Text

Application for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process
	ML040980584
Person / Time
Site:	Fermi
Issue date:	04/01/2004
From:	O'Connor W; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-04-0005
	Download: ML040980584 (55)
	v • d • e

William T. O'Connor, Jr.

Vice President, Nuclear Generation Fermi 2 6400 North Dixie llHwy., Newport, Michigan 48166 Tel: 734-586-5201 Fax: 734-586-4172 DTE Energy April 1, 2004 NRC-04-0005 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

Reference:

Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Application for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, Detroit Edison hereby requests an amendment to the Technical Specifications (TS) for Fermi, Unit 2.

The proposed amendment would modify TS requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the existing TS Bases pages (for information only) marked up to show the proposed change.

Detroit Edison requests approval of the proposed License Amendment by September 30, 2004, with the amendment being implemented within the next 90 days.

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USNRC NRC-04-0005 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Michigan State Official.

If you should have any questions regarding this submittal, please contact Norman K.

Peterson at (734) 586-4258.

Sincerely, Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases (for information only) cc: M. A. Ring E. R. Duncan H. K. Chernoff D. P. Beaulieu NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-04-0005 Page 3 I, WILLIAM T. O'CONNOR, JR., do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

A2D@ V WILLIAM T. O'CONNOR, JR.

Vice President - Nuclear Generation On this day of Flipri ,2004 before me personally appeared William T. O'Connor, Jr., being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public

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KoIA r. PEMERSON WtArf PtLW MONROE 00, MI c ON WrC Ji 2 20 REMM S.-

.5- -p to NRC-04-0005 Page I ATTACHMENT 1 DESCRIPTION and ASSESSMENT

1.0 DESCRIPTION

The proposed changes would modify TS requirements for mode change limitations in LCO 3.0.4 and SR 3.0.4. The proposed change will allow mode changes with inoperable equipment unless an LCO 3.0.4 exemption note specifically excludes it. The current LCO 3.0.4 requirement is to ensure all LCO requirements are met prior to a mode change unless a specific LCO 3.0.4 exemption note exits.

The changes are consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications change TSTF-359, Revision 9 (Reference 1). TSTF-359, Revision 9 is the equivalent of TSTF-359, Revision 8 as modified by the notice in the Federal Register published on April 4, 2003 (Reference 2). That Federal Register notice announced the availability of this TS improvement through the Consolidated Line Item Improvement Process (CLIIP). The Federal Register notice also requires that plants adopting TSTF-359 have a TS Bases Control Program consistent with Section 5.5 of the Improved Standard Technical Specifications (ISTS), and the equivalent of ISTS SR 3.0.1 and associated bases. These provisions are not being adopted as part of this license amendment request because they are already contained in the Fermi 2 Technical Specifications and Bases.

2.0 ASSESSMENT 2.1 Applicabilitv of Published Safety Evaluation Detroit Edison has reviewed the safety evaluation dated April 4, 2003, as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-359 Revision 8, and included the updates made in TSTF-359, Revision 9. Detroit Edison has concluded that the justifications presented in the TSTF 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 Technical Specifications.

2.2 Optional Chan2es and Variations Detroit Edison is not proposing any variations or deviations from the TS changes described in the modified TSTF-359 Revision 8 and the NRC staffs model safety evaluation dated April 4, 2003.

However, due to minor differences between Fermi 2 TS/TS Bases and the model STS in NUREG-1433, Revision 2, Standard Technical Specifications, "General Electric Plants, to NRC-04-0005 Page 2 BWRI4", small variances from the TSTF mark-up changes are necessary. These variances are discussed below and do not affect the adoption or application of TSTF-359, Revision 9.

In the TSTF mark-ups, STS 3.3.6.3, "Low-Low Set (LLS) Instrumentation", the Note in Required Action B.1, which is the LCO 3.0.4 non-applicability Note, is deleted. The equivalent Fermi 2 Note is in Required Action B.3, and the same change is made.

In the TSTF mark-ups, STS 3.6.3. 1, "Primary Containment Hydrogen Recombiners", the Note is modified. Fermi 2 TS do not include this TS, so no changes are needed.

In the TSTF mark-ups, STS 3.6.3.2, "Drywell Cooling System Fans", the Note is modified.

Fermi 2 TS do not include this TS, so no changes are needed.

In the TSTF mark-ups, STS 3.6.3.4, "Containment Atmosphere Dilution System", the Note is modified. Fermi 2 TS do not include this TS, so no changes are needed

In the TSTF mark-ups, STS 3.7.3, "Diesel Generator (DG) Standby Service Water (SSW)

System", the Note in Required Action A.1, which is the LCO 3.0.4 non-applicability Note, is deleted. The equivalent TS for Fermi 2 is TS 3.7.8, "Emergency Diesel Generator Service Water (EDGSW) System", and does not contain an LCO 3.0.4 non-applicability Note, so no changes are needed.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Detroit Edison has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. Detroit Edison has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Fermi 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003, for this TS improvement, plant-specific verifications were performed as follows:

Detroit Edison has established TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before entering an associated mode or other specified condition in the TS Applicability.

to NRC-04-0005 Page 3 The modification also includes changes to the bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The bases changes describe in detail how: LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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; LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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; and LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), though it may be applied to other Specifications based on NRC plant-specific approval. The bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182. "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. In addition, the bases state that upon entry into a Mode or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry in to the applicable Conditions and Required Actions for no more than the duration of the applicable Completion Time or until the LCO is met or the unit is not within the Applicability of the TS. The bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

Finally, the Fermi 2 TSs have a bases control program consistent with Section 5.5 of the STS, and the equivalent of STS SR 3.0.1 and associated bases.

4.0 ENVIRONMENTAL EVALUATION Detroit Edison has reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003, as part of the CLTIP. Detroit Edison has concluded that the staffs findings presented in that evaluation are applicable to Fermi 2 and the evaluation is hereby incorporated by reference for this application.

5.0 REFERENCES

1. Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-359, Revision 9, Increase Flexibility in MODE Restraints.

to NRC-04-0005 Page 4

2. Federal Register, Volume 68, Number 65, Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process," dated April 4, 2003

ATTACHMENT 2 TO NRC-04-0005 Technical Specification Improvement Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.4 'hen an LCO is not met. entry into a MODE or other specifi con nin the Applicability shall not be made excep en the asso ted ACTIONS to be entered permit contin operation in e MODE or other specified condi in the Applicability fo n unlimited period of t . This Specification shall prevent change MODES or other Insert specified conditions in e Applic ity that are required to comply with ACTIONS or t part of a shutdown of the unit.

Exceptions to this fication are ed in the individual Sp cations.

LCO 3.0 only applicable for entry into a MO other spe 3 ed condition in the Applicability in MODES 1.

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.

(continued)

FERMI - UNIT 2 3.0-2 Amendment No. 134

INSERT 1 (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.

INSERT 2 (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.

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk I

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 into a MODE or other specified condition in the A ppli ~nit of an LCO shall not be made unless thl r' Surveillanc ye been met within their spec Frequency. Thi shall not peetetyit

.azsion MODES or other spec-if tWsnditiognth Apicability Insert 2 that are required to comply¢tAcin or that are part of a shutdown of the un SR 3.0.4 n y applicable for entry into a E or other s d condition in the Applicability in MODE and I

I FERMI - UN1IT 2 3.0-5 Amendment No. >4a,. ! i-,

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES I and 2.

ACTIONS NT--- NTE ---- -- --- -- --- -- --- -- --- --

a. LC- S.O B. 4 unt al, ~R.yu - .

X Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 "days with one required channel to OPERABLE, channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.7.

not met.

C. ---------NOTE ----- C.1 Restore one required 7 days Not applicable to channel to OPERABLE primary containment status.

hydrogen and primary containment oxygen concentration channels.

One or more Functions with two required channels inoperable.

(continued)

FERMI - UNIT 2 3.3-24 Amendment No. 134

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Division I Remote Shutdown System Functions in Table 3.3.3.2-1 shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

. . . .................... T-- ---- O~ .. . . . . . . ..................

1. LCO a.4 3 i4 Rot app44ea^l^.

Separate Condition entry is allowed for each function.

_ ........................................................................... I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days functions inoperable. function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associ ated Completion Time not met.

FERMI -UNIT 2 3.3-28 Amendment No. 134

LLS Instrumentation 3.3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. .-..-- NOTE.--: - B.1 Restore one tailpipe 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Separate Condition pressure switch for entry is allowed for 11 OPERABLE SRVs to each SRV. OPERABLE status.

AND One or more safety/

relief valves (SRVs) B.2 Restore one tailpipe 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with one or more pressure switch in Function 3 channel(s) each Division for an inoperable. OPERABLE SRV inthe lowest setpoint group, to OPERABLE status.

AND L.......... ....

B.3 Restore both tailpipe Prior to pressure switches for entering MODE 2 11 OPERABLE SRVs. or 3 from MODE 4 including 4 of 5 OPERABLE SRVs with the lowest relief setpoints. to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two LLS valves inoperable due to inoperable channels.

FERMI - UNIT 2 3.3-64 Amendment No. 134

RCS Leakage Detection Instrumentation

.3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Leakage Detection Instrumentation LCO 3.4.6 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump flow monitoring system:

b. The primary containment atmosphere gaseous radioactivity monitoring system channel; and

c. Drywell floor drain sump level monitoring system.

APPLICABILITY: MODES 1. 2. and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain A.1 Restore drywell floor 30 days sump flow monitoring drain sump flow system inoperable. monitoring system to OPERABLE status.

B. Required primary B.1 Analyze grab samples Once per containment atmosphere of primary 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months gaseous radioactivity containment monitoring system atmosphere.

inoperable.

(continued)

FERMI - UNIT 2 3.4-13 Amendment No. 134

RCS Specific Activity 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Specific Activity LCO 3.4.7 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity s 0.2 pCi/gm.

APPLICABILITY: MODE 1.

MODES 2 and 3 with any main steam line not isolated.

n rt 3 ACTIONS CONDITION REQUIRED ACTION / COMPLETION TIME A. Reactor coolant - - -- NOTE--- - ---

specific activity LCO 3.0. plicable.

> 0.2 pCi/gm and

4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT 1-131.

A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limits.

(continued)

FERMI - UNIT 2 3.4-16 Amendment No. 134

RHR Shutdown Cooling System- Hot Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES-

1. Both RHR shutdown cooling subsystems and recirculation pumps 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 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3. with reactor steam dome pressure less than the RHR cut in permissive pressure.

ACTIONS

.......................... .......... - -NOTEX ----------------------

I1. LLP! .0.6. i; 1.0b ppliceehc-

)$ Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CUNIIUN REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status.

AND (continued)

FERMI - UNIT 2 3.4-18 Amendment No. 134

ECCS -Operating

1) 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING KIMCC SYSTEM 3.5.1 ECCS-.Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1.

MODES 2 and 3. except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure s 150 psig. I l

-Insert 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. One LPCI pump in both B.1 Restore both LPCI 7 days LPCI subsystems pumps to OPERABLE inoperable. status.

C. One CSS subsystem C.1 Restore CSS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One LPCI subsystem C.2 Restore LPCI 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. subsystem to OPERABLE status.

(continued)

FERMI - UNIT 2 3.5-1 Amendment No. 134

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1.

MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS . .nse.t_

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to s 150 psig.

FERMI - UNIT 2 3.5-12 Amendment No. 134

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two emergency diesel generators (EDGs) per division.

APPLICABILITY: MODES 1. 2. and 3. I Insert 6 Il ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.- One or both EDGs in A.1 Perform SR 3.8.1.1 1 hour-one division , for OPERABLE offsite inoperable. circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter A.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s), supported discovery of an by the inoperable inoperable EDG EDGs. inoperable when concurrent with the redundant inoperability of required feature(s) redundant are inoperable. required feature(s)

AND A.3 Verify the status of Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CTG 11-1.

AND (continued)

FERMI - UNIT 2 3.8-1 Amendment No. 134

INSERT 3 (RCS SPECIFIC ACTIVITY)

-NOTE-LCO 3.0.4.c is applicable.

INSERT 4 (LCO 3.5.1, ECCS - OPERATING)

-NOTE-LCO 3.0.4.b is not applicable to HPCI.

INSERT 5 (LCO 3.5.3, RCIC SYSTEM)

-NOTE-LCO 3.0.4.b is not applicable to RCIC.

INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING)

-NOTE-LCO 3.0.4.b is not applicable to EDGs.

ATTACHMENT 3 TO NRC-04-0005 Technical Specification Improvement Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process PROPOSED TECHNICAL SPECIFICATION PAGES

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.

I 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.

(continued)

FERMI - UNIT 2 3.0-2 Amendment No. 38

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is'permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 Conditionfs)'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 not be made when the LCO's I 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.

I FERMI - UNIT 2 3.0-5 Amendment No. aAK .

XKA,

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

-- NOTE.-----------------------------------

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION'TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.7.

not met.

C. --------- NOTE ------- C.1 Restore one required 7 days Not applicable to channel to OPERABLE primary containment status.

hydrogen and primary containment oxygen concentration channels.

One or more Functions with two required channels inoperable.

(continued)

FERMI -UNIT 2 3.3-24 Amendment No. AK.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Division I Remote Shutdown System Functions in Table 3.3.3.2-1 shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

-NOTE -------- .......................-

Separate Condition entry is allowed for each function.

~~..... ........... ;.............................. ........................................ ........................................

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days functions inoperable. function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

FERMI - UNIT 2 3.3-28 Amendment No. Jar.

LLS Instrumentation 3.3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ----- NOTE ------- B.1 Restore one tailpipe 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Separate Condition pressure switch for entry is allowed for 11 OPERABLE SRVs to each SRV. OPERABLE status.

AND One or more safety/ B.2 Restore one tailpipe 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months relief-valves (SRVs). pressure switch in with one or more each Division for an Function 3 channel(s) OPERABLE SRV in the inoperable. lowest setpoint group, to OPERABLE status.

AND I

B.3 Restore both tailpipe Prior to pressure switches for entering MODE 2 11 OPERABLE SRVs. or 3 from MODE 4 including 4 of 5 OPERABLE SRVs with the lowest relief setpoints. to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND or B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two LLS-valves inoperable due to inoperable channels.

FERMI -UNIT 2 3.3-64 Amendment No. 1g%.

RCS Leakage Detection Instrumentation 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS 3.4.6 RCS Leakage Detection Instrumentation LCO 3.4.6 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump flow monitoring system;

b. The primary containment atmosphere gaseous radioactivity monitoring system channel; and

c. Drywell floor drain sump level monitoring system.

APPLICABILITY: MODES 1, 2. and 3.

ACTIONS I1.

CONDITION- REQUIRED ACTION COMPLETION TIME A. Drywell floor drain A.1 Restore drywell floor 30 days sump flow monitoring drain sump flow system inoperable. monitoring system to OPERABLE status.

B. Required primary B.1 Analyze grab samples Once per containment atmosphere of primary 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months gaseous radioactivity containment monitoring system atmosphere.

inoperable.

(continued)

FERMI - UNIT 2 3.4-13 Amendment No. All,#

RCS Specific Activity 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS 3.4.7 RCS Specific Activity LCO 3.4.7 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity S 0.2 pCi/gm.

APPLICABILITY: MODE 1.

MODES 2 and 3 with any main steam line not isolated.

ACTIONS CONDITION REQUIRED ACTION - COMPLETION TIME A. Reactor coolant ..............NOTE...........

specific activity LCO 3.0.4.c is applicable.

> 0.2 pCi/gm and .............................

< 4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT I-131 to within limits.

(continued)

-FERMI - UNIT-2 3.4-16 Amendment No. J,3.

RHR Shutdown Cooling System - Hot Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM CRCS 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System- Hot Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and,

-with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shal1 be in operation.

. NOTES-.,.

1. Both RHR shutdown cooling subsystems and recirculation pumps 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 per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may-be inoperable for up to 2-hours for the performance of Surveillances.

APPLICABILITY: MODE 3. with reactor steam dome pressure less than the RHR cut in permissive pressure.

ACTIONS

- ,,,,,,., ..... NOTE-........-....... '..

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status.

AND (continued)

FERMI - UNIT 2- 3.4-18 Amendment No. Add.

ECCS- Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS- Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1.

MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure s 150 psig.

ACTIONS

- ----------------------- NOTE -.............................

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. One LPCI pump in both B.1 Restore both LPCI 7 days LPCI subsystems pumps to OPERABLE inoperable. status.

C. One CSS subsystem C.1 Restore CSS subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. to OPERABLE status.

AND OR One LPCI subsystem C.2 Restore LPCI 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. subsystem to OPERABLE status.

(continued)

FERMI - UNIT 2 -3.5-1 Amendment No. AW.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1.

MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

. ....................... ........... NOTE ....................................

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days

.to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to s 150 psig.

FERMI - UNIT 2 3.5 12 Amendment No. AM,

AC Sources- Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources- Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two emergency diesel generators (EDGs) per division.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

- NOTE.

LCO 3.0.4.b is not applicable to EDGs.

CONDITION REQUIRED ACTION. COMPLETION TIME A. One or both EDGs in A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months one division for OPERABLE offsite inoperable. circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s). supported discovery of an by the inoperable inoperable EDG EDGs. inoperable when concurrent witth the redundant inoperability of required feature(s) redundant are inoperable., required feature(s)

AND A.3 Verify the status of Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months CTG 11-1.

AND (continued)

FERMI - UNIT 2 3.8-1 Amendment No. A44,

ATTACHMENT 4 TO NRC-04-0005 Technical Specification Improvement Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

(For Information Only)

LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)

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

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, "Spent Fuel Storage Pool Water Level." LCO 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 LCO 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 LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu-of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

[CO 3.0.4 CO 3.0.4 establishes limitations on changes in MODES or o er specified conditions in the Applicability when a CO is n met. It precludes placing the unit in a MODE r other cified condition stated in that ApplicabX ty (e.g., Ap icability desired to be entered) whe the following et:

a. Unit condi s are such that the quirements of the LCO would not met in the App ability desired to be entered; and

b. Continued noncomplian th the LCO requirements, if InserBthe Inse..A

^; ^..Applicability

_A-V;wer red, would result in the -l---

UnItL LIg1F1 rFquir LU tAIL Nit! iApp IILdUiIILY Ue Ire to be entered t omply with Required Actions.

Compliance with quired Actions that pe it continued operation-of e unit for an unlimited per d of time in a MODE or other specified condition provides an kcceptable level ofXafety for continued operation. This i without regar wo the status of the unit before or after t MODE chare. Therefore, in such cases, entry into a MODE'5t er specified condition in'the Applicability may be m e FERMI - UNIT 2 B 3.0 -5 Revision 0

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) in accordance with the provisions of the Required Actions.

e provisions-of this Specification should not be in erpreted as endorsing the failure to exercise the good pra tice of restoring systems or components to OPERABLE stat before entering an associated MODE or other spe fied conditon in the Applicability.

The prov ions of LCO 3.0.4 shall not prevent chan s in MODES or a her specified conditions in the Applic ility that are re uired to comply with ACTIONS. In a ition, the provisions o LCO 3.0.4 shall not prevent changs in MODES or other.speci ied conditions in the Applicabity that result from any unit shutdown.

Exceptions to LCO .0.4 are stated in the ndividual Specifications. Th exceptions allow enry into MODES or other specified cond tions in the ApplVability when the associated ACTIONS to e entered do n provide for continued operation for an unlimite period of time.

Exceptions may apply to 11 the AC ONS or to a specific Required Action of a Spec icatio LCO 3.0.4 is only applicable w n entering MODE 3 from MODE 4, MODE 2 from MODE 3 or , or MODE 1 from MODE 2.

Furthermore, LCO 3.0.4 is ap i able when entering any other specified condition in the ppli ability only while operating in MODE 1, 2,o 3. Th requirements of LCO 3.0.4 do not apply in MODES 4 nd 5, or i other specified conditions of the Appl ability (unl ss in MODE 1, 2, or 3) because the ACTIONS o individual spe ifications sufficiently define e remedial measu s to be taken. In some cases (none c rently in Fermi-2-Te hnical Specifications) t se ACTIONS provide a N te that states "While this LCO s not met, entry into a MOE or other specified conditon in the Applicability is ot permitted, unless requir .to comply with ACTIONS." Thi Note is a requirement xplicitly precluding entry into a ODE or other specified. ndition of the Applicability.

Surveill nces do not have to be performed on the a ociated inoper le equipment (or on variables outside the sp cified limit , as permitted by SR 3.0.1. Therefore, changi MODE or other specified conditions while in an ACTION Co ition, either in compliance with LCO 3.0.4 or where n e/ eption to LCO 3.0.4 is stated, is not a violation of FERMI - UNIT 2 B 3.0 -6 Revision 0

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) or S 3.04 for those Surveillances that have to b d due to the associatdfcral t b~se-tE~nsue OERABILITY equimen.Hoeve~t~~aw prior to declrn teDJftedsuimnOPRBLE (or variable withglr1)adrsoig5minc with the-a'f LCO 3.0.5 LCO 3.0.5 establishes the allowance 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.

An example of demonstrating the OPERABILITY ofthe equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing.

'An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on ,

-another channel in the other trip system. A similar example' of demonstrating.the.OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same tri~p system.

FERMI - UNIT 2 B 3.0- 7 Dott,;c; Ad n

INSERT BI (LCO 3.0.4 BASES)

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met 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.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in 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 LCO 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 qualitative 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 LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 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.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall .not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and

Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4, is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

SR Applicability 3.0 BASES SR 3.0.3 (continued) period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4

R 3.0.4 establishes the requirement that all applicable SRA st be met before entry into a MODE. or other specified co ition in the Applicability.

This ecification ensures that system and component OPERABI TY requirements and variable limits are m before entry intMODES or other specified conditions i the Applicabili for which these systems and comp ents ensure safe operati of the unit.

The provisions o this Specification shou not be interpreted as en rsing the failure to ercise the good practice of restori systems or compo nts to OPERABLE Insert B2 status before enterin an associated ODE or other specified condition in the Applic ility.

However, in certain circu anc , failing to meet an SR will not result in SR 3.0.4 tricting a MODE change or other specified condition c ge. When a system, subsystem, division, component, devic or ariable is inoperable or outside its specified li ts, the associated SR(s) are not required to be perform per SR 3. 1, which states that surveillances do not ave to be perf med on inoperable equipment. When eq pment is inoperab , SR 3.0.4 does not apply to the asso ated SR(s) since the equirement for the SR(s) to be perf rmed is removed. Theref e, failing to perform the Su eillance(s) within the spec ied Frequency does not res t in an SR 3.0.4 restriction to changing MODES or other s cified conditions of the Applicabi 'ty.

However,' ince the LCO is not met in this instan , LCO 3.0.4 w 1 govern any restrictions that may (or ma not) apply o MODE or other specified condition changes.

Th provisions of SR 3.0.4 shall not prevent changes in DES or other specified conditions in the Applicability FERMI - UNIT 2 B 3.0 - 15 Re~vision 0

SR Applicability 3.0 BASES SR 3.0.4 (continued) hat are required to comply with ACTIONS. In addition, th p visions of LCO 3.0.4 shall not prevent changes in MOD or shther specified conditions in the Applicability tha resu from any unit shutdown.

The prec e requirements for performance of SRs a specified uch that exceptions to SR 3.0.4 are t necessary. he specific time frames and cond ions necessary for eting the SRs are specified n the Frequency, in t Surveillance, or both. is allows performance of Su veillances when the prequisite condition(s) specified in a Surveillan procedure require entry into the MODE other specifi condition in the Applicability of the a ociated LC prior to the performance or completion of a Surveilance. Surveillance that could not be performed until af r entring the LCO Applicability would have its Frequency sp ied such that it is not "due" until the specific conditio eeded are met. Alternately, the Surveillance may be s ted *n the form of a Note as not required (to be met or p formed until a particular event, condition, or time has een reache Further discussion of the specific formats f SRs' annotaton is found in Section 1.4, Frequ cy.

SR 3.0.4 is oni applicable when entering ODE 3 from MODE 4, MODE from MODE 3 or 4, or MODE 1 om MODE 2.

Furthermore SR 3.0.4 is applicable when ente ing any other specified ondition in the Applicability only ile operati in MODE 1, 2, or 3. The requirements SR 3.0.4 do not/apply in MODES 4 and 5, or in other specifi d condiions of the Applicability (unless in MODE 1, or 3) be Wuse the ACTIONS of individual Specifications fficiently define the remedial measures to be taken.

FERMI - UNIT 2 B 3.0 - 16 Revision 0

I .SERT B2 (SR 3.0.4 BASES)

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a

Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

PAM Instrumentation B 3.3.3.1 BASES LCO (continued)

10. Primary Containment Isolation Valve (PCIV) Position PCIV position is a Type B, Category I variable, and is provided for verification of containment integrity. In the case of PCIV position, the important information'is the isolation status of the containment penetration. The LCO requires one channel of valve position indication in the control room to be OPERABLE for each active PCIV in a containment penetration flow path, i.e., two total channels of PCIV position indication for a penetration flow path with two active valves. For containment penetrations with only one control room indication, Note (b) requires a single channel of valve position indication to be OPERABLE. This is sufficient to redundantly verify the isolation status of each isolable penetration via indicated status of the active valve, as applicable, and prior knowledge of passive-valve or system boundary status. If a penetration flow path is isolated, position indication for the PCIV(s) in the associated penetration flow path is not needed to determine status. Therefore, the position indication for valves in an isolated penetration flow path is not required to be OPERABLE. The PCIV position PAM instrumentation consists of position switches, wiring, cabling, and control room indicating lamps for active PCIVs. Therefore, the PAM specification deals specifically with these instrument channels.

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2.

These variables are related to the diagnosis and preplanned actions required'to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS added to the ACTIONS to exclud en entry into the applica E relying on the ACTIONS even h the oACTIOp require plant shutdown. T <~ec~ion is acceptabrBda7 !_po the passive funtu>rEh isrmnts, the operator's aErey FERMI - UNIT 2 B 3.3.3.1 - 6 Revision 0

PAM Instrumentation B 3.3.3.1 BASES ACTIONS (continued) methds, nd he lmL~dM4JR~rt5f5Eeit requiring these A-Note;K has been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAN instrumentation channels provide appropriate compensatory measures for separate Functions. 'As such, a Note has been provided that allows'separate Condition entry for each inoperable PAM Function.

A.1 When-one or more Functions have one required channel that is inoperable, the required inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channels (or, in the case of a Function that has'only one required channel, other non-Regulatory Guide 1.97 instrument channels to monitor the Function), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval.

B.1 If a channel has nbt been restored to OPERABLE status in 30 days, this Required Action specifies initiation of action in accordance with Specification.5.6.7, which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions.

FERMI - UNIT 2 ,B3.3.3.1-7 Revision 0

Remote Shutdown System B 3.3.3.2 BASES APPLICABILITY (continued)

This LCO is not applicable in MODES 3, 4, and 5. In these MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the TS do not require OPERABILITY in MODES 3, 4, and 5.

ACTIONS ~ 1U ~isncluded that excludes the MODE change re on of LCO 3.0-,47 -Th4is_exception allows ent£LRrff applicable MODE while libb~>t 11IONS even though the ACTIONS may eventualLwr p~r ld-own. This exceptio ~sas~able due to the low pro a equiring this system.

.Note has been provided to modify the ACTIONS related to Remote Shutdown System Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown System Functions provide appropriate compensatory measures for separate Functions.

As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function.

A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System is inoperable. This includes any Function listed in Table 3.3.3.2-1.

The Required Action is to restore the Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

FERMI - UNIT 2 8 3.3.3.2 - 3 Revision 0

LLS Instrumentation B 3.3.6.3 BASES ACTIONS (continued) instrument channels inoperable. Therefore, it is acceptable for plant operation to continue provided that within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , per Required Action B.1 and B.2, verification and/or restoration is made to ensure at least: a) one tailpipe pressure switch in each Division OPERABLE on one OPERABLE SRV in the lowest SRV setpoint group; and b) at least 11 OPERABLE SRVs have at least one OPERABLE tailpipe pressure switch. Therefore, it is acceptable for plant operation to continue even with only one tailpipe pressure switch OPERABLE on each SRV. However, this is only acceptable provided each LLS valve is OPERABLE. (Refer to Required Action A.1 and C.1 Bases).

Required Action B.3 requires restoration of both tailpipe pressure switches on 2 11 OPERABLE SRVs, including 4 SRVs out of the 5 lowest relief setpoint OPERABLE SRVs, to OPERABLE status, prior to entering MODE 2 or 3 from MODE 4.

This will ensure that sufficient switches are OPERABLE at the beginning of a reactor startup (this is because the switches are not accessible during plant operation). The Required Actions do not allow placing the channel in trip since this action could result in an inadvertent LLS valve actuation. As nlted, LCO 3.0.4 is n -apHplicable, thus allcowing entry in~to MODE 1 or 2 fro MODE 2 or.3 with

&Io.perable channels. This allewanee is needed sinee the charnnels onily hav~e to be repaired prior to entering MODE 2

-o. 11ODE 3 Irom MODE 4.

A Note has been provided in the Condition to modify the Required Actions and Completion Times conventions related to LLS Function 3 channels. Section 1.3, Completion Times, specifies that 'once a Condition has been ente'red, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable br not within limits.' will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition 'continue to apply for each additional failure, with Completion Times based on initial entry into

.the Condition. However, the Required Actions for inoperable LLS Function 3 channels provide appropriate compensatory measures for separate inoperable Cond1ition entry for each SRV with inoperable tailpipe pressure switches.

FERMI - UNIT 2 B 3.3.6.3 -5 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES LCO The drywell floor drain sump flow monitoring system is required to quantify the unidentified LEAKAGE from the RCS.

The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded.

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4.

ACTIONS TIONS are modified by a Note that states that tih-provsiSsvsLC 3..4 are not applicable. jksa-eifsuit, a NODE change is ati when one or two eif-primary containment sump flow m i em, primary containment atmosphere gaseous radi itoring system, and the drywell floor d rf plvlmon t fz~ustem are inoperab is allowance is provided becau er ntation is available to monitor RCS leakage ALL With the drywell floor drain sump flow monitoring system inoperable, the plant has lost one means to quantify leakage. However, the primary containment atmosphere gaseous radioactivity monitoring system and the drywell floor drain sump level monitoring system will provide indication of changes in leakage.

With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (SR 3.4.4.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is-acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available.

FERMI - UNIT 2 B 3.4.6 -3 -Revision 0

A note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry RCS Specific Activity into the applicable MODE(S) while relying B3.4.7 on the ACTIONS.

BASES ACTIONS (cont nued)

Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to

\take and analyze a sample. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to

\restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems.

AMNuL to Lthe Re ed Actio s of Co11dition1 A exoludes the MODE change restcton of LCO 3.0.4. This cxeption allows entry into thc, prrcable HIODE(S) wdhile relying en the ACTIONS even though the ACTIONS may evcntually r.quirc plant

-shutdowwn ieis usEeetHen is acceptable due to the

__s4d11n-lt conservatism incorporated into the specific allowance activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation.

B.1. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to s 0.2 pCl/gm within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if at any time it is > 4.0 pCi/gm, it must be determined at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and all the main-steam lines must be isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident.

Alternatively, the plant can be placed in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads).

In MODE 4, the requirements of the LCO are no longer applicable.

The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the time needed to take and analyze a sample. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

FERMI - UNIT 2 B 3.4.7 -3 Revision 0

RHR Shutdown Cooling System -Hot Shutdown B 3.4.8 BASES APPLICABILITY (continued) the steam in the main condenser. Additionally, in MODE 2 below this pressure, the OPERABILITY requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS-Operating') do not allow placing the RHR shutdown cooling subsystem into operation.

The requirements for decay heat removal in MODE 4 are discussed in LCO 3.4.9, "Residual Heat Removal (RHR)

Shutdown Cooling System-Cold Shutdown"; and for MODE 5 are discussed in LCO 3.9.7, "Residual Heat Removal (RHR) -High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)- Low Water Level."

ACTIONS to the ACTIONS excludes the MODE change'restri of ICO-3 . L This exception allows entry into aplcbl O~t>~ile relying on theSfE en though the ACTIONS may eve l~~requiru3E- shutdown. This exception is acceptabe du redundancy of the OPERABLE sub ytmJ4r~ow P. sSS atwich the plant is operating, t probability of an even rring during opera0in this condition, and the availabilit ernate methods of decay heat removal capability.

A efto4 ote has been provided to modify the ACTIONS rela'tedto RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on-initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

FERMI - UNIT 2 B 3.4.8-3 Revision 0

ECCS - Operating B 3.5.1 BASES APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is & 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS -Shutdown."

ACTIONS A.I If any one low pressure ECCS injection/spray subsystem is Insert B3 inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide'adequate core cooling during a LOCA. However, overall 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. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.I If one LPCI pump in both LPCI subsystems is inoperable, both inoperable pumps must be restored to OPERABLE status within

.7days. (Note the first inoperable LPCI pump resulted in entry into Condition A, and will require restoration within 7 days of entry into *Condition A, which may be more restrictive than the requirements of Required Action B.1.)

In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA, even assuming an additional single failure, however, overall ECCS reliability is reduced. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability,- assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function FERMI - UNIT 2 B 3.5 .1- 6 Revision 0

RCIC System B 3.5.3 BASES ACTIONS A.1 and A.2 If the RCIC System is inoperable during MODE 1,- or MODE 2 or'3 with reactor steam dome pressure > 150.psig, and the Insert B4 HPCI System isverified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified immediately when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be verified, however, Condition B must be immediately entered. For transients and certain abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status.

The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e., Completion Times) determined for HPCI are also applied to RCIC.

B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition 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 reactor steam dome pressure reduced to s 150 psig 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 plant conditions from full power conditions in an

.orderly manner and without challenging plant systems.

FERMI - UNIT 2 B 3.5.3 -3 Revision 0

AC Sources - Operating B 3.8.1 BASES AA .

ACT IONS To ensure a highly reliable power source remains with one or both EDGs in one division inoperable, it is necessary to verify the availability of the OPERABLE offsite circuits on Insert B5 a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met.

However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must'then be entered.

A.2 Required Action A.2 is intended to provide assurance that a loss of offsite power, during the period that one or both EDGs in one division is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included).

Redundant'required features failures consist of inoperable features associated with a division redundant to the division that has an inoperable EDG.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

In this Required Action the Completion Time only begins on discovery that both:

a. An inoperable EDG exists; and

b. A required feature on the other division (Division 1 or 2) that is redundant to a feature supported by the inoperable EDG(s) is inoperable. -

If, at any time during the existence of this Condition (one or both EDGs in one division inoperable), a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering one required EDG inoperable coincident with one or more inoperable redundant required support or supported features, or both, that are associated with the OPERABLE EDGs results in starting the Completion Time for the Required Action. Four hours from the discovery of these FERMI - UNIT 2 B 3.'8.1 -5 Revision .0

INSERT B3 (LCO 3.5.1, ECCS - OPERATING)

A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

INSERT B4 (LCO 3.5.3, RCIC SYSTEM)

A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

INSERT B5 (LCO 3.8.1, AC SOURCES - OPERATING)

A Note prohibits the application of LCO 3.0.4.b to an inoperable EDG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable EDG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

NRC-04-0005, Application for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

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NRC-04-0005, Application for Technical Specification Change Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

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Subject:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

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