.6.2.2 The suppression pool findJrywell mod be demonstrated OPERABLE: g,j l

a. At least once per 31 days by verifying that each valve (manual, 5 R 3,(,,'2,I/, l power operated, or automatic) in the flow path that is not locked, nJ '---

KIlQtgi 4es Mein L) With onero. vs 3 >-- 4eoof h l g. g more the see r system automatic i_ solation dampers 2----- =:y containeen ventilat U

.:.:.: _ noperable,> maintain at seast one2 Gsolation damper urtRABLE in eacn attectea penetration that is oceofand within 8 hours either:

j g g ,y g x 2. b.

                                        "-" - t ': 5:;;..P.: in;;r':,' t: ^^:" " " ' :t:t;;, :M                                    .

Isolate each affected penetration by use of at least one deactivated g vQ :d M ien damper secured in the isolation position, or A.i c. Isolate each affected penetration by use of at least one closed manual valve or blank flange. Otherwise, in OPERATIONAL CONDITION 1, 2, or 3, be in at least HOT

  ^~N           Acxu (          SHUTDOWN          within the next 12 hours and in COLD SHUTDOWN within the
         }                      following 24 hours.

Ac11o,J D Otherwise, in Operational Condition *, suspend handling of irradiated fuel in the secondary containment CORE ALTERATIONS and operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable. SURVEllt ANCE REOUTREMENTS _ __ 4.6.5.2 Each second damper E., . ,~ , . ....ary contai n t ventilation system automatic isolation ;

                                                   ., . ; . ; . .- ; all be demonstrated OPERABLE:

Prior k. ' returning or r acement work th idamoer performedto service afterr or on the da maintenance, its associ .dre ir,] act le sttor, onecontrol complete or power yele ofcircuit ny cyc ng the damper thr gh at 1 ru11 travel intinn 94== - dverifyinoth.==cified) b. g 3 (,,,/.1 3 G ,.. w r r . __^ = f at least once per 18 months by ~ _ _ verifying that on a containment isolation damper actuates to its isolation position. t signal each is lation { j

c. c4ud ersimulaW 5 M M .2. L By verifying the isolation time to be within its limit when t sted i pursuant to Specification 4.0.5.

                      *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for craining the reactor vessel.

FERMI - UNIT 2 3/4 6 52 h PAGE cd 0F 03 b5I E

                                                                      $fc' Clftcq f /c p. S. 5. 2 CAlso see .cpec,Acaston. g. g. e)

FLECTRICAL POWER SYSTEMS SURVEf ttANCE PE0UIREMENTS

At least the above requirELpowardistribution system divistonhand ' QOC'2'4.8.3.2. s

the swing bui shTTT os outermined energtzed at least once per 7 days by - verifying correct breaker alignment and voltage on the busses / cabinets. l { f4.8.3. 2 The A.C. power istributton system swi g bus automatiq, throw i sch shall be canonstr ted OPERABLE at least ce per 31 days by man 11y * [, I ope pg postiton 3C bu 72C and vertfying that he automatic transfe scheme h I l l 1 FERM1 - UNIT 2 3/4 8-15a %wg3 1

                                                                                          /b V ll     l PAGE       F       0F       08                -

L l

i INSERT THIS PAGE IN FRONT OF VOLUME 12 Vol6me 12: . IMPROVED TECHNICAL SPECIFICATIONS A Remove Replace 3.5.1 ITS pg 3.5-4 Rev 7 3.5.1 ITS pg 3.54 Rev i1 3.6.1.1 ITS pg 3.6-2 Rev 0 3.6.1.1 ITS pg 3.6-2 Rev 11 3.6.1.3 ITS pg 3.6-11 Rev Sa 3.6.1.3 ITS pg 3.6-11 Rev i1 3.6.1.3 ITS pg 3.6-12 Rev Sa 3.6.1.3 ITS pg 3.6-12 Rev i1 3.6.1.3 ITS pg 3.6-15 Rev Sa 3.6.1.3 ITS pg 3.6-15 Rev 1I 3.6.1.4 ITS pg 3.6-14 Rev 0 3.6.1.4 ITS pg 3.6-14 Rev i1 3.6.1.7 ITS pg 3.6-18 Rev 5 3.6.1.7 ITS pg 3.6-18 Rev 11 3.6.1.7 ITS pg 3.6-19 Rev 5 3.6.1.7 ITS pg 3.6-19 Rev i1 3.6.1.7 ITS pg 3.6-19a Rev 11 , 3.6.2.3 ITS pg 3.6-28 Rev 5 3.6.2.3 ITS pg 3.6-28 Rev 11 3.6.2.4 ITS pg 3.6-29i Rev i1 3.6.2.4 ITS pg 3.6-29ii Rev i1 3.6.4.3 ITS pg 3.6-41 Rev 5 3.6.4.3 ITS pg 3.6-41 Rev 11 3.8.1 ITS pg 3.8-3 Rev 7 3.8.1 ITS pg 3.8-3 Rev 11 3.8.1 ITS pg 3.8-5 Rev 0 3.8.1 ITS rg 3.8-5 Rev i1 3.8.1 ITS pg 3.8-6 Rev 7 3.8.1 ITS pg 3.8-6 Rev i1 3.8.1 ITS pg 3.8-7 Rev 0 3.8.1 ITS pg 3.8-7 Rev i1 l I i I

I Rev 11 07/14/99 . 1

b. I

CCS -Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify correct voltage and breaker 7 days alignment to the LPCI swing bus.

SR 3.5.1.2 - - NOTE - - When LPCI is placed in an inoperable status s solely for performance of this SR or when Q the LPCI swing bus automatic throwover scheme is inoperable due to EDG 12 being paralleled to the bus for required testing.

 >3h                   entry into associated Conditions and                                  .

Required Actions may be delayed up to 12 h'l N hours for completion of the required testing. Perform a functional test of the LPCI swing 31 days bus automatic throwover scheme. SR 3.5.1.3 Verify, for each ECCS injection / spray 31 days subsystem, the piping is filled with water from the pump discharge valve to the injection valve. 1 (continued) ) l

    ! FERMI    UNIT 2                                   3.5 4      Revisiron 11     07/14/99 L

Primary Containment 3.6.1.1

 )       SURVEILLANCE REQUIREENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.1.2 Verify drywell to suppression chamber 18 months differential pressure does not decrease at a rate > 0.2 inch water gauge per ANQ minute tested over a 10 minute period at an initial differential pressure of - - NOTE- -- 1 psid. Only required after two consecutive tests fail and continues until two consecutive tests pass 9 months SR 3.6.1.1.3 --- -

                                               - NOTE-            --- -- ---

Only required to be performed after

   >i                    safety / relief valve operation with the suppression chamber average water M                     temperature = 160*F and reactor coolant M                     system pressure > 200 psig, u                     .........................................

M Q Perform an external visual examination of Once prior to

   %                     the suppression chamber.                               entry into MODE 2 or 3 from MODE 4 I

J .. j FERMI UNIT 2 3.6 2 Revision 11. 07/14/99 w ._

PCIVs 3.6.1.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 4

  '41 4            D. One or more secondary   D.1   Restore leakage rates   4 hours for d                 containment bypass            to within limit.        leakage on b                  leakage rate. MSIV                                    hydrostatically
         ,          leakage rate, purge                                   tested line

[ valve leakage rate, without a closed hydrostatically tested system

   $ll              line leakage rate, or EFCV leakage rate not                                 M kl within limit.

4 hours for secondary containment bypass leakage . I E 7 8 hours for MSIV learage bl E 24 hours for i purge valve leakage N M 72 hours for

           '                                                                leakage on so      ,

hydrostatically

       -                                                                    tested line on a            i E,                                                                     closed system               i and EFCV leakage r                                                                             -

gj E. Required Action and associated Completion E.1 Be in MODE 3. 12 hours 3 Time of Condition A. E B. C or D not met in

 %g                  MODE 1. 2. or 3.        E.2   Be in MODE 4.             36 hours (continued) l FERMI - UNIT 2                     3.6 11              Revi si,o,n,11.      07/14/99 L

c PCIVs 3.6.1.3

ACTIONS - (continued) CONDITION REQUIRED ACTION COMPLETION TIME Required Action and F.1 Initiate action to Immediately

  ^l     F.

associated Completion isolate Rm Shutdown

  @          Time of Condition A.                           Cooling System.

l B. C. or D not met for RHR-SDC PCIV(s) QB required to be yl OPERABLE during MODE 4 F.2 Initiate action to Immediately or 5. restore valve (s) to OPERABLE status. 1 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 -- - - ---

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

Not required to be met when the isolation i valves for one purge or containment pressure control supply line and one i purge or containment pressure control ! exhaust line are open for inerting, de-inerting pressure control. ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open. m Verify each drywell and suppression 31 days . bV chamber purge system and containment - pressure control isolation valve is closed. LQ) . (continued) l FERMI UNIT 2 3.6 12 Revision 11. 07/14/99 i

PCIVs 3.6.1.3

SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.1.3.10 Remove and test the explosive squib from 18 months on a each shear isolation valve of the TIP STAGGERED TEST System. BASIS T~ j SR 3.6.1.3.11 Verify the combined leakage' rate for all secondary containment bypass leakage In accordance with the paths that are not provided with a seal Primary Q system is s 0.04 L, when pressurized to Containment ..

                           = 56.5 psig.                                      Leakage Rate Testing Program         1 and Inservice nl                                                                      Testing Program d

SR 3.6.1.3.12 Verify combined MSIV leakage rate for all In accordance D four main steam lines is s 100 scfh when with the tested at = 25 psig. Primary Containment ' Leakage Rate Testing Program SR 3.6.1.3.13 - - - - NOTE - - - -- Only required to be met in MODES 1, 2 and 3. gi Verify combined leakage rate through In accordance hydrostatically tested lines that with the ' 3 9e! penetrate the primary containment is within limits. Primary Containment Leakage Rate Testing Program l FERMI UNIT 2 3.6 15 Revision 11. 07/14/99 l'

Primary Containment Pressure 3.6.1.4

 )    3.6 CONTAINMENT SYSTEMS 3.6.1.4 Primary Containment Pressure LCO 3.6.1.4       Primary containment pressure shall be = 0.10 psig and l                     5 +2.0 psig.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 Restore primary 1 hour pressure not within containment pressure I limit. to within limit. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. 6NQ . 1 B.2 Be in MODE 4. 36 hours i l SURVEILLANCE REQUIREMENTS SURVEILLANCE ' FREQUENCY SR 3.6.1.4.1 Verify primary containment pressure is 12 hours within limit. J .- l FERMI - UNIT 2 3.6 14 Revision 11 07/14/99 k

Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7 i 3.6 CONTAINHENT SYSTEMS 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers l LCO 3.6.1.7 Each reactor building to suppression chamber vacuum breaker shall be OPERABLE. M I APPLICABILITY: MODES 1, 2, and 3. ACTIONS

              ..................................... NOTE---

Separate Condition entry is allowed for each line. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more lines with A.1 Close the open vacuum 72 hours one reactor building- breaker. 3 t0 suppression chamber vacuum breaker not closed. k B. One or more lines with B.1 Close one open vacuum 2 hours y two reactor building- breaker, q to suppression chamber vacuum breakers not v closed. h C. One line with one or more reactor building-to-suppression chamber C.1 Restore the vacuum breaker (s) to OPERABLE status. 72 hours

           !        vacuum breakers f            inoperable for m             opening.

W 4 y (continued) l l FERMI UNIT 2 3.6 18 Revision 11 07/14/99 b

Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7

                                                                                                                ~
 ]          ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two lines with one or D.1 Restore all vacuum I hour O more reactor building- breakers in one line

     %           to suppression chamber                         to OPERAELE status.

b vacuum breakers inoperable for opening. 1 l E. Required Action and E.1 Be in MODE 3. 12 hours ' Associated Completion Time not met. 851 d l E.2 Be in MODE 4. 36 hours J

   %        SURVEILLANCE REQUIREMENTS SURVEILLANCE                                         FREQUENCY SR 3.6.1.7.1        . -....--- --- - NOTES                  - - - --    -

1. Not required to be met for vacuum breakers that are open during Surveillances.

2. Not required to be met for vacuum breakers open when performing their -

intended function. , Verify each vacuum breaker is closed. 14 days SR 3.6.1.7.2 Perform a functional test of each vacuum 31 days breaker. (continued) s .- l FERMI UNIT 2 3.6 19 Revision 11 07/14/99 L

Reactor Building to Suppression Chamber Vacuum Breakers-3.6.1.7

i SURVEILLANCE REQUIREENTS (continued) SLRVEILLANCE FREQUENCY SR 3.6.1.7.3 Verify the opening setpoint of each 18 months

                      , vacuum breaker is s 0.5 psid.

4 i

l' FERMI UNIT 2 3.6 19a Revision 11 07/14/99 u

RR Suppression Pool I l .3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal-(RM) Suppression Pool Cooling LCD 3.6.2.3' Two Rm suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression A.1 Restore Rm 7 days pool cooling subsystem suppression pool inoperable, cooling subsystem to OPERABLE status. 1 B. Two RHR suppression B.1 Restore one Rm 8 hours pool cooling suppression pool subsystems inoperable, cooling subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion hl Time not met. 8NQ C.2 Be in MODE 4. 36 hours i I 1 l l

       ] FERMI     UNIT 2                       3.6 28              Revision 11. 07/14/99 k.

Rm Suppression Pool Spray 3.6.2.4 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Two R R suppression pool spray subsystems shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression A.1 Restore RE 7 days pool spray subsystem suppression pool inoperable. spray subsystem to OPERABLE status. l B. Two RHR suppression B.1 Restore one RHR 8 hours pool spray subsystems suppression pool inoperable. spray subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. 6NQ C.2 Be in MODE 4. 36. hours l l FERMI - UNIT 2 3.6 291 Revision 11. 07/14/99 b

I i RHR Suppression Pool Spray 3.6.2.4 l l ~ l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l l SR 3.6.2.4.1 Verify each RHR suppression pool spray 31 days ' subsystem manual, power operated, and i automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position. SR 3.6.2.4.2 Verify each RHR pum) develops a flow rate In accordance -

                         = 500 gpm through tw heat exchanger and     with the                ,

suppression pool spray sparger while Inservice I operating in the suppression pool spray Testing Program l mode. I I l FERMI UNIT 2 3.6 29ii Revision 11. 07/14/99 a

SGT System 3.6.4.3

    )      ACTIONS CONDITION                 REQUIRED ACTION            COMPLETION TIME C.  (continued)            C.2.1     Suspend movement of     Immediately irradiated fuel assemblies in secondary containment.

M C.2.2 Suspend CORE Immediately ALTERATIONS. M C.2.3 Initiate action to Immediately suspend OPDRVs. I D. Two SGT subsystems D.1 Enter LC0 3.0.3. Immediately inoperable in MODE 1.

2. or 3.

E. Two SGT subsystems - -

                                                   -- NOTE - - -   ---

inoperable during LC0 3.0.3 is not applicable. Q movement of irradiated fuel assemblies in the secondary E.1 Suspend movement of Immediately

      %@        containment, during            irradiated fuel CORE ALTERATIONS. or           assemblies in                  ,

during OPDRVs. secondary containment. -- M (continued) 1

        ! FERMI - UNIT 2                       3.6 41                 Revision 11. 07/14/99 L                                                                                                   i

r-AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and 7 days indicated power availability for each offsite circuit. l 1 SR 3.8.1.2 --- - -

                                                      -.---- NOTES.                      . ----          -     -- -

l l l 1. All EDG starts may be preceded by an n engine'prelube period and followed by S a warmup period prior to loading.

2. A modified DG start involving id'11ng and gradual acceleration to -

synchronous speed may be used for this SR as recommended by the manufacturer. Verify each EDG starts and achieves steady 31 days state voltage = 3740 V and s 4580 V and frequency = 58.8 Hz and s 61.2 Hz. SR 3.8.1.3 NOTES -- -- - - - -

1. EDG loadings may include gradual loading as recommended by the unufacturer.

l - 2. Momentary transicnts below the load l T limit do not invalidate this test. l l l l g. 3. This Surveillance shall be conducted on only one EDG at a time. Verify each EDG is synchronized and loaded 31 days l and operates for = 60 minutes at a load

                               = 2500 kW.

(continued) 1 1 l l l FERMI UNIT 2 383 Revision,11 07/14/99 i l I ,

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.9 Ve.'ify each EDG does not trip and voltage 18 months is maintained s 4784 V during and following a load rejection of a 2850 kW. SR 3.8.1.10 -- - - NOTE- - ---- - - All EDG starts may be preceded by an engine prelube period. Verify on simulated loss of offsite power 18 months signal: .

a. De energization of emergency buses:

b. Load shedding from emergency buses:

and

c. EDG auto starts and:

1. energizes permanently connected loads in s 10 seconds.

2. energizes auto connected shutdown ;

loads through load sequencer. l

3. maintains steady state voltage

                                     = 3740 V and 5 4580 V.

4 maintains steady state frequency a 58.8 Hz and s 61.2 Hz. and

5. supplies permanently connected and auto connected shutdown loads for a 5 minutes. ,

(continued)

 ! h j FERMI    UNIT 2                             3.85               Revision 11. 07/14/99 k

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.11 --- - - ---- NOTE - - -- --- - All EDG starts may be preceded by an engine prelube period. Verify on an actual or simulated Emergency 18 months , Core Cooling System (ECCS) initiation i signal each EDG auto starts and:

a. In s 10 seconds after auto start and during tests, achieves voltage j = 3740 V and frequency = 58.8 Hz: .

3 b. Achieves steady state frequency

                              = 58.8 Hz and s 61.2 Hz. and voltage 3

b = 3740 V and s 4580 V: and El c. Operates for = 5 minutes. SR 3.8.1.12 Verify each EDG's automatic trips are 18 months o bypassed on an actual or simulated emergency start signal except: (( E- a. Engine overspeed:

b. Generator differential current:

c. Low lube oil pressure:

d. Crankcase overpressure: and

e. Failure to start. .

(continued) i i I j FERMI UNIT 2 3.86 Revision-11. 07/14/99 i i

                 "                                      eme e+*

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREENTS (continued) SURVEILLANCE FREQUENCY I SR 3.8.1.13 --- - NOTE - - - - - - - Momentary transients outside the load range do not invalidate this test. Verify each EDG operates for = 24 hours: 18 months I

a. For all but the final = 2 hours. loaded

                              = 2500 kW and 5 2600 kW: and

b. For the final = 2 hours of the test loaded = 2800 kW and s 2900 kW.

SR 3.8.1.14 ---- - NOTES - - - - -

1. This Surveillance shall be performed within 5 minutes of shutting down the EDG after the EDG has operated

                              = 2 hours loaded = 2500 kW or until operating temperatures have y                            stabilized.

f Momentary transierts below the load

 -                            limit do not invalidate this test.
 &                    2.      All EDG starts may be preceded by an engine prelube period.

Verify each EDG starts and achieves: 18 months

a. In s 10 seconds. voltage = 3740 V and frequency = 58.8 Hz: and

b. Steady state voltage = 3740 V and

5 4580 V and frequency = 58.8 Hz and s'61.2 Hz.

l (continued) l l FERMI - UNIT 2 - 3.,8 7 Revision 11. 07/14/99 k

INSER'I THIS PAGE IN FRONT OF VOLUME 13

              ' Volume 13:- IMPROVED TECHNICAL SPECIFICATIONS BASES' Remove                                         Replace           I B 3.6.1.1 ITS pg B 3.6.1.1-5 Rev 0             B 3.6.1.1 ITS pg B 3.6.1.1-5 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev Sa            B 3.6.1.3 ITS pg B 3.6.1.3-4 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-5 Rev Sa            B 3.6.1.3 TPS pg B 3.6.1.3-5 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev Sa            B 3.6.1.3 ITS pg B 3.6.1.3-6 Rev i1 D 3.6.1.3 ITS pg B 3.6.1.3-7 Rev Sa            B 3.6.1.3 ITS pg B 3.6.1.3-7 Res !I B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev Sa            B 3.6.1.3 ITS pg B 3.6.1.3-8 Rev i1 B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev Sa            B 3.6.1.3 ITS pg B 3.6.1.3-9 Rev i1       I B 3.6.1.3 ITS pg B 3.6.1.3 16 Rev Sa           B 3.6.1.3 ITS pg B 3.6.1.3-16 Rev i1 B 3.6.1.7 ITS pg B 3.6.1.7-3 Rev 5             B 3.6.1.7 ITS pg B 3.6.1.7-3 Rev 11 B 3.6.1.7 ITS pg B 3.6.1.7-5 Rev 5             B 3.6.1.7 ITS pg B 3.6.1.7-5 Rev i1       l B 3.6.1.7 ITS pg B 3.6.1.7-6 Rev 5             B 3.6.1.7 ITS pg B 3.6.1.7-6 Rev i1 B 3.6.1.8 ITS pg B 3.6.1.8-2 Rev 0             B 3.6.1.8 ITS pg B 3.6.1.8-2 Rev 11 B 3.6.1.8 ITS pg B 3.6.1.8-3 Rev 0             B 3.6.1.8 ITS pg B 3.6.1.8-3 Rev 11 l

D 3.6.2.3 ITS pg B 3.6.2.3-3 Rev 5 B 3.6.2.3 ITS pg B 3.6.2.3-3 Rev i1 l

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B 3.8.1 ITS pg B 3.8.1-17 Rev 7 B 3.8.1 ITS pg B 3.8.1-17 Rev !! B 3.8.1 ITS pg B 3.8.1-18 Rev 7 B 3.8.1 ITS pg B 3.8.1-18 Rev i1 ! Rev 11 07/14/99 L

Primary Containment B 3.6.1.1 BASES SURVEILLANCE REQUIREENTS (continued) are identified by other primary containment SRs. Two consecutive test failures, however, would indicate. unexpected degradation: in this event, as the Note indicates, increasing the Frequency to once every 9 months is required until the situation is remedied as evidenced by passing two consecutive tests. SR 3 . 6 .1.1. 3'

    %                     The primary containment suppression chamber can experience 4                     significant hydrodynamic loading during safety / relief valve     -

g (SRV) operation with the suppression pool average water

     -                    temperature = 160'F and reactor coolant system pressure 9                     > 200 psig. After SRV operation during these conditions, a M                     visual examination of the exterior surface of the
    &                     suppression chamber will identify any abnormal conditions M                     that may warrant further inspection and review for continued OPERABILITY. This examination is performed prior to resuming operation in MODES where primary containment is required to be OPERABLE.

REFERENCES 1. UFSAR, Section 6.2.

2. UFSAR. Section 15.6.5.

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

4 l FERMI UNIT 2 B 3.6.1.1 - 5 Revision 11. 07/14/99 p i

PCIVs B 3.6.1.3 BASES LC0 (continued) The normally closed manual PCIVs are considered OPERABLE when the valves are closed and blind flanges are in place, D or open under administrative controls. Normally closed T automatic PCIVs, are required to have isolation times within

        %                    limits and actuate on an automatic isolation signal. These Q                      passive isolation valves and devices are those listed in Reference 2.

Purge valves with resilient seals, secondary containment bypass valves, HSIVs, EFCVs, and hydrostatically tested valves must meet leakape rate requirements in addition to the other PCIV leakage rates which are addressed by LCO 3.6.1.1, " Primary Containment," as Type B or C testing. Tnis LC0 provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents. APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In H0 DES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, most PCIVs are not required to be OPERABLE in H0 DES 4 and 5. Certain valves, however, are required to be OPERABLE to prevent inadvertent reactor vessel draindown. These valves are those whose associated instrumentation is required to be OPERABLE per LC0 3.3.6.1

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

r ACTIONS The ACTIONS are modified by a Note allowing penetration flow path (s) to be unisolated intermittently under administrative dl l' controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous O@c L communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated. Due to the size of the primary containment purge line penetration and the fact that those penetrations exhaust directly from the containment atmosphere to the environment, the penetration flow path _./ . . . l FERMI UNIT 2 B 3.6.1.3 - 4 Revision 11 07/14/99 L:

PCIVs B 3.6.1.3

 )         BASES ACTIONS (continued) containing these valves is not allowed to be opened under administrative controls.

A second Note has been added to provide clarification that, for the purpose of this LCO. separate Condition entry is allowed for each penetration flow Jath. This is acceptable, since the Required Actions for eac1 Condition provide appropriate compensatory actions for each inoperable PCIV. Complying with the Required Actions may allow for continued { operation. and subsequent inoperable PCIVs are governed by I subsequent Condition entry and application of associated - Required Actions. The ACTIONS are modified by Notes 3 and 4. Note 3 ensures that appropriate remedial actions are taken, if necessary. if the affected system (s) are rendered inoperable by an inoperable PCIV (e.g., an Emergency Core Cooling System subsystem is inoperable due to a failed open test return valve) . Note 4 ensures appropriate remedial actions are tabia when the primary containment leakage limits are exceeded. Pursuant to LCO 3.0.6. these actions are not required even when the associated LCO is not met. Therefore. Notes 3 and 4 are added to require the proper actions be taken. , A.1 and A.2 ' With one or more penetration flow paths with one PCIV inoperable except for leakage (i.e.. secondary containment , bypass leakage rate. MSIV leakage rate. purge valve leakage i rate hydrostatically tested line leakage rate, and EFCV leakage rate) not within limit. the affected penetration flow paths must be isolated. The method of isolation must include the use of at least one isolation barrier that A cannot be adversely affected by a single active failure. d Isolation barriers that meet this criterion are a closed and D de activated automatic valve. a closed manual valve. a blind flange, and a check valve with flow through the valve secured. For a penetration isolated in accordance with Required Action A.1. the device used to isolate the

     \                       penetration should be the closest available valve to the primary containment. The Required Action must be completed 1

within the 4 hour Completion Time (8 hours for main steam

         $                   lines). The Completion Time of 4 hours is reasonable considering the time required to isolate the penetration and the relative importance of supporting primary containment
 .)                                                                             .-

i k l FERMI UNIT 2 B 3.6.1.3 - 5 Revision 11. 07/14/99 k

l PCIVs B 3.6.1.3

   ]           BASES-ACTIONS (continued)-     1. .

OPERABILITY during MODES 1, 2, and 3. For main steam lines, an 8 hour Completion Time is allowed. The Completion Time of 8 hours for the main steam lines allows a period of time to restore the MSIVs to OPERABLE status given the fact that MSIV closure will result in isolation of the main steam fl line(s) and a potential for plant shutdown. s For affected' penetrations that have been isolated in accordance with Required Action A.1, the affected penetration flow path (s) must be verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following - an accident, and no longer capable of being automatically isolated will be in the isolation position should an event occur.- This Required Action does not require any testing or device manipulation. Rather, it involves verification that those devices outside containment and capable of potentially being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside primary containment" is appropriate because the devices are operated under administrative controls and the probability of their misalignment is low. For the devices inside primary containment, the time period specified " prior

                                . to entering MODE 2 or 3 from MODE 4. if primary containment was de inerted while in MODE 4. if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the devices and other administrative controls ensuring that device misalignment is an unlikely possibility.

j Condition A is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two PCIVs. For penetration flow paths with one PCIV. Condition C provides the appropriate Required Actionst. el Required Action A.2 is modified by two Notes. Note 1 d applies to isolation devices located in high radiation b areas. and allows them to be verified by use of s administrative means. Allowing verification by Ei administrative means is considered acceptable, since access t to these areas is typically restricted. Note 2 applies to

      \                           isolation devices that are locked, sealed, or otherwise

( secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable since the function of locking sealing, or

           !. FERMI   UNIT 2                      B 3.6.1.3 - 6          Revision 11     07/14/99 6

PCIVs B 3.6.1.3

-]

BASES' ACTIONS (continued) securing components is to ensure that these devices are not ; inadvertently repositioned. Therefore, the probability of ! misalignment of these devices, once they have been verified 4 to be in the proper position. is low. IL1 With one or more penetration flow paths with two PCIVs inoperable, except for leakage (i.e., secondary containment

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

leakage rate) not within limit, either the inoperable PCIVs -l ' must be restored to OPERABLE status or the affected penetration flow path must be isolated within 1 hour. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve, and a blind flange. The 1 hour Completion Time is consistent with the ACTIONS of LCO 3.6.1.1. Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two PCIVs. For penetration flow paths with one PCIV. Condition C provides the appropriate Required Actions. C.1 and C.2 d With one or more penetration flow paths with one PCIV b inoperable, except for leakage (i.e., secondary containment l bypass leakage rate. MSIV leakage rate. purge valve leakage rate. hydrostatically tested line leakage rate., and EFCV h leakage rate) not within limit, the inoperable valve pust be restored to OPERABLE status or the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be j adversely affected by a single active failure. Isolation V barriers-that meet this criterion are a closed and de activated automatic valve, a closed manual valve. and a

    >1
        \                       blind flange. A check valve may not be used to isolate the affected penetration. The Completion Time of 4 hours is i                         reasonable considering the time required to isolate the qft penetration and the relative importance of supporting primary containment OPERABILITY during MODES 1. 2. and 3.

The Completion Time of 72 hours for penetrations with a s . l FERMI UNIT 2 B 3.6.1.3 - 7 Revision 11 07/14/99 k

r , h PCIVs l-B 3.6.1.3 i

_] BASES ACTIONS (continued) closed system is reasonable considering the relative stability of the closed system (hence, reliability) to att _/ as a penetration isolation boundary and the relative importance of supporting primary containment OPERABILITY during MODES 1. 2. and 3. The closed system must meet ~the l requirements of Reference 4. The Completion Time of 72 hours for EFCVs is also reasonable considering the instrument'and the small pipe diameter of penetration (hence, reliability) to act as a penetration isolation boundary and the small pipe diameter of the affected penetrations. In the event the affected penetration flow i A path is isolated in accordance with Required Action C.l. the - d affected >enetration aust be verified to be isolated on a periodic ) asis. This is necessary to ensure that primary containment penetrations required to be isolated following an accident are isolated. The Completion Time of once per ! 31 days for verifying.each affected penetration is isolated is appropriate because the valves are operated under

     %                           administrative controls and the probability of their L.                                misalignment is low.

! Condition C is modified by a Note indicating that this l . Condition is only applicable to penetration flow paths with only one PCIV. For penetration flow paths with two PCIVs. Conditions A and B provide the appropriate Required Actions. ReWred Action C.2 is modified by two Notes. Note 1 applies to valves and blind flanges located in high . l radiation areas and allows them to be verified by use of I administrative means. Allowing verification by l administrative means is considered acceptable, since access ' to these areas is typically restricted. Therefore. the

                                  )cobability of misalignment of these valves, once they have            ;

l >aen verified to be in the pro >er position. is low. . Note 2 l l ap) lies to isolation devices t1at are locked, sealed.' or ot1erwise secured in position and allows these devices to be ! l verified closed by use of administrative means. Allowing

verification by administrative means is considered Y

acceptable since the function of locking. sealing. or l securing components is to ensure that these devices are not inadvertently repositioned. i [ FERMI UNIT 2 B 3.6.1.3 - 8 Revision 11. 07/14/99 m

PCIVs B 3.6.1.3 h BASES. _ ACTIONS (continued) l M p With one or more secondary containment bypass leakage rate (SR 3.6.1.3.11). MSIV leakage rate (SR'3.6.1.3.12). purge valve leakage rate (SR 3.6.1.3.6). hydrostatically tested line leakage rate (SR 3.6.1.3.13), or EFCV leakage rate (SR 3.6.1.3.9). not within limit, the assumptions of the safety analysis'may not be met. Therefore, the leakage must be restored to within limit. Restoration can be accomplished by isolating the penetration that caused the

                                  . limit to be exceeded by use of one closed and de activated automatic valve. closed manual valve. or blind flange. When         .

a penetration is isolated, the leakage rate for the isolated L penetration is assumed to be the actual pathway leakage o through the isolation device. If two isolation devices are g used to isolhe the penetration. the leakage rate is assumed to be the lesser actual pathway leakage of the two devices. Q The 4 hour Completion Time for leakage on hydrostatically tested lines and for secondary containment bypass leakage is reasonable considering the time required to restore the leakage by isolating the penetration and the relative

   % k importance of leakage to the overall containment function.
    ~

For MSIV leakage, an 8 hour Completion Time is allowed. The Completion Time of 8 hours for MSIV leakage allows a period i of time to restore the MSIVs to OPEPABLE status given the fact that the MSIV closure will result in isolation of the main steam line(s) and potential for plant shutdown. The 24 hour Completion Time for purge valve leakage is acceptable , considering the purge valves remain closed so that a gross ' breach of the containment does not exist. The 72 hour Completion Time for EFCV leakage is acceptable based on the instrument and small pipe diameter of the penetration i (hence, reliability) to act as a penetration . isolation y boundary. I E.1 and E.2 If any Required Action and associated Completion Time cannot be met in MODE 1. 2. or 3. the plant must be brought to a MODE in which the LCO does not apply. To achieve this ! status, the plant must be brought to at least MODE 3 within l 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable. based on operating j experience, to reach the required plant conditions from full l power conditions in an orderly manner and without ' i challenging plant systems. B 3.6.1.3 - 9 Revision 11 07/14/99 f(' l FERMI - UNIT 2 L

PCIVs l B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued) l e Secondary containment bypass leakage is also considered part 1l of L,. SR 3.6.1.3.12 The analyses in References 1 and 4 are based on leakage that is less than the specified leakage rate. Leakage through all four main steam lines must be s 100 scfh when tested at

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

accountec for to assure safety analysis assumptions, regarding the MSIV LCS ability to provide a positive pressure seal between MSIVs remain valid. This leakage test is performed in lieu of 10 CFR 50. Appendix J. Type C test requirements, based on an exemption to 10 CFR 50, Appendix J. As such, this leakage is not combined with the Type B and C leakage rate totals. The Frequency is required by the Primary Containment Leakage Rate Testing Program. SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the n number of valves per penetration, not to exceed 3 gpm. when f (a 62.2 psig). Additionally, a combined tested leakageatrate 1.1lim P,it of s 5 gpm when tested at 1.1 P,

   %                     (a 62.2 psig) is applied for all hydrostatically tested Q                      PCIVs that senetrate containment. The combined le'akage rates must ye demonstrated in accordance with the leakage rate test Frequency required by Primary Containment Leakage Rate Testing Program.

This SR has been modified by a Note that states that -these valves are only required to meet the combined leakage rate in MODES 1, 2, and 3, since this is when the Reactor Coolant l System is pressurized and primary containment is required. l In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1. 2 I and 3. However, specific leakage limits are not applicable ; in these other MODES or conditions. l l l l FERMI - UNIT 2 B 3.6.1.3 - 16 Revision 11 07/14/99 L

Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7

  )        BASES 1

APPLICABLE SAFETY ANALYSES (continued) The results of these two cases show that the external vacuum breakers, with an opening setpoint of 0.5 psid. are capable of maintaining the differential pressure within design limits. The reactor building to suppression chamber vacuum breakers satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 4 LC0 All reactor building to-suppression chamber vacuum breakers, two on each line, are required to be OPERABLE to satisfy the assumptions used in the safety analyses. The requirement ensures that the two vacuum breakers (vacuum breaker and air l ' Q operated butterfly isolation valve) in each of the two lines from the reactor building to the suppression chamber

     @                      airspace are closed (except during testing or when t                       performing their intended function). Also, the requirement       I b                        ensures both vacuum breakers in each line will open to relieve a negative pressure in the suppression chamber.

l APPLICABILITY In MODES 1, 2. and 3. a DBA could cause pressurization of primary containment. In MODES 1, 2. and 3. the Suppression i Pool Spray System is required to be OPERABLE to mitigate the n effects of a DBA. Excessive negative pressure inside n primary containment could occur due to inadvertent 2! initiation of this system. Therefore, the vacuum breakers E are required to be OPERABLE in MODES 1. 2 and 3. when the l Jl Suppression Pool Spray System is required to be OPERABLE, to I mitigate the effects of inadvertent actuation of the l Suppression Pool Spray System. l : Also, in MODES 1. 2. and 3. a DBA could result in excessive negative differential pressure across the drywell wall ! caused by the rapid depressurization of the drywell. The I event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with , steam. Subsequent condensation of the steam would result in i depressurization of the drywell. The limiting pressure and l temperature of the primary system prior to a DBA occur in MODES 1. 2. and 3. l j .- l FERMI UNIT 2 83.6.1.7-3' Revision 11 07/14/99 l L

Reactor Building to Suppression Chamber Vacuum Breakers B-3.6.1.7 i BASES ACTIONS (continued)- the fact that the leak tight primary containment boundary is being maintained. D1 9 With two lines with one or more vacuum breakers inoperable

     ;I                          for opening, the primary containment boundary is intact.

4 However in the event of a containment depressurization, the 4 . function of the vacuum breakers is lost. Therefore, all 17) vacuum breakers in one line must be restored to OPERABLE status within 1 hour. This Completion Time is consistent w with the ACTIONS of LCO 3.6.1.1. which requires that primary . Q containment be restored to OPERABLE status within 1 hour, j E.1 and E.2

       l    -

If all the vacuum breakers in one line cannot be closed or restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 3 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems. SURVEILLANCE 1R 3.6.1.7.1 REQUIREMENTS Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker position or by verifying a differential pressure of 0.5 psid is maintained between the reactor building and suppression chamber. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations ; personnel, and has been shown to be acceptable through ; operating experience. ' Two Notes are added to this SR. The first Note allows ; reactor-to suppression chamber vacuum breakers opened in ) conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening i FERMI UNIT 2 B 3.5.1.7 - 5 Revision 11 07/14/99 L '

Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7

   ,i   BASES SURVEILLANCE REQUIREMENTS (continued) l                          vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers. The second Note is included to clarify that vacuum breakers open due to an

! actual differential pressure are not considered as failing this SR. SR 3.6.1.7.2 Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position. This ensures that the safety analysis assumptions are valid. The 31 day Frequency of - this SR was developed based upon Inservice Testing Program l requirements to perform valve testing at least once every i 92 days. A 31 day Frequency was chosen to provide . j l additional assurance that the vacuum breakers are OPERABLE. ] SR 3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is , necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 5 0.5 psid is valid. This verification may be performed by measurement of the equivalent force to move the pullet. The 18 nonth 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. The 18 month Frequency has been shown to be acceptable, based on ! operating experience. and is further justified because of j other surveillances performed at shorter Frequencies that i convey the proper functiondag status of each vacuum breaker. l

l REFERENCES 1. UFSAR. Section 6.2. 1 l l FERMI UNIT 2 B 3.6.1.7 - 6 Revision 11 07/14/99 L

Suppression Chamber to Drywell Vacuum Breakers I B 3.6.1.8

i BASES

APPLICABLE 31alytical methods and assumptions involving the SAFETY. ANALYSES suppression chamber to drywell vacuum breakers are presented in Reference 1 as part of the accident response of the primary containment systems. Internal (su)pression chamber to drywell) and external (reactor )uilding-to suppression chamber) vacuum breakers are provided as part of the primary containment to limit the negative differential pressure across the drywell and suppression

                          . chamber walls that form part of the primary containment boundary.

The safety analyses assume that the internal vacuum breakers are closed initially and are fully open at a differential ' pressure of 0.5 psid (Ref.1). Additionally. 3 of the i 12 internal vacuum breakers are assumed to fail in a closed l

                          . position (Ref. 1). The results of the analyses show that              ;

the design pressure is not exceeded even under the worst I case accident scenario. The vacuum breaker opening differential pressure set)oint and the assumption that 9 of 12 vacuum breakers open wien required are a result of the requirement placed on the vacuum breakers to limit excessive water level variation in the portion of vent discharge line l submerged in the suppression pool. j The suppression chamber to drywell vacuum breakers satisfy l Criterion 3 of 10 CFR 50.36(c)(2)(ii). i LC0 All vacuum breakers are required to be OPERABLE for opening and are also required to be closed (except during testing or when the vacuum breakers are performing their intended design function). The vacuum breaker OPERABILITY requirement provides assurance that the drywell to-suppression chamber negative differential pressure remains below the design value. The requirement that the vacuum breakers be closed ensures that there is no excessive bypass leakage should a LOCA occur. In MODES 1, 2. and 3. the Suppression Pool Spray System is

    @{ APPLICABILITY       required to be OPERABLE to mitigate the effects of a DBA.

Q Ni Excessive negative pressure inside the drywell could occur due to inadvertent actuation of this system. The vacuum l FERMI UNIT 2 B 3.6.1.8 - 2 Revision 11 07/14/99 L

Suppression Chamber to-Drywell Vacuum Breakers B 3.6.1.8

BASES APPLICABILITY (continued) breakers, therefore, are required to be OPERABLE in MODES 1 Ml 2. and 3. when the Suppression Pool Spray System is required 4 to be OPERABLE. to mitigate the effects of. inadvertent actuation of the Suppression Pool Spray System. Q Also, in MODES 1. 2. and 3. a DBA could result in excessive negative differential pressure across the drywell wall. 3 caused by the' rapid depressurization of the drywell. The j event that results in the limiting rapid depressurization of l the drywell is the primary system rupture that purges the j drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in - depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES 1. 2. and 3. In MODES 4 and 5. the probability and consequences of these events are reduced by the pressure and temperature limitations in these MODES: therefore, maintaining suppression chamber-to drywell vacuum breakers OPERABLE is not required in MODE 4 or 5. 1 ACTIONS M l I With one of the required vacuum breakers inoperable for ) opening (e.g.. the vacuum breaker is not open and may be stuck closed or not within its opening setpoint limit. 50 l that it would not function as designed during an event that depressurized the drywell). the remaining eleven OPERABLE vacuum breakers are capable of providing the vacuum relief function. However overall system reliability is reduced, and since normal periodic functional testing of the vacuum breakers is deferred to MODE 4 (SR 3.6.1.8.2). additional undetected failures could result in an excessive suppression chamber-to drywell differential pressure during a DBA. Therefore. with one vacuum breaker inoperable. 72 hours is allowed to restore the inoperable vacuum breaker to OPERABLE status. The 72 hour Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate.

   ! FERMI    UNIT 2                    B 3.6.1.8 - 3            Revision 11. 07/14/99 e

RHR Suppression Pool Cooling B 3.6.2.3

                                                                                                 ~
 ]          BASES ACTIONS (continued).

overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pooi cooling capabilities afforded by the OPERABLE subsystem and-the low probability of a DBA occurring during this period. IL1 With two RlR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours. In this condition, there is a substantial loss of -

      "                       the primary containment pressure and temperature mitigation E                       function. The 8 hour Completion Time is based on this loss k                       of function and is considered acceptable due to the low Q                       probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the RHR suppression pool cooling subsystem to operate.

C.1 and C.2 If the Required Action and associated Completion Time cannot

be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be k brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience. to reach the recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems, c I SURVEILLANCE SR 3.6.2.3.1 - l REQUIREMENTS - i Verifying the correct alignment for manual, power operated, and automatic valves in the RHR sup>ression pool cooling mode flow path provides assurance t1at the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is _. c ._. l FERMI - UNIT 2 B 3.6.2.3 -3 Revision 11. 07/14/99 L

RHR Suppression Pool Spray B 3.6.2.4

i B 3.6 CONTAINENT SYSTEMS B 3.6.2.4 ' Residual Heat Removal (RE) Suppression Pool Spray BASES

         ' BACKGROUND-        Following a Design Basis Accident (DBA), the RHR Suppression Pool Spray System removes heat from the suppression chamber airspace. The suppression )ool-is designed to absorb the sudden input of heat from tie primary system from a DBA or a rapid depressurization of the reactor pressure vessel (RPV) through safety / relief valves. The heat addition to the            ;

suppression pool results in increased steam in the .t suppression chamber, which increases primary containment pressure. Steam blowdown from a DBA can also by) ass the suppression pool and end up in the suppression clamber airspace. Some means must be provided to remove heat from the suppression chamber so that the pressure and temperature inside primary containment remain within analyzed design limits. This function is provided by two redundant Rm suppression pool s) ray subsystems. The purpose of this LCO is to ensure that >oth subsystems are OPERABLE in applicable MODES. Each of the two RHR suppression pool spray subsystems contains two pumps and one heat exchanger, which are manually initiated and independently controlled. The two subsystems perform the suppression pool spray function by circulating water from the suppression pool through the RHR heat exchangers and returning it to the suppression pool spray spargers. The spargers only accommodate a small portion of the total RE pump flow: the remainder of the flow returns to the suppression pool through the suppression pool cooling return line. Thus, both suppression pool cooling and suppression pool spray functions are performed when the Suppression Pool Spray System is initiated.: RHR service water, circulating through the tube side of the heat exchangers, exchanges heat with the suppression pool' water and discharges this heat to the RHR reservoir. Either RHR suppression pool spray subsystem is sufficient to condense the steam from small bypass leaks from the drywell to the suppression chamber airspace during the postulated DBA. l l FERMI UNIT 2 B 3.6.2.4- 1 Revision 11. 07/14/99 j k

RHR Suppression Pool Spray B 3.6.2.4 BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break loss of coolant accidents. The intent of the analyses is to demonstrate that the pressure reduction capacity of the RHR Suppression Pool Spray System is adequate to maintain the primary containment conditions within design limits. The time history for primary containment pressure is calculated to demonstrate that the maximum pressure remains below the design limit. The RHR Suppression Pool Spray System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). . LC0 In the event of a DBA, a minimum of one RHR suppression pool spray subsystem is required to mitigate potential bypass leakage paths and maintain the primary containment peak pressure below the design limits (Ref.1). To ensure that these requirements are met two RHR suppression pool spray subsystems must be OPERABLE with power from two safety related independent power supplies. Therefore, in the event '. of an accident, at least one subsystem is OPERABLE assuming ; the worst case single active failure. An RHR suppression l pool spray subsystem is OPERABLE when one of the RHR pumps. ) the heat exchanger, and associated piping, valves, i instrumentation, and controls are OPERABLE. l l APPLICABILITY In MODES 1, 2. and 3. a DBA could cause pressurization of primary containment. In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining RHR suppression pool spray subsystems OPERABLE is not required in MODE 4 or 5. ACTIONS J A With one RHR suppression pool spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE RHR suppression pool spray subsystem is adequate to perform the primary containment bypass leakage mitigation function. However, the overall reliability is reduced because a single l FERMI - UNIT 2 B 3.6.2.4-2 Revision 11 07/14/99 L

RHR Suppression Pool Spray B 3.6.2.4

BASES ACTIONS (continued) failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation ca) ability. The 7 day

                        - Completion Time was chosen in light of t1e redundant RHR su)pression pool spray capabilities afforded by the OPERABLE su) system and the low probability of a DBA cccurring during this period.

L.1 With both RHR suppression pool spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status , within 8 hours. In this Condition, there is a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available. C.1 and C.2 If the inoperable RHR suppression pool spray subsystem cannot be restored to OPERABLE status within the associated i Completion Time, the plant must be brought to a MODE in J which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power opdrated, and automatic valves in the RHR suppression pool spray mow flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or l FERMI - UNIT 2 B 3.6.2.4 - 3 Revision 11 07/14/99 L

RHR Suppression Pool Spray B 3.6.2.4 BASES , i i SURVEILLANCE REQUIREMENTS (continued) valve manipulation: rather, it involves verification that those valves capable of being mispositioned are in the J correct position. This SR does not apply to valves that i cannot be inadvertently misaligned, such as check valves. l The Frecuency of 31 days is justified because -the valves are operatec under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the I subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating i experience. SR 3.6.2.4.2 .l Verifying each RHR pump develops a flow rate a: 500 gpm while o>erating in the sup)ression pool spray mode with flow t1 rough the heat exc1 anger ensures that pump performance has not degraded during the cycle. Flow is a normal test of l centrifugal pump performance required by Section XI of the i ASME Code (Ref. 2). This test confirms one point on the pum) design curve and is indicative of overall performance. Suc1 inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is [in accordance with the Inservice Testing Program. REFERENCES 1. UFSAR. Section 6.2.

2. ASME, Boiler and Pressure Vessel Code, Section XI.

l l FERMI UNIT 2 B 3.6.2.4 -4 Revisio[11, 07/14/99 l L !

F SCIVs B 3.6.4.2

    )'       BASES APPLICABLE SAFETY ANALYSES (continued) containment performs no active function in response to             j either of these limiting events, but the boundary established by SCIVs.is required to ensure that leakage from the primary containment is processed by the Standby Gas            1 Treatment (SGT) System before being released to the environment.

Maintaining SCIVs OPERABLE with islation times within limits ensures that fission products will remain trapped inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment. . SCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 SCIVs form a part of the secondary containment boundary. m The SCIV safety function is related to control of offsite h radiation releases resulting from DBAs.

    ' 'l                      The power operated automatic isolation valves are considered OPERABLE when their isolation times are within limits and the valves actuate on an automatic isolation signal. The valves covered by this LCO. along with their associated stroke times, are listed in Reference 3.

The normally closed isolation valves or blind flanges are considered OPERABLE when manual valves and blind flanges are closed..or open in accordance with appropriate ( administrative controls. APPLICABILITY In MODES 1. 2. and 3. a DBA could lead to a fission product release to the primary containment that leaks to the 1 secondary containment. Therefore, the OPERABILITY of SCIVs ! is required. 1 In MODES 4 and 5. the probability and consequences of these l events are reduced due to pressure and temperature limitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5. except for other

 .i                                                    -
                                                                                ..               i
         !. FERMI   UNIT 2                     B 3.6.4.2 - 2          Revision 11   07/14/99 L

i L L L' SCIVs l B 3.6.4.2 i BASES APPLICABILITY (continued) situations under which significant radioactive releases can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS or during movement of irradiated fuel

assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES.1. 2. and 3.

l ACTIONS The ACTIONS are modified by three Notes. The first Note allows penetration flow paths to be unisolated - intermittently under administrative controls. These controls consist of stationing a dedicated operator, who is in continuous communication with the control room, at.the controls of the isolation device. In this way, the penetration can be rapidly isolated when a need for secondary containment isolation is indicated. The second Note provides clarification that for the purpose of this LCO separate Condition entry is allowed for eacn penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate com)ensatory actions for each inoperable SCIV. Complying wit 1 the. Required Actions may allow for continued operation, and subsequent inoperable SCIVs are governed by subsequent Condition entry and application of associated Required Actions. The third Note ensures ap)ropriate remedial actions are taken. if necessary, if tie affected system (s) are rendered inoperable by an inoperable SCIV. A.1 and A.2 . In the event that there are one or more penetration flow paths with one SCIV inoperable, the affected penetration flow path (s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic SCIV. a closed manual valve. and a blind flange. For penetrations isolated in accordance with L L j FERMI . UNIT 2 B 3.6.4.2 - 3 Revision 11. 07/14/99

SCIVs B 3.6.4.2

  )          BASES ACTIONS (continued)

Required Action A.1, the device used to isolate the penetration should be the closest available device to secondary containment. The Required Action must be - completed within the 8 hour Completion Time. The specified time period is reasonable considering the time required to isolate the penetration, and the probability of a DBA, which requires the SCIVs to close, occurring during this short time is very low. For affected penetrations that have been isolated in accordance with Required Action A.1, the affected

                                 )enetration must be verified to be isolated on a periodic         -
                                 ) asis. This is necessary to ensure that secondary containment penetrations required to be isolated following an accident, but no longer capable of being automatically isolated. will be in the isolation position should an event occur. The Completion Time of once per 31 days is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves verification that the affected penetration remains isolated.         !
       *l Required Action A.2 is modified by two Notes. Note 1
                              . applies to devices located in high radiation areas and allows them to be verified closed by use of administrative controls. Allowing verification by administrative controls n                         is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of b                       misalignment, once they have been verified to be.in the proper position, is low. Note 2 applies to isolation devices that are-locked, sealed, or otherwise secured in position and allows these devices to be verified closed by

(

           ,                   use of administrative means. Allowing verification by administrative means is considered acceptable, since'the function of locking, sealing, of securing components is to ensure that these devices are not inadvertently t                         repositioned.

IL1 With two SCIVs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. s

          ! FERMI - UNIT 2                       B 3.6.4.2 -4          Revision 11   07/14/99 L

SCIVs B 3.6.4.2

                                                                                               ~
   )       BASES ACTIONS (continued)

Isolation barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve and a blind flange. The 4 hour Completion Time is reasonable considering the time required to isolate the penetration and the probability of a DBA which requires the SCIVs to close. occurring during this short time, is very low. The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of two penetrations. . C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the 1 recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems. D.1. 0.2. and 0.3 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply. If applicable. CORE ALTERATIONS and the movement of irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPORVs in order to minimize the probability of a vessel draindown and ng the subsequent potential for fission product release. Actions must continue until OPDRVs are suspended. The Required Actions have been modified by a Note stating {Dl that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5. LC0 3.0.3 would not specify any action. If moving fuel while in MODE 1. 2. or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. [ j FERMI UNIT 2 B 3.6.4.2- 5 Revision 11 07/14/99 u

t I SCIVs B 3.6.4.2

     )       BASES SURVEILLANCE   SR 3.6.4.2.1 REQUIREMENTS Q                   This SR verifies that each secondary containment manual isolation valve and blind flange that is not locked, sealed.

or otherwise secured and is required.to be closed during C accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in' secondary containment that are capable of baing mispositioned are in the correct position. - Since these SCIVs are readily accessible to personnel during normal operation and verification of their >osition is relatively easy, the 31 day Frequency was closen to

        %                  provide added assurance that the SCIVs are in the correct
          )                positions. This SR does not apply to valves that are 3                 locked, sealed, or otherwise secured in the closed position Q                 since these were verified to be in the correct position upon locking, sealing, or securing.

Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of aditinistrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1. 2. and 3 for ALARA reasons. Therefore, the arobability of misalignment of these SCIVs. once they have

                           >een verified to be in the proper position, is low.

A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. . n SR 3.6.4.2.2 ' D Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate y OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. l FERMI UNIT 2 B 3.6.4.2-6 Revision 11 07/14/99 L

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)- components usually pass the SR when performed at the 18 month Frequency. Therefore. the Frequency is acceptable from a reliability standpoint. This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing. SR 3.8.1.12 This Surveillance demonstrates that EDG non critical o protective functions (e.g. high jacket water temperature)

T are bypassed on an actual or simulated emergency start (LOCA

  -                    or loss of offsite power) signal and critical protective k,                    functions (engine overspeed, generator differential current.

low lubricating oil pressure crankcase overpressure, and failure to start) trip the EDG to avert substantial damage to the EDG unit. The non critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The EDG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the EDG. The 18 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when ; performed at the 18 month Frequency. Therefore the Frequency was concluded to be acceptable from a reliability standpoint. SR 3.8.1.13 - Regulatory Guide 1.108 (Ref 9), paragraph 2.a.(3), requires demonstration once per 18 months that the EDGs can start and l run continuously at full load capability for an interval of not less than 24 hours-22 hours of which is at a load equivalent to the continuous rating of the EDG, and 2 hours of which is at a load equivalent to 110% of the continuous duty rating of the EDG. Fermi 2 has taken an exception to this requirement and performs the 22 hour run at approximately 90% of the continuous rating (2500 kW-

     ! FERMI   UNIT 2                      B' 3. 8.1 - 16         Revision 11. 07/14/99

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

2600 kW). and performs the 2 hour run at approximately the continuous rating (2800 kW 2900 kW). The EDG starts for j this Surveillance can be rerformed either from standby or hot conditions. The prov.sions for prelube and warmup, i discussed ir SR 3.8.1.2 and for gradual loading, discussed / in SR 3.8.1.3, are applicable to this SR. m Although no power factor requirements are established by this SR. .the' EDG is normally operated at a power factor b between 0.8 lagging and 1.0. The 0.8 value is the design d rating of the machine, while the 1.0 is an operational Q limitation to ensure circulating currents are minimized. A D load band is provided to avoid routine overloading of the 'l EDG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY. The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3); takes into consideration plant conditions required to perform the Surveillance: and is intended to be consistent with expected fuel cycle lengths. This Surveillance has been modified by a Note. The Note states that momentary transients due to changing bus loads do not invalidate this test. SR 3.8.1.14 j This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown ; from normal Surveillances, and achieve the minimum required ! voltage and frequency within 10 seconds and maintain a steady state voltage and frequency range. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. .The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5). This SR is modified by two Notes. Note 1 ensures that the n test is performed with the diesel sufficiently hot. Thc p requirement that the diesel has operated for at least 2 hours near full load conditions prior to performance of , D this Surveillance is based on manufacturer recommendations t for achieving hot conditions. Routine overloads may result Dl in more frequent teardown inspections in accordance with l FERMI UNIT 2 B 3'.8.1 - 17 Revisien-11. 07/14/99

l l l AC Sources-Operating B 3.8.1 BASES l SURVEILLANCE REQUIREMENTS (continued) , vendor recommendations in order to maintain EDG OPERABILITY. I Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all EDG starts to be ; preceded by an engine prelube period to minimize wear and tear on the diesel during testing. SR 3.8.1.15 As requ. ired by Regulatory Guide 1.108 (Ref. 9). paragraph 2.a.(6). this Surveillance ensures that the manual synchronization and load transfer from the EDG to the offsite source can be made and that the EDG can be returned to standby status when offsite power is restored. It also ' ensures that the auto start logic is reset to allow the EDG to restart and reload if a subsequent loss of offsite power l occurs. The EDG is considered to be in standby status when i the EDG is shutdown with the output breaker open. the load sequence timers are reset, and is able to restart and reload i l on a subsequent bus under voltage. j The Frequency of 18 months is consistent with the i recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into consideration plant I conditions desired to perform the Surveillance. S_R 3.8.1.16 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and

                       .-starting signals to motor breakers to prevent overloading of the EDGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the EDG to restore frequency and voltage prior to applying the next load and that. safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic leading of ESF buses.

The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(2): takes into consideration plant conditions required to perform the Surveillance: and is intended to be consistent with expected fuel cycle lengths. UNIT 2 B ' 3. 8.1 - 18 Revision 11 07/14/99 g i FERMI l L

Spcifedka L4.8

                                                                    &lSo See Sfecificabon 3.10.l}

REACTOR COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL [, { HOT SHUIDOWN LIMITING CONDITION FOR OPERATION kCO -2.'.9 1 Two8 shutdown cooling mode loops of the residual heat removal (RHR) 3.46 system shall be OPERABLE and, at least one recirculation pump shall be in o eration_or, at least one shutdown cooling mode loop shall be in operation *88 - i withpch' loop cQnsisting of at least.: I

                    # a.                ERABCE RH   ump, nd                         *
                           . One      RABL RHR heat er       er. )

APPLICABILITY: OPERAT!bHALCONDITION3,withreactorvesselpressureless ) than the RHR cut-in pemissive setpoint. 1 ACTION: (Md Acfan s ModC h . ess than the above required RHR shutdovn cooling mode loops

             ,                   OPERABLE. immediately initiate corrective action to return the j   h o.g/            required loops _to OPERABLE status as soon as_possible. _)(i. thin 1 hour fod'atAgast-oncs-eer 2 b hours.-thereafter1 verify the M,}

OPERABILITY of at least one alternate method capable of decay heat Be in removal forSHUTDOWN at least COLD each inoperable within 24 RHR hours shutdohcooling mode loop.

                        & ~ With neither a recirculation pump nor an RHR shutdown cooling mode loop in operation, immediately initiate corrective action to return
                                                                                                                \

R either at least one recirculation pump or at least one RHR shutdown [ C, /0 $ V cooling mode loop to operation as soon as possible. Within 1 hour establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per Achon s hic I 1 e p Q ,g,j e The provisions of Specification 3.0.4 are not applicable for up to 4 9 prs IJOTY hours for the purpose of establishing the RHR system in the shutdown cooling mode once the reactor vessel pressure is less than the RHR cut-in permissive setpoint. A I SURVElltANCE REOUTREMENTS S -4.4.s.l.1- At least one shutdown cooling mode loop of the residual heat N 3,.01 removal system or at least one recirculation pumn shall be determined to be in M operation and circulating reactor coolant at least once per 12 hours. p 9 Lco5. }80ne RHR shutdown cooling mode loop mry be inoperable for up to 2 hours for tJo+e 2 %. surveillance testing. gco 3 4 *The shutdown cooling pump may be removed from operation for up to 2 hours 1 p,te i per 8-hour period. b,,ep fion }I8The RHR shutdown cooling mode loop may be removed from operation during hy.drostatic test 1D9 4 *3 p.1 *Whedever'FoW R'HR shutdown cooling modeJcops are two rable, i unablesto 4'l A attain,. COLD SHUTDOWN as rel> d by this'ACTJON, main acto ntN l emperature as lowft_ practical use of altelnate heat rem 1 meth 7 i FERMI - UNIT 2 ./4 4-26 PAGE 0F 02 MI

l S PE c t Fs(4T10,J 3. 7, l EMERGENCY CORE COOLING SYSTEMS LIM TING CONDITION FOR OPERATION (Continued) EJ.SE:

      , g, l        a.        For the core spray system:

i

1. WithoneCSSsubsysteminopgrable,providedthatatleastoneLPCI MT/ON A pump in each LPCI subsystem is OPERABLE. restore the inoperable CSS subsystem to OPERABLE status within 7 days or be in at least

{ HOT SHU100WN within the next 12 hours and in COLD SHUTDOWN within A CTIOM D the following 24 hours. l ACf/0g.7- 2. With both CSS subsystems inoperable, be in at least H SHUTDOWN d hours. L.l withinQoursandinCOLDSHUTDOWNwithinthenext

b. For the LPCI system:

1. With one LPCI pump in either or both LPCI subsystems inoperable, A C7/O'i Ae6 provided that at least one CSS subsystem is OPERABLE, restore the inoperable LPCI pump (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours and in COLD A CTION D SHUTDOWN within the following 24 hours.

A c7f Orj A 2. WithoneLPCIsubsystemothgrwiseinoperable,providedthatboth CSS subsystems are OPERABLE , restore the inoperable LPCI subsystem to OPERABLE status within 7 days or be in at least HOT RT/od D SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.

3. @liUTDOWNwithinith A C7/oy rs andain LPCI system cross-tie, valve _close y--

S COLD SHUTDOWN within the next hours. A 4. With' both LPCI kub_ systems othentise inoperable, be in at least(HOT

       /f C.T IO N J                   SHUTDOWN within[2) hours and in COLD SHUTDOWN within the next@

hours.* 5 R 3. 5.1. 4- 5. se orovisions of saecification 3.0.4-are not mooltenwrb for up to gg 4 hours for the purpose of establishing the RHR system in the Lyc1 gf i mode once the reactor vessel cressur (is greater than the RHR cut-in permissive setpoint. Q o0 E y A(,Tiord y 3i for__ the HPCI system, (provided .the CSS'. the LPCI systemQthe ADS and

c. l2 f cTiorg g ,the RCIC system)are OPERABLE:

000 /kitora p

1. With the HPCI system inoperable, restore the HPCI system to -

A CT r ou E OPERABLE status within 14 days or be in at least HOT SHUTDOWN k within the next 12 hours and reduce reactor' steam dome pressure to o s 150 psig within the following 24 hours. ,

                 *Whe
                                                   ^

r two or more RWR subsystems are ino le, if unable t tainCOLp r-h ~

                                                                                                                               &1 OWN as require        y this ACTI.... or ,1,ON, main n reactor coolant       pnar2tur v          3 inw me nr. ,+ v                           ......      .. .. - .1 - , s a,, ,

4xcept one'CSSulubs stein and oMPCI subsystem _may be inoperablefdue to a lacd ACT/Ot) C 'oTTECW cooli~n$ provided theCAciavna vi apesivitatiuna.i.a.garetaken. j ( App Action c ) FERMI - UNIT 2 3/4 5 2 Amendment No. $,80 PAGE

                                                                       '       0F      10
                                                                                                   ~

bI,

                                                                                       $$Est Psckf1DA) 3 G,2.,2.

m

     '                                                                         (Also .ue. SnhKes 3.S.2)

LINfTING CONDITION FDR OPFRATION 21? The suppression chamber shall be OPERABLE: . LCO 3.G.2. 2.- .

a. In OPERATl0NA. ColSITIONS 1. 2. and.3 with Es tsfitaindi watafvolume4D at leastuume rt>,reenwalenVtapa level orQpy (-Z inches indication).

b. bPERATIONAL CONDITIONS 4 and l' with a contais.ed volume of at least 64,550 ft*, equivalent to a level of 9'0' (r66 inches indication),

except that the suppression chamber level may be less than the Itait gg,L or may be drained provided that: SpeciscekM 1. - No operations are performed that have a potential for draining g,f- g,, the reacter vessel,

2. The reactor mode switch is locked in the Shutdown or Refuel position,

3. The condensate storage tank water level is at least 19 ft., and l

4. The core spray system is OPERA 8LE pe- Specification 3.5.2 with an OPERABLE flow path capable of taking suction from the condensate storage tank and transferring the water through the spray sparger to the reactor vessel. .sas, u,6 3 5 2 APPLICABfLfTY: OPERATIONALCONDITIONS{1,2,I){and5 l

ACTION: b / CB .3,G,2.2-In OPERATIONA CONDITION 1. 2. or 3 with the suppression chamber water ACTlav Aa. ievei iess than,the above iimit, restore the water level to within the limit within our or be in at least HOT SHUTDOWN within the next 12 MT10tJ hours and in 0 SHUT 00WN within the following 24 hours,

b. ln OPERATIONAL CONDITION 4 or 5' with the suppression chamber water su level less than the above limit or drained and the above reevired '

conditions not satisfied, suspend CORE ALTERATIONS and all. operations SpecihCab ! that have a potential for draining the reactor vessel and lock the t y,g reactor mode switch in the Shutdown position. Establish SECONDA8Y 1 CONTAlfetENT INTEGRITY within 8 hours.

        \
          \ ,,         *The suppression chamber is not required to be OPERA 8LE provided that the                        ;

N reactor vessel haad is removed, the cavity is flooded, or being flooded 1 from the suppression pool, the spent fuel pool gates are removed when the I cavity is flooded, and the water level is maintained within the llatts of Specifications 3.9.5 and 3.9.9.

                      "                                                                                         l FERMI - UNIT 2                                  3/4 5 8                        Amendment No.131 f PAGE         I    _0F      05

i-i t,. Specanc 3.s . t. 3 , (Also s ce Syceifica.1:n f.6,I .I) CONTs1Ns4ENT SYc m ? ( $ {s o fe e_ Specife'cdfo n f,5) \ LIMITING CONDTTMN r?D ODED1 TION (Continue 9 gTJQ!!: (Continued)

c. Tne c:m::na: iaamage rate for primary c:ntainment penetrations and '

primary containment isolation valves subject to Type B and C tests 5*E , . in accoroance with the Primary Containment Liakage Rate Testing 6FecificaIf *4 Program, except for main steam line isolation valves

and primary f, y I containment isolation valves which are hydrostatically tested.

Qasts to less than or equal to 0.60 La, and

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

d. ) The combined leakage rate for all containment isolation valves in y Ac.ppy p 4 hydrostatically tested lines whith penetrate the primary --

containment p,Aers),asn or penalp gpand 6' -

e. The leakage rate of ary hydrostatically tested linehe'. rating _ h primary containmentit iuss Inaya yy p inva.6 valve s) N e permeer of conta ntisol#tionvalv[va nor a atratio .r 1Ms aff 3 comAier pen ration / l SURVEfttANCE RE001REMENTS

   %                  4.6.1.2 Perform required primary containment leakage rate testing in                          !
    ,1                 ccordance with the Primary Containment Leakage Rate Program described in
              ' , 7 Specification 6.8.5.g.**

i Iet l' Sy reificdie n '

      .'           3.(, . l .\

k i sit. 3. G l 3,lz Fraynucy S tt. 3 6 . t. 5 ,1 3 Frspany .

                   %0: SR % IStl4 Aukvn D &

NON A1NIhETJT 4tf [t4 bay

                                                                                        \          *q                    &

ge e

Exemption to Appendix J of 10 CFR Part 50 j 6f'esificAf > *Except for LPCI Loop A and B Injection isolation valves, which are f, f hydrostatically tested in accordance with Specification 4.4.3.2.2 in lieu l, of this requirement.

_, FERM1 - UNIT 2 3/4 6 3 Amendmen(No. Jp2,109 ReV11 e PAGE I 0F 09 Rev R

SpEcoPtatrie4 %,l.3 A . [ CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER PURGE SYSTEM LIMITING CONDITION FOR OPERATION s g g , g ,g 3.6.1.8 The drywell and suppression chamber purge system '0 ..~., M ..~..,

                      ^^ ' :' . : ' ?' '--' " '"-*) may be in operation with the supply and exhaust                                              '-

M _ isolation valves in one supply line and one exhaust line open for inerting, T deinertin or pressure control. Nitrogen VENTING / makeup and pressure control N.,.al s{ a,loweg,tgougp,tg 1-inch valvg .{..

                                                                                                 ,'....; .;.. . ;-... ... _ _;r. tr.; L,f APPLICABILITY: OPERATIONAL CONDITIONS 1,g2 and 3.                                          j                           l hDe A-capNK AcinNs NorE         norE/8-y)                                      [g                   y AG.I. LDH

i jg a.

hhe keneMy 08012 3 > With a drywell and suppression chamber purge system supply and/or 92 "ON4 exhaust isolation valve open, except as permitted above, close the valve (s) or otherwise isolate the penetration (s) within 4 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD ' MNb SHUTDOWN within the following 24 hours,

b. With a drywell and suppression chamber purge system supply and/or h"2 kW D exhaust isolation valve (s) with resilient material seals having a measured leakage rate exceeding the limit of Specification h s:

f 4.6.1.8.2 restore the inoperable valve (s) to OPERABLE status fp r% within 24 hours or be in at least HOT SHUTDOWN within the next 12 j% e4

         }       $ 0d b                 hours and in COLD SH DOWN within the following 24 hours.

Oo i AcT>ord 8 \ L .7 ' k' SURVEfLLANCE REOUIREMENTS w 54 % 13 1 4.6.1.8.1[Beforebeinaopened75 purge /ventoperationE__dSETS)the e tJoTE - drywell ano suppression enameer purge supply and exhaust butterfly isolation 7 valves shall be verified not to have been open for purge / vent operatio through *"" '- - -- +':. ^ ..;.., ... ;;.. -- '::: ?!E d:,; .- , Ll g N b y*4 4

                        ^.6.1.8.2      At least once per[92 days}                                ation for each     0-.....,  ;;d i..2,   ;;d ** ' e, : ' ::'. ;-                     -

'. drywell and suppression chamber purge supply and exhaust isolation valve with resilient material seals shall be .

demonstrated OPERABLE by verifying that_the measured leakage rate E '- -- ; { G _. ;er . = _ , * ::

'a

r----- _;

                                                                                        ^             LA.3 3( M,J,3e [

Primary containment nitrogen VENTING and pressure control is permitted 8 I

through the 1-inch valves :nd i: =t :dj::t 'a t '- 9" " : m 355 d:- I E W ,! % l FERMI - UNIT 2 3/4 6-1~4 Amendment.No. SS l# 09 PAGE - 0F f[f liL--

SPEC Ptmnud 3.6.y5 PEACTOR COOLANT SYSTEM 3/4.4.7 MAIN STEAM LINE ISOLATION VALVES 11MYTING CONDITION FOR OPERATION

  @ N'O 3.4.7 Two main steam line isolation valves (MSIVs) per main steam line shall M 3'W'3'7 be OPERABLE with closing times greater than or equal to 3 seconds and less than or equal to 5 seconds.

00 Ac7;o45 MOTE f ) bo APPLICABILITY: OPERATIONAL CONDITIONS 1, 2. and j ACTION:

                                                 @4 MOTE 2.h                    '9 k

AcTsoutMoTEs34Q g y 4 a. With one for morelMSIVs inoperable: Add M TTO N 6 L. 2. .

1. { Maintain at least one MSlv OPERABLE in each affected main steam 7 Lline that it open/Thd within 8 hours, either:

l g n... .. .,,. . _ .. , ., x m . y .... . e gq b) Isolate the aff2cted main steam line by use of a ( !:f dIeactivated Ms110 in the closed position. ,l 1 bgg g 2. Otherwise, be in at least HOT SHUTDOWN within the next 12 hours k and in COLD SHUTDOWN within the following 24 hours. f\ l NY & Y' EURVillt ANCE REOUTREMENTS y~ ;

                                                                                                                       -      i 4.4.7    Each of the above reavired MSIVs snall be cemonstrated OPERABLE by 9' 9'g 3 verifying full closure between 3 and 5 seconds when tested pursuant to 4       '

Specification 4.0.5. FERMI - UNIT 2 3/4 4 24 Amenoment No. 83 Rev11 ll C PAGE _0F 09 fev E I L

r 1 b fECl A CA-Uord N ll fbioSM.3PecN*Cahb.T.la.7.I , (ktso se seehn. pu ) CONTAINMENT SYSTEMS l SURVEILLANCE REQUIREMENTS (Continued) r I

1. At least once per 5 minutes curing testing wnicn acos neat to the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105'F.

2. At least once per hour when suppression chamber average water temperature is greater than or equal to 95'F, by verifying:

a) Suppression chamber average water temperature to be less Se a. than or equal to 110*F, and b) THERMAL POWER to be less than or equal tn 1% of RATED Spacifhhow THERMAL POWER after suppression chamber average water M.L l temperature has exceeded 95'F for more than 24 hours.

c. At least once per 30 minutes in OPERATIONAL CONDITION 3 following a i

scram with suppression chamber average water temperature greater , than or equal to 95'F, by verifying suppression chamber average e4

                        %gr temperature less than or equal to 120*F.                                       j

d. By an external visual examination of the suppression chamber after D da l.l. 3 safety / relief valve operation with the suppression chamber average l water temperature greater than or equal to

nd reactor coolant h' system pressure greater than 200 psig Q g 3,f,J,j,l * - At ;. d unse per-18-months-Dyla visual insnactio_ndT t!.; accesMb

inter +0p-and-axteM er rf S.: =.r; ;; t : ,-chaw 4

    /     5,.n.          f.      By verifying eight suppression pool water temperature                                 l instrumentation channels OPERABLE by performance of a:

S 1. CHANNEL CHECK at least once per 24 hours,

   \eab.b*.

3 4.2. . ] 2. 3. CHANNEL FUNCTIONAL TEST at least once per 31 days, and CHANNEL CAllBRATION at least once per 18 months, with the water high temperature alarm setpoint for s 105'F.

g. Bf verifying both narrow range suppression chamber water level instrumentation channels OPERABLE by performance of a:

gg 1. CHANNEL CHECK at least once per 24 hours, CHANNEL FUNCTIONAL TEST at least once per 31 days, and 2. 6FcIM4b. 3. CHANNEL CAllBRATION at least once per 18 months, f .G .*L. L With the water level alarm setpoint for:

1. High water level 1 14'8"

2. Low water level 1 14'4" (TWMS Narrow Range) g3,g y,g h. At least once per 18 months by conducting a drywell-to-suppression chamber bypass leak test at an initial differential preseure of 1 psi and verifying that the differential pressure does not decrease by more than OJn inch na meer ner minute for_ a period of 10 m_inutes._]If z'ny drywell-t -suppression hamber bypas leak t rTalisjto meet e specified imit, the te schedule f s_ubseo nt- l,,,)

( test,g shall b reviewed an accroved by e Conslissio If two ! ' consecutive tests fail to meet the specified limit, a test shall be l performed at least every 9 months until two consecutive tests meet i the specified limit, at which time the IB. month test schedule may be l resumed. FERMI UNIT 2 3/4 6-17 i PAGE' T OF 08 - l l L 1

I. L L l DISCUSSION OF CHANGES l ITS: SECTION 3.8.2 - AC SOURCES SHUTDOWN [ i- 1

                                                                                          .6 LR.1        Not used.                                                             l4 TECHNICAL CHANGES     LESS RES1RICTIVE
      " Specific" L.1         CTS SR 4.8.1.2. Surveillance Requirements for EDG and offsite sources while shutdown, includes the requirement to perform the CTS equivalent of ITS SR 3.8.1.18 (simultaneous EDG start test).

ITS SR 3.8.2.1 does not require this test to be applicable for determining Operability when shutdown. The change is acceptable because simultaneous start of all four EDGs is not needed because only 2 EDG are required to be Operable. Therefore, this exception has minimal impact on safety. - Furthermore. ITS SR 3.8.2.1, Note, provides several exceptions to required demonstrations (although still retaining the applicability of the specific functional capability to be Operable) that are not provided in CTS SR 4.8.1.2. The reason for the Note is to preclude requiring the Operable EDG from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs. and to preclude de energizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance o, SRs. With limited AC sources available, a single event could compromise both the required circuit and the EDGs. The Fermi-2 EDG design is such that on any EDG surveillance test start, the EDG is rendered m inoperable. Therefore the exception list includes all ITS SRs D involving an EDG start (i.e.. ITS SRs 3.8.1.2. 3.8.1.7. and g 3.8.1.11 are included, in addition to those proposed in the g NUREG). This change is consistent with NUREG 1433. t l I 1 FERMI UNIT 2 5 REVISION 11. 07/14/99l m}}

v t e Letter Sequence Request
TAC:MA1465, TSTF-16, TSTF-38 (Open)
Initiation Request, Request, Request, Request Acceptance... Administration Meeting Questions 26 October 1998 20 November 1998 4 December 1998 22 December 1998 14 January 1999 4 February 1999 11 February 1999 Answers 8 January 1999 30 March 1999 8 April 1999 30 April 1999 7 May 1999 2 June 1999 Results Approval... Other: ML20202H611, ML20239A178, NRC-98-0123, Responds to 980903 RAI Re Plant Staff Qualifications.Util Requests That NRC Act in Timely Manner Toward Resolution,Re Adoption of Reg Guide 1.8,Rev 2,to Ensure That It Does Not Impede Issuance of Fermi 2 ITS SER in May 1999, NRC-99-0052, Forwards Rev 9 to Fermi 2 ITS Submittal,Dtd 980403. Attachment 1 Contains Brief Abstract of Changes Included in Rev.Attachment 2 Contains Revised Pages for Submittal Along with Rev Instructions, NRC-99-0077, Forwards Rev 11 to Fermi ITS Submittal,Dtd 980403,providing Update to Submittal for ITS Sections 3.5,3.6 & 3.8.Update Includes Changes Associated with NRC Review of Util Transmittals of Revs 5,5a & 7 to ITS, NRC-99-0079, Forwards Rev 15 to Fermi 2 ITS Submittal,Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev, NRC-99-0089, Forwards Rev 13 to Fermi 2 ITS Submittal Dtd 980403.Rev Provide Update for Remaining Open Issues Associated with NRC Review of ITS Submittal.Attachment 1 Contains Brief Abstract of Changes Included in Rev
MONTHYEAR1999-02-04 [Table View]

ML20216D609

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