NRC-23-0002, License Amendment Request to Revise Technical Specification 3.8.1, AC Sources - Operating, Surveillance Requirement SR 3.8.1.12

License Amendment Request to Revise Technical Specification 3.8.1, AC Sources - Operating, Surveillance Requirement SR 3.8.1.12

ML23128A017
Person / Time
Site:	Fermi
Issue date:	05/05/2023
From:	Peter Dietrich DTE Electric Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-23-0002
Download: ML23128A017 (1)

Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Email: peter.dietrich@dteenergy.com DTE May 5, 2023 10 CFR 50.59 NRC-23-0002 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:

License Amendment Request to Revise Technical Specification 3.8.1, AC Sources - Operating, Surveillance Requirement SR 3.8.1.12 Pursuant to 10 CFR 50.90, DTE Electric Company (DTE) hereby proposes to amend the Fermi Unit 2 Plant Operating License, Appendix A, Technical Specifications (TS) to revise Surveillance Requirement (SR) 3.8.1.12 in TS 3.8.1, "AC Sources - Operating." Specifically, the proposed amendment would add a requirement to verify the crankcase overpressure automatic trip for each emergency diesel generator (EDG) is bypassed on an actual or simulated emergency start signal. to this letter includes a description and assessment of the proposed change including an analysis of the significant hazards considerations using the standards of 10 CFR 50.92. DTE has concluded that the changes proposed herein do not result in a significant hazards consideration. Enclosure 2 provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages.

Approval of the proposed amendment is requested within 90 days of the submittal of this License Amendment Request to allow timely implementation of a modification that eliminates a potential design vulnerability with the Emergency Diesel Generators. Once approved, the amendment shall be implemented within 6 months.

This submittal contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Mr. Eric Frank, Manager - Nuclear Licensing, at (734) 586-4772.

USNRC NRC-23-0002 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 5, 2023 Peter Dietrich Senior Vice President and Chief Nuclear Officer

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages cc: NRC Project Manager NRC Resident Office Regional Administrator, Region III Michigan Department of Environment, Great Lakes, and Energy

Enclosure 1 to NRC-23-0002 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 3.8.1, AC Sources -

Operating, Surveillance Requirement SR 3.8.1.12 Description and Assessment to NRC-23-0002 Page 2

1.0 DESCRIPTION

The proposed amendment revises Surveillance Requirement (SR) 3.8.1.12 in Technical Specification (TS) 3.8.1, "AC Sources - Operating." Specifically, the proposed amendment would add a requirement to verify the crankcase overpressure automatic trip for each Emergency Diesel Generator (EDG) is bypassed on an actual or simulated emergency start signal. The proposed change will ensure surveillance testing of the bypassed automatic trip is performed consistent with other existing bypassed non-essential EDG protective trips.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The EDGs are described in UFSAR Sections 8.3 and 9.5. The onsite standby power source at Fermi Unit 2 (Fermi 2) consists of four EDGs separated into two independent divisions; Division I includes EDG 11 and EDG 12, and Division II includes EDG 13 and EDG 14.

Either divisional pair of diesel generator units is capable of supplying loads needed to safely shutdown the reactor and maintain it in a safe shutdown condition after a Design Basis Accident (DBA). The EDGs are located in the Residual Heat Removal (RHR) Complex, which is a Category I structure.

All EDGs start automatically on a Loss of Coolant Accident (LOCA) signal or on an Engineered Safety Feature (ESF) bus degraded voltage or undervoltage signal. After an EDG has started, it automatically connects to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with a LOCA signal. The EDGs also start and operate in the standby mode without connecting to the ESF bus on a LOCA signal alone. Following the trip of offsite power, load shed relays strip nonpermanent loads from the ESF bus. When the EDG is tied to the ESF bus, safety-related loads are then sequentially connected to its respective ESF bus by the automatic sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the EDG.

In the event of a loss of normal power, the ESF electrical loads are automatically connected to the EDGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a DBA such as a LOCA.

When the EDGs are operating in parallel with offsite power, several protective relay functions are used to protect both the generator and engine. These trips are listed in UFSAR Table 8.3-12 for both the test condition and emergency condition. Under conditions that cause pickup of the emergency start relays, all of the trip circuits are blocked, with the exception of overspeed trip, generator differential, low lube-oil pressure, crankcase overpressure, and start failure trip. The low lube-oil pressure and crankcase overpressure trips are each connected in a two-out-of-three logic (one out of three causes an alarm only).

Although there is one start failure relay, once the engine is started, either the low speed or running speed relays will inhibit initiation of the start failure relay.

to NRC-23-0002 Page 3 There are two emergency start relays: either of these relays will initiate EDG starting as well as bypass the unnecessary trips. All of the bypassed trip circuits still retain their alarm function to alert the operator to an abnormal condition. Since the trip bypass is achieved with the emergency start relays, the bypass circuitry is directly monitored by the annunciator position "EDG - Auto Start."

Surveillance tests on the emergency start relays are performed in accordance with TS 3.8.1 to test the status and operability of the bypass circuits. The EDG logic is designed so that the non-emergency trip relay is automatically reset by the emergency start signal.

(Non-emergency trips are those other than the emergency-mode trips described above.) This feature prevents the inadvertent lockout of an EDG during standby by a false or real non-emergency-mode trip. The SRs for demonstrating EDG operability are based on the recommendations of Regulatory Guide 1.9 (Reference 1), Regulatory Guide 1.108 (Reference 2), and Regulatory Guide 1.137 (Reference 3), as addressed in the Fermi 2 UFSAR 8.3 2.2 Current Technical Specification Requirements Presently, Technical Specification (TS) 3.8.1, "AC Sources - Operating, includes the following SR:

SR 3.8.1.12 Verify each EDG's automatic trips are bypassed on an actual or simulated emergency start signal except:

a. Engine overspeed;

b. Generator differential current;

c. Low lube oil pressure;

d. Crankcase overpressure; and

e. Failure to start.

The surveillance frequency is in accordance with the Surveillance Frequency Control Program.

2.3 Reason for the Proposed Change During the 2022 Design Basis Assurance Inspection (DBAI), the NRC identified that during a Loss of Off-Site Power (LOOP) in conjunction with a tornado event, the Emergency Diesel Generators (EDGs) could trip on a high crankcase pressure (Reference 4). During a tornado, the atmospheric pressure inside the RHR complex could drop faster than the internal pressure of the associated EDG crankcases, which in turn would cause a high crankcase differential pressure trip of the EDGs.

The current design of the EDGs and the exciter include automatic and manual trips to protect the EDG from various abnormal conditions. The exciter is tripped off to prevent damage to the excitation system as the engine slows down following a trip. The automatic trips are divided into two categories: essential and non-essential trips. Non-essential trips are inhibited when the EDGs are running in the emergency mode to prevent an undesired EDG shutdown during a to NRC-23-0002 Page 4 LOCA or LOOP. Within the current design, one of the essential trips of the EDGs is high crankcase pressure. During any mode of operation, the EDG will trip on high crankcase pressure to prevent crankcase explosion and catastrophic damage to the diesel engine.

Information was requested from the EDG vendor (Fairbanks Morse Engine,) and it was concluded that the crankcase ejector system includes an orifice (3/16 nominal) that limits the depressurization rate of the EDG crankcase. Furthermore, the EDG rooms in the RHR Complex are equipped with gravity dampers that open to vent the air out of the engine room and rapidly depressurize the building in the event of a tornado. Based on this information, the crankcase high pressure trip would be activated if the EDG were running prior to a depressurization of the RHR complex.

Therefore, DTE is performing a modification for Fermi 2 that will change the high crankcase pressure trip from an essential trip to a non-essential trip for all four EDGs 11, 12, 13, and 14.

This will ensure that during an emergency run (such as during a LOOP and tornado event), the EDG will not trip on high crankcase pressure and all essential loads fed from the EDGs will remain powered. The existing Main Control Room alarm for Crankcase Pressure High will be maintained. The associated annunciator response procedures for each EDG will be revised to reflect the change.

The physical modifications that will change the EDG high crankcase pressure trip from an essential trip to a non-essential trip were reviewed for potential effects on the affected EDG and other plant structures, systems, and components under the 10 CFR 50.59 process in support of the engineering design package. However, the proposed change to SR 3.8.1.12 is required to verify that, after implementation of the modification on each EDG, the high crankcase pressure trip is bypassed on an actual or simulated emergency start signal in accordance with the Surveillance Frequency Control Program.

2.4 Description of the Proposed Change The proposed change is to revise Surveillance Requirement (SR) 3.8.1.12 by deleting current exception d. Crankcase overpressure. The revised SR will read as follows:

SR 3.8.1.12 Verify each EDG's automatic trips are bypassed on an actual or simulated emergency start signal except:

a. Engine overspeed;

b. Generator differential current;

c. Low lube oil pressure; and

d. Failure to start. provides the existing TS pages marked to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. There are no required changes to the TS Bases.

to NRC-23-0002 Page 5

3.0 TECHNICAL EVALUATION

The proposed change to TS SR 3.8.1.12 will ensure verification that the high crankcase pressure trip is bypassed on an actual or simulated emergency start signal and that this is performed for EDGs 11, 12, 13, and 14 in accordance with the Surveillance Frequency Control Program. The proposed trip bypass verification is the same type of verification that is applied to other non-essential protective EDG trips per SR 3.8.1.12. The surveillance frequency applied will be the same as that of the other verifications performed per SR 3.8.1.12.

The purpose of this EDG protective trip is to minimize engine degradation as the result of failure modes that may cause high crankcase pressure. The EDG manufacturer, Fairbanks Morse Engine, has identified five failure modes which could result in high crankcase pressure.

Any one of these failure modes could occur from a random single failure mechanism. These failure modes are:

1. Broken piston rings;

2. Cracked pistons;

3. Blower seal failure;

4. Liner water seal failure; and,

5. Failed crankcase vacuum system These failure modes have different outcomes. Although uncommon in the industry, the first four modes of failure could lead to further internal engine component failure, if allowed to go unchecked by an automatic trip, such as the high crankcase pressure trip. In the current configuration, the common effect of these failure modes would be an increase in crankcase pressure and engine shutdown from two-out-of-three crankcase pressure switch logic. However, by the time any of these four failure modes would activate a high crankcase pressure trip, significant damage to the affected engine would have already occurred requiring a lengthy repair process. As such, the EDG out-of-service time is not significantly affected by blocking the high crankcase pressure trip for the first four failure modes. Furthermore, it has been determined that allowing an EDG to operate in a high crankcase pressure condition would not increase the possibility of failure of any of the three unaffected EDGs.

The fifth mode of failure, failed crankcase vacuum system, is the most common and does not lead to immediate engine degradation. Therefore, in the current configuration, the effect of a crankcase vacuum system failure would be an unnecessary EDG shutdown in Emergency mode, resulting in a failure of the EDG to perform its safety-related function.

Regulatory Guide 1.9, Rev. 2 (Reference 1), provides design guidance for handling of diesel generator protective trips. Fermi 2 has not committed to this regulatory guide, however, the plant does conform to it with exceptions, as described in UFSAR Appendix A.1.9 (Reference 9). Regulatory Position C.7 indicates that, while certain trips (such as generator differential trip) must operate immediately in order to prevent substantial damage to the EDG, it is important to prevent needless shutdown as a result of spurious operation of a non-essential trip circuit.

Institute of Electronic and Electrical Engineers (IEEE) Standard 387-1977, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power to NRC-23-0002 Page 6 Generating Stations," as augmented by Regulatory Guide 1.9, provides guidance for bypassing EDG protective trips during emergency conditions. Regulatory Position C.7 states that trips may be bypassed under accident conditions provided that the operator has sufficient time to react appropriately to an abnormal EDG condition.

Bypass of the crankcase high pressure trip during EDG operation in the emergency mode is supported by the Fairbanks Morse Owners Group (FMOG). The trip will continue to be utilized for operation in the manual (test) mode. A high crankcase pressure is annunciated in the Main Control Room which alerts the operators of the abnormal crankcase condition. Plant procedures currently include monitoring of EDG protective trips that are bypassed when operating in the emergency mode. In the event of an engine malfunction in which the EDG crankcase pressure reaches the alarm setpoint, operators would be alerted of the condition by annunciation in the Main Control Room and at the local control panel. Local indication is available to monitor the high crankcase pressure condition. Plant operating procedures instruct the operators to monitor certain EDG parameters when an emergency start signal is present. A precaution will be added for monitoring high crankcase pressure conditions as part of the modification process. This will ensure the operator has sufficient time to react appropriately to this condition.

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

10 CFR 50.36, Technical Specifications, establishes regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2) states, in part, Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. In addition, 10 CFR 50.36(c)(3) states, Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met.

The proposed change to the EDG SR does not affect compliance with these regulations.

The applicable 10 CFR Part 50, Appendix A, General Design Criteria, was considered as follows:

Criterion 18 - Inspection and Testing of Electrical Power Systems. Electrical power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The system shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems to NRC-23-0002 Page 7 sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

Regulatory Guide 1.9, Revision 2 - Selection, Design, and Qualification of Diesel-Generator Units Used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants, was considered as follows:

Regulatory Position C.7, states: Section 5.6.2.2, "Automatic Control," of IEEE Std 387-1977 (Reference 10) pertains to automatic startup requirements and their relationship to other operating modes. In conjunction with Section 5.6.2.2, engine-overspeed and generator-differential trips may be implemented by a single-channel trip.

All other diesel-generator protective trips should be handled in one of two ways: Either, (1) a trip should be implemented with two or more independent measurements for each trip parameter with coincident logic provisions for trip actuation, or (2) a trip may be bypassed under accident conditions, provided the operator has sufficient time to react appropriately to an abnormal diesel-generator unit condition. The design of the bypass circuitry should satisfy the requirements of IEEE Std 279-1971 (Reference 11) at the diesel-generator system level and should include the capability for (1) testing the status and operability of the bypass circuits, (2) alarming in the control room abnormal values of all bypass parameters, and (3) manually resetting of the trip bypass function.

(Capability for automatic reset is not acceptable.)

The proposed change is consistent with Criterion 18 and Regulatory Guide 1.9 Rev. 2, Position C.7.

4.2 Precedent It is common industry practice to bypass non-essential EDG protective trips in accordance with Regulatory Guide 1.9, including the crankcase high pressure trip, for emergency mode operation. The potential for inadvertent EDG trip or lockout due to tornado depressurization has been previously identified by the NRC at other nuclear power plants, as well.

As an example, Calvert Cliffs Nuclear Power Plant Units 1 & 2 bypass the crankcase high pressure trip on an automatic EDG start (References 5, 6, 7, and 8). The TS SRs include verification that the trip is bypassed.

4.3 No Significant Hazards Consideration Analysis DTE Electric Company (DTE) requests an amendment to the Technical Specifications (TS) for Fermi Unit 2 (i.e., Appendix A, Technical Specifications of Renewed Facility Operating License NPF-43). DTE proposes to revise TS Surveillance Requirement (SR) 3.8.1.12 as described in Section 2.0 above. This proposed amendment would add a requirement to TS SR 3.8.1.12 to verify the crankcase overpressure automatic trip for each emergency diesel generator (EDG) is bypassed on an actual or simulated emergency start signal. The associated TS Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).

to NRC-23-0002 Page 8 TS Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).

DTE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92(c),

Issuance of amendment, as discussed below:

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

Response: No.

The proposed change revises a TS surveillance requirement (SR) for each emergency diesel generator (EDG). The EDG automatic trips bypass circuitry is required for EDG operability and reliability during emergency operation of the EDG. The SR test frequency will continue to assure that the EDG will perform as required. Performance of SRs is not an initiator of any accident previously evaluated. As a result, the proposed change has no effect on the probability of any accident previously evaluated.

The proposed TS SR change adds the high crankcase pressure trip as one of the EDG trips verified to be bypassed during emergency operation. A high crankcase pressure condition on one EDG will not impact either of the three unaffected EDGs, or any other equipment required to mitigate accident consequences, and satisfies the single failure criteria. The EDG manufacturer concurs with the proposed change to bypass this trip during emergency operation. The proposed change does not alter or prevent the capability of structures, systems, and components to perform their intended function to mitigate the consequences of an initiating event within the assumed applicable acceptance limits.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The function of the EDGs is to provide power to ESF and safe shutdown equipment for events invoking a loss of offsite power. The proposed change revises a TS SR for each EDG to verify bypass of the high crankcase pressure trip during emergency operation.

The proposed change will not alter the design function or operability requirements of the EDGs. Each EDG must be capable of performing the safety functions assumed in the accident analysis or the EDG is declared inoperable, and the associated TS Required Actions are followed. The proposed change does not create new failure mechanisms, malfunctions, or accident initiators or a new or different kind of accident not previously evaluated or included in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different to NRC-23-0002 Page 9

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

Response: No.

The proposed change revises a TS SR for each EDG. The proposed change does not adversely affect plant safety margins or the reliability of the EDGs or other equipment assumed to operate in the safety analyses. Bypass of the high crankcase pressure trip during emergency operation will reduce the likelihood of unnecessary shutdown. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The margins associated with the safety analyses and applicable acceptance criteria are not impacted.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, DTE concludes that the proposed amendment does not involve a 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.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL EVALUATION The proposed amendment 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 amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment 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 amendment.

to NRC-23-0002 Page 10

6.0 REFERENCES

1. Regulatory Guide 1.9, Revision 2, Selection, Design, and Qualification of Diesel-Generator Units Used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants, December 1979.

2. Regulatory Guide 1.108, Revision 1, Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants, August 1977.

3. Regulatory Guide 1.137, Revision 1, Fuel-Oil Systems for Standby Diesel Generators, October 1979.

4. Letter from Karla K. Stoedter (U. S. Nuclear Regulatory Commission) to Peter Dietrich (DTE Electric Company), " Fermi Power Plant, Unit 2 - Design Basis Assurance Inspection (Teams) Inspection Report 05000341/2022010," dated November 9, 2022 (ADAMS Accession No. ML22313A103).

5. Calvert Cliffs Nuclear Power Plant Units 1 & 2, License Amendment Request; Emergency Diesel Generator Crankcase High Pressure Trip, dated August 1994 (ADAMS Accession No. ML20149E832).

6. Letter from Daniel G. McDonald (NRC) to Robert E. Denton ( Baltimore Gas and Electric Company) to Calvert Cliffs Nuclear Power Plant, Issuance of Amendments for Calvert Cliffs Nuclear Power Plant, Unit No. 1 (TAC No. M90122) And Unit No. 2 (TAC No.

M90123), March 3, 1995 (ADAMS Accession No. ML010580036).

7. Calvert Cliffs Nuclear Power Plant, Technical Specification Bases Units 1 & 2, Rev. 76 (ADAMS Accession No. ML21278A297).

8. Calvert Cliffs Nuclear Power Plant Units 1 & 2, UFSAR Section 8.4, Rev. 47 (ADAMS Accession No. ML21278A201).

9. Fermi 2 UFSAR, Revision 24 (ADAMS Accession No ML22313A186)

10. IEEE 387-1977 - IEEE Standard: Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations

11. IEEE 279-1971- IEEE Standard: Criteria for Protection Systems for Nuclear Power Generating Stations

Enclosure 2 to NRC-23-0002 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 3.8.1, AC Sources -

Operating, Surveillance Requirement SR 3.8.1.12 Proposed Technical Specification Changes (Mark-Up)

Note: TS Page 3.8-6 is also revised under separate previously submitted LAR NRC-22-0026 (ML22350A504). There is no impact to the previously submitted LAR TS Changes.

AC Sources-Operating 3.8.1 SURVEILLANCE REQUIREMENTS (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 In accordance Core Cooling System (ECCS) initiation with the signal each EOG auto-starts and: Surveillance Frequency

a. Ins 10 seconds after auto-start and Control Program during tests, achieves voltage

~ 3950 V and frequency~ 58.8 Hz;

b. Achieves steady state voltage~ 3950 V ands 4580 V, and frequency~ 58.8 Hz ands 61.2 Hz: and

c. Operates for~ 5 minutes.

SR 3.8.1.12 Verify each EDG's automatic trips are In accordance bypassed on an actual or simulated with the emergency start signal except: Surveillance Frequency

a. Engine overspeed: Control Program

b. Generator differential current; C. low lube oil pressure; and

d. Crankcase overpressure: and d e. Failure to start.

(continued)

FERMI

• UNIT 2 3.8-6 Amendment No. !.ff. 178 -lSJ, 201

Enclosure 3 to NRC-23-0002 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specification 3.8.1, AC Sources

- Operating, Surveillance Requirement SR 3.8.1.12 Revised Technical Specification Pages

AC Sources Operating 3.8.1 SURVEILLANCE REQUIREMENTS (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 In accordance Core Cooling System (ECCS) initiation with the signal each EDG auto-starts and: Surveillance Frequency

a. In 10 seconds after auto-start and Control Program during tests, achieves voltage 3950 V and frequency 58.8 Hz;

b. Achieves steady state voltage 3950 V and 4580 V, and frequency 58.8 Hz and 61.2 Hz; and

c. Operates for 5 minutes.

SR 3.8.1.12 Verify each EDG's automatic trips are In accordance bypassed on an actual or simulated with the emergency start signal except: Surveillance Frequency

a. Engine overspeed; Control Program

b. Generator differential current;

c. Low lube oil pressure; and

d. Failure to start.

(continued)

FERMI - UNIT 2 3.8-6 Amendment No. 134, 178, 183, 201