NRC-20-0038, Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules

ML20302A480
Person / Time
Site:	Fermi
Issue date:	10/28/2020
From:	Peter Dietrich DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-20-0038, TSTF-529
Download: ML20302A480 (27)

Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: peter.dietrich@dteenergy.com October 28, 2020 10 CFR 50.90 NRC-20-0038 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules Pursuant to 10 CFR 50.90, DTE Electric Company (DTE) is submitting a request for an amendment to the Technical Specifications (TS) for Fermi Unit 2 (Fermi 2). The proposed amendment would modify TS requirements in Section 1.3 and Section 3.0 regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules." provides a description and assessment of the proposed changes. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides, for information only, existing TS Bases pages marked up to show the proposed changes.

Approval of the proposed amendment is requested by April 28, 2021. Once approved, the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan State Official.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Ms. Margaret Offerle, Manager - Nuclear Licensing, at (734) 586-5076.

DTE

USNRC NRC-20-0038 Page2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 28, 2020 Brian Sullivan, Vice President Engineering and Technical Support, for Peter Dietrich, Senior Vice President and CNO

Enclosures:

1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-Up)

3. Revised Technical Specifications Pages

4. Proposed Technical Specifications Bases Changes (Mark-Up)-Information Only cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy NRC-20-0038 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request - Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules Description and Assessment to NRC-20-0038 Page 1

1.0 DESCRIPTION

The proposed change revises Section 1.3, "Completion Times," and Section 3.0, "LCO Applicability" of the Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

• Section 1.3 is revised to clarify "discovery."

• Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

• Limiting Condition for Operation (LCO) 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options.

• Surveillance Requirement (SR) 3.0.3 is revised to allow application of SR 3.0.3 when a SR has not been previously performed and to clarify the application of SR 3.0.3.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation DTE Electric Company (DTE) has reviewed the safety evaluation for TSTF-529 provided to the Technical Specifications Task Force in a letter dated April 21, 2016. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-529. DTE has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of the changes to the Fermi 2 TS.

2.2 Variations DTE is proposing the following variations from the TS changes described in the TSTF-529 or the applicable parts of the NRC staffs safety evaluation dated April 21, 2016. These variations do not affect the applicability of TSTF-529 or the NRC staff's safety evaluation to the proposed license amendment.

A comma was added to the Fermi 2 TS 1.3 Completion Times DESCRIPTION. This variation is administrative and was added to make the Fermi 2 TS consistent with the Standard TS on which TSTF-529 is based. This variation does not affect the applicability of TSTF-529 to the Fermi 2 TS.

The Fermi 2 TS utilize different numbering and wording in LCO 3.8.1 than the Standard TS on which TSTF-529 was based. Specifically, Required Action A.2 in the Fermi 2 TS corresponds to Action B.2 in the STS and TSTF-529. In addition, the associated Completion Times uses the phrase discovery of an inoperable EDG instead of discovery of Condition B in the STS and TSTF-529. The new text added to TS 1.3 Completion Times DESCRIPTION which references LCO 3.8.1 is modified accordingly for consistency with these differences in numbering and wording. This variation is administrative and does not affect the applicability of TSTF-529 to the Fermi 2 TS.

to NRC-20-0038 Page 2 In addition to these variations associated with the TS changes, DTE is proposing the following variations from the TS Bases changes, which are for information only. These TS Bases variations do not affect the applicability of TSTF-529 or the NRC staff's safety evaluation to the proposed license amendment.

In the LCO 3.0.3 Bases, periods were replaced with commas for the termination and exit requirements, along with adding an or to the end of the next to last statement which says, A Condition exists for which the Required Actions have now been performed.

This variation is administrative and was added to make the Fermi 2 TS consistent with the Standard TS on which TSTF-529 is based. This variation does not affect the applicability of TSTF-529 to the Fermi 2 TS.

In the new text being added to LCO 3.0.4 and 3.0.5 Bases, trains was replaced with divisions to be consistent with the Fermi 2 TS definition of OPERABLE -

OPERABILITY and the terminology used in Section 1.3, Completion Times, of the Fermi 2 TS. This variation is administrative and does not affect the applicability of TSTF-529 to the Fermi 2 TS.

A mark-up of TS Bases LCO 3.0.4.c to change wording from (e.g., Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient) to (RCS Specific Activity) is not included. This change was previously incorporated into the Fermi 2 TS Bases. As identified in TSTF-529, omission of one or more changes is an acceptable variation.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis DTE requests adoption of TSTF-529, "Clarify Use and Application Rules," that is an approved change to the standard technical specifications (STS), into the Fermi 2 technical specifications (TS). The proposed change revises Section 1.3, "Completion Times," and Sections 3.0, "LCO Applicability" and "SR Applicability" of the Technical Specifications to clarify the use and application of the TS usage rules and revise the application of Surveillance Requirement (SR) 3.0.3. Section 1.3 is modified to clarify the concept of "discovery" that a Limiting Condition for Operation (LCO) is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

DTE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

to NRC-20-0038 Page 3

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

Response: No.

The proposed changes to Section 1.3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed changes does not significantly affect system Operability, the proposed change will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change to the TS usage rules does not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed if there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

to NRC-20-0038 Page 4 Based on the above, DTE concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

NRC-20-0038 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Proposed Technical Specifications Changes (Mark-Up)

Add Insert 1 here as a new paragraph with remaining text also moved to a new paragraph.

, unless otherwise specified.

Add a comma u

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION FERMI - UNIT 2 The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the :t4-Hle-

-&¥ discovery of a situation (e.g.* inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified. providing the uii it ;s iR a MODE or specified condition stated in the Applicability of t he tco. Required Actions must be completed prior to the expiration of the specified Completion Time.

An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a-single LCO (multiple Conditions). the Required Actions for each Condition must be performed within the associated Completion Time.

When in multiple Conditions. separate Completion Times are tracked for each Condition starting from the time gf discovery of the situation that required entry into the Conditiory Once a Condition has been entered. subsequent divis ns.

subsystems. components. or variables expressed in. e Condition. discovered to be inoperable or not with n imi s.

will not result in separate entry into the Conditi unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure. wi Completion Times based on initial entry into the Condition/

(continued) 1.3*1 Amendment No. 134

Insert 1 Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action A.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of an inoperable EDG concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

appropriate (exceptions to this Specification are stated in the individual Specifications); or V

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.4 When an LCO is not met, entry into a HOOE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIOUS to 0

be entered pennit continued operation in :ihe IDDE or other s~cified

• condition in the Applicability for an unlimited period of time:

b.

After ~rforrnance of a.risk assessment addressing ino~rable systems and components, consideration *of the results, determination of the acceptability of entering V

LCO 3.0.5 LCO 3.0.6 FERHI -*UNIT 2 HOOE *or other specified condition in the A~,

lity, "and establishment of risk management

~~e!f¥ieat10:PI:~t::tg~ ;::~~=i~~~i:d!~~s :

Spee;fieatieHs, er

c.

W'nen an allowance is.stated in the individual value, param~ter.* or 9ther Specification.

This spec1fication shall not prevent changes in MODES or other*sP.ecified conditions in the Applicability that are requireo to comply with ACTIONS or that are part of a shtitdC1n'll of the unit.

Equipment removed from service or declared inoperable to

• comply With ACTID~S may be returnetl to service unaer administrative control solely to perform testjng reguired to*

demonstrate its OPERABILm or the OPERABILITY of other eq1=Jipment. This 1s *an exceP.tion to LCO 3:0.2 for the system returned to service under aaministrative~contro1 to p~rform the testing required.to demonstrate OPERABILilY *..

• When a supported system LCD is not met solely due to a suppqrt system LCO not being met~ the*condit1ons and

• Reguired Actions*associated with this supported syst~m are not r~ired to be entered. Only the supPQrt system LCO ACTIONS are reguired to be *entered.* This is.an exception to LCD 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with

• S~cification 5.5.11, *safety Function Detennination Program (SFDP).

• If.a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety functiory exists are*required to be entered. *

(continued) 3.0*2 Amendment Ho. i'Jt, 163

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

SR 3.0.3 SR 3.0.4 FERMI - UNIT 2 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCD not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of specified Frequency, whichever is greater. This delay perio ermitted to allow performance of the Survei 11 anc A risk evaluation sha*ll be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period. the LCO must immediately be declared not met, and the applicable Condition{s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met. the LCO must immediately be declared not met. and the applicable Condition(s) must be entered.

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's j

Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3.

When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCD 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the I unit.

3.0-5 Amendment No. AM. Mt, 163

NRC-20-0038 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Revised Technical Specifications Pages

(continued)

FERMI - UNIT 2 1.3-1 Amendment No. 134 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered.

The otherwise specified exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, AC Sources - Operating, Required Action A.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of an inoperable EDG concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition

(continued)

FERMI - UNIT 2 1.3-1a Amendment No.

Completion Times 1.3 1.3 Completion Times DESCRIPTION remains in effect and the Required Actions apply until the (continued)

Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

(continued)

FERMI - UNIT 2 3.0-2 Amendment No. 134, 163 LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

FERMI - UNIT 2 3.0-5 Amendment No. 134, 145, 163 LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

NRC-20-0038 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Proposed Technical Specifications Bases Changes (Mark-Up) - Information Only

, unless otherwise specified LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCD) APPLICABILITY BASES LCOs LCO 3.0.1 LCO 3.0.2 FERMI

• UNIT 2 LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 establishes that upon scovery of a failure to meet an LCO, the associated ACT NS shall be met. The Completion Time of each Requir U Action for an ACTIONS Condition is applicable from e point in time that an ACTIONS Condition is entered The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a.

Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b.

Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions.

The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable.

(Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

The second type of Required Action specifies the B 3.0-1 Revision 42

enter BASES LCO Applicability 8 3.0 LCO 3.0.2 (continued)

LCO 3.0.3 FERMI - UNIT 2 When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable and the ACTIONS Condition(s) are entered.

LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a.

An associated Required Action and Completion Time is not met and no other Condition applies; or

b.

The condition of the unit is not specifically addressed by the associated ACTIONS.

This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering LCO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS.

It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.-

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with th~

load dispatcher to ensure the stability and availability of' the electrical grid.

The time limits specified to ~

lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities B 3.0-3 Revision O

b.

The LCO is no longer applicable, c

d entering entered enter entered entering enter Replace period with a comma Replace period with, or BASES LCO Applicability B 3.0 LCO 3.0.3 (continued) of the unit, assuming that only the minimum required equipment is OPERABLE.

This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies.

The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:

a.

The LCO is now met/I

~.

A Condition exists for which the Required Actions have

~.

now been performed/<

I I

ACTIONS exist that do not have expired Completion Times.

These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of LCO 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to.-----,

be in MODE 4 when a shutdown is required during MODE 1 operation.

If the unit is in a lower MODE of ope on when a shutdown is required, the time limit for the next lower MODE applies.

If a lower MODE is reaeheel~ n Jess time l I than allowed, the total allowable time to ODE 4, ur.

__ ___,_~

applicable MODE, is not reduced. For example,

• MODE ~

,eaehee in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for rea£htA§ MODE 3 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time c:::::7 foi>feaehiA§ MODE 3 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.

Therefore, if remedial measures are completed FERM1 - UNIT 2 that would permit a return to MODE 1, a penalty is not incurred by having t ~

a lower MODE of operation in less than th a time allowed.

ODES 1, 2, and 3, LCD 3.0.3 provides actions for Conditions not covered in other Specifications.

The requirements of LCD 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCD 3.0.3.

The requirements of LCD 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the B 3.0-4 Revision 0

either following entry into will permit continued operation within the MODE or other specified condition ACTIONS and the Required Actions followed after entry into the Applicability BASES LCD Applicability B 3.0 LCD 3.0.3 (continued)

LCD 3.0.4 D

FERMI

• UNIT 2 ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCD 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCD 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit.

An example of this is in LCD 3.7.7, "Spent Fuel Storage Pool Water Level."

LCD 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES.

If the LCO and the Required Actions of LCD 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCD 3.7.7 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCD 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCD is not met.

It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the

• ability desired to be entered) when unit conditions are sue the requirements of the LCO would not be met, in accordance w1 LCO 3.0.4.a, LCD 3.0.4.b, or LCO 3.0.4.c..

LCD 3.0.4.a allows entry into a MODE or other specified cOi,dilioA iA +be Applicability with the LCD not met when the associated ACTIONS to be er1Le,2~ permit £QAtiAYe~ e~eratioA

-i-A-the MODE or other specified condition in the Applic9biJj+~ for an unlimited period of time. Compliance wit Requires ActioAs that permit continued operation of the u

• for an unlimited period of time in a MODE or other pecified condition provides an acceptable level of safety for continued operation. This is without.regard to t~ e.-------

status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made

• 5eea1dfl11ee with the p1 evisio~s of the Requires ActioAs.

B 3.0-5 Revision 30

Add this new paragraph here.

For example, LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION

("Required Action and associated Completion Time not met") allows the OPERABLE division to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE division in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

BASES LCD Applicability B 3.0 LCD 3.0.4 (continued)

FERMI

• UNIT 2 LCD

.0.4.b allows entry into a MODE or other specified cond tion in the Applicability with the LCD not met after per ormance of a risk assessment addressing inoperable sys ems and components, consideration of the results, de rmination of the acceptability of entering the MODE or ot er specified condition in the Applicability, and es ablishment of risk management actions, if appropriate.

Te risk assessment may use quantitative, qualitative, or ended approaches, and the risk assessment will be onducted using the plant program, procedures, and criteria n place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCD 3.0.4 (b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qual~tative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCD would be met prior to the expiration of ACTIONS Completion Times that would require exiting t~e Applicability.

LCD 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

B 3.0-6 Revision 30

Add Insert 2 Examples are 1)

, or 2)

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or divisions previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

Add Insert 3 BASES LCO Applicability B 3.0 LCO 3.0.5 LCO 3.0.5 establishes the al1owance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS.

The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a.

• The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY.

This Specification does not provide time to perform any other preventive or corrective maintenance.

(

_I ___

At, e,~amr,le ef tlemenstFatiAg the OPE"RABILITY ef U1e eEJui13mer:1t eei fl§ rett:trAeEI te seF1/41i ee is ree13eni A§ a ceRt.ai r-imor-:it faol ati el'I *;alive t,19at 1'las aeer-1 el eseEI te eo~ly *..'itl:-1 R-tl<;Jbli rl<4 Aeti ens ans ffl1:mt se r:-eo13eRoe to 13@rfgrm th,;; rQq1 ti red test i 119.

,6,R *o*affi131e of demonstrating the OPERABILITY of other equi ~

i--s taking an inoperable channel or trip sys out L____L.----e-F-e_ rripped cond'

• to prevent the trip fu

• n from occurri n e performance of.. requi r esti ng on channel in the other trip system/

~..:i-*RH-1

• -El+!--E);4emi;;µ.Q..

ef seTHonstrati fl§ the OPE:RP,BI LIT¥ of ether 9Efbli ~ent i g tald fl§ aR i l'ler,ef'aal e ehaARel ep tf'i fJ systoffl eut ef the FE'I - UNIT 2

ri1313es eoRElitioA to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

B 3.0-9 Revision 55

Insert 2 LCO 3.0.5 should not be used in lieu of other practicable alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Insert 3 Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

FERMI - UNIT 2 B 3.0-22 Revision 73 SR Applicability 3.0 BASES SR 3.0.2 (continued) single Completion Time. One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

When a Section 5.5, Programs and Manuals, specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when the testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 specification).

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

performed perform performance

FERMI - UNIT 2 B 3.0-22a Revision 73 SR Applicability 3.0 BASES SR 3.0.3 (continued)

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance Add this new paragraph here.

SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact; the adjacent, physically connected relay contacts were tested during the SR performance; the subject relay contact has been tested by another SR; or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and equipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

repeatedly(

I I

,_