Text

Revision to License Amendment Request to Revise Technical Specification 3.3.6.1, Primary Containment Isolation Instrumentation.
	ML060380522
Person / Time
Site:	Fermi
Issue date:	01/31/2006
From:	Cobb D; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-06-0001
	Download: ML060380522 (34)
	v • d • e

Donald K. Cobb Assistant Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, MI 48166 Tel: 734.586.5201 Fax: 734.586.4172 DTE Energy January 31, 2006 10 CFR 50.90 NRC-06-0001 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

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

2) Detroit Edison Letter to NRC "Proposed License Amendment to Revise Technical Specification 3.3.6.1, "Primary Containment Isolation Instrumentation,"" NRC-04-0006, dated March 19, 2004.

3) Detroit Edison Letter to NRC "Revision to License Amendment Request to Revise Technical Specification 3.3.6.1, "Primary Containment Isolation Instrumentation,"" NRC-05-0016, dated March 17, 2005.

Subject:

Revision to License Amendment Request to Revise Technical Specification 3.3.6.1, "Primary Containment Isolation Instrumentation" Pursuant to 10 CFR 50.90, Detroit Edison hereby requests the following amendment.

This submittal replaces Reference 3 in its entirety and incorporates Detroit Edison's September 8, November 7, November 28, and December 13, 2005 telephone discussions with the Fermi 2 NRC Project Manager. Accordingly, Detroit Edison requests that our Reference 3 submittal be withdrawn.

The proposed change addresses an inconsistency that was inadvertently introduced during conversion to Improved Technical Specifications when "1 per room" replaced "2" as the Required Channels per Trip System for the Reactor Water Cleanup Area Ventilation Differential Temperature - High isolation function. This inaccuracy in the Technical Specifications was introduced during conversion to the Improved Technical Specifications.

Detroit Edison requests approval of the proposed License Amendment by April 30, 2006, with the amendment being; implemented within 90 days following approval.

Mb DD I

USNRC NRC-06-0001 Page 2 contains an evaluation, including a significant hazards consideration, of the proposed change.

Enclosure:

2 contains a copy of the existing Technical Specification (TS) pages marked up to show the proposed change. Enclosure 3 contains a copy of the proposed revised TS pages. Enclosure 4 provides marked up pages of the existing TS Bases showing the proposed changes (for information only).

There are no new regulatory commitments associated with this proposed change.

Detroit Edison has reviewed the proposed change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor does it significantly change the types or significantly increase the amounts of effluents that may be released offsite. The proposed change does not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed change meets the criteria provided in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

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

If you have any questions regarding this submittal, please contact Ronald W. Gaston at (734) 586-5197.

Sincerely D. K. Cobb Assistant Vice President Nuclear Generation

Enclosures:

1. Fermi 2 Nuclear Power Plant Evaluation for License Amendment Request

2. Proposed Technical Specification Change (Mark-Up)

3. Proposed Technical Specification Revised Page

4. Marked up pages of the existing TS Bases showing the proposed changes (for information only) cc: D. H. Jaffe T. J. Kozak NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-06-0001 Page 3 I, Donald K. Cobb, 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.

D. K. Cobb Assistant Vice President Nuclear Generation On this _ _ _ day of , 2006 before me personally appeared Donald K. Cobb, being firsf-uly sworn d says that he executed the foregoing as his free act and deed.

Notary Public ROSALIE ARVIMA NOTARY PUBLIC MONROE CO, N MY COMMISSION EXPIRES Oct 11, 2007

ENCLOSURE 1 to NRC-06-0001 FERMI 2 NUCLEAR POWER PLANT EVALUATION FOR LICENSE AMENDMENT REQUEST

FERMI 2 NUCLEAR POWER PLANT EVALUATION

SUBJECT:

Revise Technical Specification (TS) 3.3.6.1, "Primary Containment Isolation Instrumentation."

1. DESCRIPTION

2. PROPOSED CHANGE

3. BACKGROUND

4. TECHNICAL ANALYSIS

5. REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements / Criteria

6. ENVIRONMENTAL CONSIDERATION

7. REFERENCES to NRC-06-0001 Page 2

1.0 DESCRIPTION

The proposed change would:

Add a note to Condition B of Technical Specification (TS) 3.3.6.1, "Primary Containment Isolation Instrumentation," stating "With a Table 3.3.6.1-1 Function 5.c channel inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room."

Modify Surveillance Requirements Notes by splitting Note 2.b. The new Note 2.b will continue to address Reactor Water Cleanup (RWCU) components for Function 5, (other than non-redundant circuitry of Function 5.a), and contains a new statement: "6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5.c provided Function 5.b is OPERABLE in the affected room;." A new Note 2.c continues to provide 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for surveillance testing for Functions 1, 2, and 6, provided the associated Function maintains isolation capability. The current Note 2.c is renumbered as 2.d.

Modify TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation," Function 5.c, Reactor Water Cleanup Area Ventilation Differential Temperature - High by replacing "1 per room" with "1 per room (d)" for the Required Channels Per Trip System.

Add note (d) to TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation,"

explaining: "For Function 5.c, Reactor Water Cleanup System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room". This note clarifies that the Fermi 2 design has only 1 trip system for each Function 5.c room.

As a result of the change inadvertently introduced during the conversion to Improved Technical Specifications (ITS), the actions specified by TS 3.3.6.1, "Primary Containment Isolation Instrumentation," for RWCU Area Ventilation Differential Temperature - High, are inconsistent with other RWCU isolation instruments listed in TS Table 3.3.6.1-1. Administrative controls have been put in place using the guidance provided in NRC Administrative Letter 98-10, "Dispositioning Of Technical Specifications That Are Insufficient To Assure Plant Safety." The administrative controls ensure that actions consistent with the intent of TS 3.3.6.1 will be taken until implementation of this amendment request.

2.0 PROPOSED CHANGE

The proposed change will restore consistency between the installed RWCU Area Ventilation Differential Temperature - High instrumentation and TS Table 3.3.6.1-1, accurately reflecting the number of installed instruments. The proposed change:

Ensures, during surveillance testing and normal operation, there will always be at least one instrument monitoring for a small leak in all RWCU locations.

Enclosure 1 to NRC-06-0001 Page 3

Allows an inoperable RWCU Area Ventilation Differential Temperature - High instrument a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with Condition A of TS 3.3.6.1.

3.0 BACKGROUND

The RWCU system is classified as a power conversion subsystem and is designed to 1) maintain the reactor coolant chemistry within TS limits; 2) conserve thermal energy during removal and return of reactor coolant to the pressure vessel; 3) remove excess reactor coolant during various operational phases; 4) serve, in part, as a reactor coolant pressure boundary; and 5) provide a containment isolation function. Only the latter two functions are directly related to safety.

The major RWCU system equipment is located within the secondary containment and external to the primary containment. Because the system processes high energy and high activity coolant, the system components are located in shielded, separated rooms or areas. Each area is ventilated by the Reactor Building Heating, Ventilation and Air Conditioning (RBHVAC) system whose discharge is through radiation monitored reactor building ventilation stack. The ventilation stack is automatically isolated by a high radiation signal.

The RWCU system is designed for continuous, controlled removal of reactor coolant from the reactor recirculation system piping. The RWCU system inlet connects to both the reactor recirculation system piping and the bottom of the reactor vessel. After passing through an inboard and outboard primary containment isolation valve, suction flow is driven by parallel motor driven pumps which discharge to the regenerative heat exchangers. From there the flow is routed to the nonregenerative heat exchangers, and parallel filter demineralizers. It is returned to the feedwater piping via the shell side of the regenerative heat exchangers, a motor-operated primary containment isolation valve, and check valves.

Automatic isolation of the RWCU system is provided to meet the safety related requirements for primary containment isolation. The two RWCU suction isolation valves and one RWCU return isolation valve are closed on signal from the Primary Containment Isolation System (PCIS),

which are triggered by reactor water level (level 2). During an accident, closure of these valves assures that 1) primary coolant pressure boundary is maintained and losses of reactor coolant are limited; and 2) the release of radioactivity from the primary containment is limited.

Additional automatic isolation capability is provided as non-safety related, and serves to limit RWCU system leakage of radioactive reactor coolant outside the primary containment. This in turn limits local contamination, high radiation and high temperature environments in equipment areas (Reference 4). These include isolations on Differential Flow - High, Area Temperature -

High, and Area Ventilation Differential Temperature - High. Although not specifically required by NRC regulations, the differential temperature monitoring was originally recommended for relatively small leak detection in small volume compartments.

to NRC-06-0001 Page 4 The RWCU isolation logic at Fermi 2 is designed to meet IEEE Std 279-1971, "Criteria for Protection Systems for Nuclear Power Stations." The degree of conformance to IEEE-279-1971 is described in Topical Report NEDO-10139, "Compliance of Protection Systems to Industry Criteria: General Electric BWR Nuclear Steam Supply System."

In NEDO-10139, Figure 4-13, the Functional Control Diagram for the RWCU System shows the isolation control logic. The figure differentiates between the safeguards and non-safeguards inputs for isolation signals. Reactor Low Water Level is a safeguards input designated Signal Code 8 and uses a fail safe one-out-of-two-taken-twice logic. The non-safeguards inputs are Standby Liquid Control (SLC) initiation (no Signal Code specified), and the RWCU System Area Temperature - High, Area Ventilation Differential Temperature - High, and RWCU Differential Flow - High, designated Signal Code 1. For Signal Code 1, combining of the three different Leakage Detection System (LDS) signals is (lone by redundant relay logic on valve control circuits for each isolation valve. Per NEDO-.10139, Section 4.1.2.1, this is so a single signal failure or a single trip logic failure can be tolerated without loss of the isolation function. The Area Temperature - High and Area Ventilation Differential Temperature - High signals work in tandem to initiate containment isolation and are not required to be redundant for each isolation valve.

At Fermi 2, the RWCU LDS consists of the RWCU system isolations on Differential Flow -

High, Area Temperature - High, and Area Ventilation Differential Temperature - High. The temperature based RWCU LDS is designed based on an assumed leakage equivalent to the allowable leakage inside containment as established in the TSs (Reference 4). The combining of the three RWCU LDS signals is done by a redundant relay logic on valve control circuits for each of the isolation valves. The isolation logic deenergizes to operate. Exceeding differential flow, any area temperature or any area ventilation differential temperature causes isolation of the RWCU system.

to NRC-06-0001 Page 5 Summary of RWCU LDS Relay Logic Inboard and Outboard isolation valves each have a total of 8 temperature isolations and one differential flow isolation. All three leak detection signals are combined into two redundant, deenergize to trip (fail safe) isolation logics. An isolation of the RWCU system can be accomplished by actuation of either trip system logic.

I 1 Differential Flow-High contact I I I I I Summary of RWCU Isolation Logic RWCU Isolation Safeguards Non-Safeguards Isolation Signal _

Water Level Low X Sensors (channels) and relay

_logic are redundant SLC X Isolates only 1 valve (outboard),

_ _ no redundancy LDS X Sensors (channels) are non-redundant,

_ _ Relay logic is redundant The Area Temperature - High channels are located in six areas with two detectors in each area.

One of the two detectors is part of the inboard valve isolation logic and one is part of the outboard valve isolation logic. Actuation of either inboard or outboard isolation logic is sufficient to isolate the RWCU system. High temperature in a single area will cause both the inboard and outboard isolation valves to close by actuating both detection channels for that area.

The Area Ventilation Differential Temperature - High channels are located in four rooms with one detector in each room. Two rooms are part of the inboard isolation logic and two rooms are to NRC-06-0001 Page 6 part of the outboard isolation logic. A high differential temperature in a single room will cause either the RWCU isolation inboard valve or outboard isolation valves to close.

Both the RWCU Area Ventilation Differential Temperature - High and the RWCU Area Temperature - High primary containment isolation instrumentation are provided to detect a leak from the RWCU system. The RWCU Area Ventilation Differential Temperature - High and RWCU Area Temperature - High isolation signals are redundant and diverse to the high differential flow instrumentation for the hot portions of the RWCU system.

Twelve thermocouples provide input to the RWCU Area Temperature - High Function (two per area). Eight thermocouples provide input to the RWCU Area Ventilation Differential Temperature - High Function. Two thermocouples are required for each differential temperature channel, one each in the inlet and outlet of the room cooling systems, for a total of four channels (one channel per room). Fermi 2 RWCU Area Ventilation Differential Temperature - High instrumentation is non-redundant at the channel level due to having one channel per room.

Fermi 2 has diversity in its RWCU temperature isolation instrumentation in that Area Ventilation Differential Temperature - High and the RWCU Area Temperature - High monitor for a small leak in the same rooms. The reliability of the RWCU system isolation function remains high even in the presence of single or multiple failures of differential temperature channels because of redundancy and diversity of the LDS. A steam leak will cause a coincidental trip of both the differential and ambient temperature channels in the same area.

x Enclosure 1 to NRC-06-0001 Page 7 LDS Isolation Sensor (Channel) Comparison RWCU Spaces RWCU A RWCU B RWCU RWCU Torus Trench Total Pump Pump HX Phase Room Piping Sensors Room Room Room Sep Area Area (Channels)

(North) (South) Room No. of Temperature- 2 2 2 2 2 2 12 High Channels Isolation signal Inboard Inboard Inboard Inboard Inboard Inboard to: & & & & & &

Outboard Outboard Outboard Outboard Outboard Outboard No. of Ventilation Differential 1 I 1 1 0 0 4 Temperature-High Channels _

Isolation signal Inboard Inboard to: Outboard _ Outboard Summary of RWCU LDS Isolation Signal Redundancy to NRC-06-0001 Page 8

4.0 TECHNICAL ANALYSIS

The proposed license amendment adds a note to Condition B of Technical Specification (TS) 3.3.6.1, "Primary Containment Isolation Instrumentation," stating "With a Table 3.3.6.1-1 Function 5.c channel inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room." This allows a single inoperable Area Ventilation Differential Temperature - High instrument to use Condition A, providing a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months action statement.

The proposed license amendment modifies the TS 3.3.6.1 Surveillance Requirements Notes by splitting Note 2.b. The new Note 2.b will continue to address Reactor Water Cleanup (RWCU) components for Function 5, (other than non-redundant circuitry of Function 5.a), and contains a new statement: "6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5.c provided Function 5.b is OPERABLE in the affected room;." A new Note 2.c continues to provide 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for surveillance testing for Functions 1, 2, and 6, provided the associated Function maintains isolation capability.

The proposed license amendment adds note (d) to TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation," explaining: "For Function 5.c, Reactor Water Cleanup System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room". This note clarifies that the Fermi 2 design has only 1 Area Ventilation Differential Temperature - High trip system for each room.

The change that prompted this proposed license amendment was introduced during TS Amendment No. 134, which implemented the ITS (TAC NO. MA1465). In Table A, Administrative Changes to Current Technical Specifications, of the NRC Safety Evaluation (ITS Section 3.3.6.1, A.13), the change from "2" to "1 per room" was described as an administrative change to better specify the number of channels for each trip system. This change was made to match the nomenclature used in the NRC Improved Standard Technical Specifications (ISTS) and to specify the number of instruments per room.

The Fermi 2 TS Bases for the RWCU Area Ventilation Differential Temperature - High isolation Function were revised during conversion to ITS. The changes were made to reflect the plant specific instrumentation at Fermi. The Bases acknowledge that there are a total of four Area Differential Temperature - High monitors for RWCU, one per room.

The Fermi 2 design for the RWCU Area Ventilation Differential Temperature - High isolation Function does not match the design used in the NRC ISTS and this change to the number of Required Channels Per Trip System created an inconsistency. Fermi 2 is designed with one differential temperature monitor per room as opposed to the NRC ISTS format of two differential temperature monitors per room. The Fermi 2 design for the RWCU Area Ventilation Differential Temperature - High isolation Function is described in a License Amendment Request (Reference

3) dated December 22, 1988, subsequently issued to Fermi 2 as TS Amendment No. 41 (TAC NO. 72759).

to NRC-06-0001 Page 9 TS Amendment No. 41 revised the RWCU Area Temperature - High isolation instrumentation by adding a second instrument to all areas monitored. This plant modification provided redundancy for the RWCU Area Temperature - High isolation Function in order to be used as isolation for a RWCU High Energy Line Break scenario. Prior to this, the RWCU Area Temperature - High isolation Function was one instrument per area, similar to the RWCU Area Ventilation Differential Temperature - High instruments.

The proposed changes acknowledge that the Fermi 2 design has four RWCU Area Ventilation Differential Temperature - High instruments and provides a completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for an inoperable instrument per Condition A of TS 3.3.6.1. This is accomplished by the addition of a note to Condition B stating "With a Table 3.3.6.1-1, Function 5.c channel inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room."

TS 3.3.6.1 Surveillance Requirements Note 2.b is modified to address surveillance requirements for RWCU Area Ventilation Differential Temperature - High instruments. The addition of note (d) to TS Table 3.3.6.1-1 clarifies the number of RWCU Area Ventilation Differential Temperature - High instruments available to be 1 per room. The RWCU Area Ventilation Differential Temperature - High instrumentation has only 1 trip system per room.

In summary, the proposed change to TS 3.3. 6.1 Condition B and RWCU Area Ventilation Differential Temperature - High isolation, Function 5.c of TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation," restores the TS to be consistent with the Fermi 2 design and ensures redundant channels are maintained in all RWCU locations in order to maintain isolation capability during surveillance testing and normal operation.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Detroit Edison 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, "Issuance of amendment," as described 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 clarifies the requirement to maintain isolation capability for the RW'CU Area Ventilation Differential Temperature -

High isolation instrumentation by addition of a note to TS 3.3.6.1 Condition B, modification of TS 3.3.6.1 Surveillance Requirements Notes, and by clarifying the number of instruments required to be available to NRC-06-0001 Page 10 in TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation,"

Function 5.c, by the addition of note (d). This ensures, during surveillance testing and normal operation, there will always be at least one instrument monitoring for a small leak in all RWCU locations. No changes in operating practices or physical plant equipment are created as a result of this change. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed change clarifies the requirement to maintain isolation capability for the RWCU Area Ventilation Differential Temperature -

High isolation instrumentation by addition-of a note to TS 3.3.6.1 Condition B, modification of TS 3.3.6.1 Surveillance Requirements Notes, and by clarifying the number of instruments required to be available in TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation,"

Function 5.c, by the addition of note (d). This ensures, during surveillance testing and normal operation, there will always be at least one instrument monitoring for a small leak in all RWCU locations. No physical change in plant equipment will result from this proposed change. Therefore, the proposed change does not create the possibility of a new or different type of accident from any previously evaluated.

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

Response: No.

The proposed change clarifies the requirement to maintain isolation capability for the RWCU Area Ventilation Differential Temperature -

High isolation instrumentation by addition of a note to TS 3.3.6.1 Condition B, modification of TS 3.3.6.1 Surveillance Requirements Notes, and by clarifying the number of instruments required to be available in TS Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation,"

Function 5.c, by the addition of note (d). This ensures, during surveillance testing and normal operation, there will always be at least one instrument monitoring for a small leak in all RWCU locations. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

to NRC-06-0001 Page 11 5.2 Applicable Regulatory Requirements / Criteria The proposed changes address an inconsistency that was inadvertently introduced during implementation of the [TS. The proposed changes have no impact on regulatory requirements or regulatory criteria.

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 adversely affect the common defense and security or the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

Detroit Edison has reviewed the proposed change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor does it significantly change the types or significantly increase the amounts of effluents that may be released offsite. The proposed change does not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed change meets the criteria provided in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

7.0 REF17ERENCES

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

2. Detroit Edison Letter to NRC "Proposed License Amendment to Revise Technical Specification 3.3.6.1, "Primary Containment Isolation Instrumentation,'"' NRC-04-0006, dated March 19, 2004.

3. Letter to NRC: NRC-88-0279, "Proposed Technical Specification Change (License Amendment) - Isolation Actuation Instrumentation (3/4.3.2)," dated December 22, 1988.

4. AEODINRC Engineering Evaluation Report, "RWCU System Automatic Isolation and Safety Considerations (AEOD/E705)," dated March 1987.

ENCLOSURE 2 to NRC-06-0001 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARK-UP)

INCLUDED PAGE:

TS 3.3-50 TS 3.3-53 TS 3.3-58

Primary Containment Isolation Instrumentation I 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.6.1-1.

ACTIONS

............................... NOTE Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for channels inoperable. trip. Functions 1.f.

2.a, 2.c, and 6.b AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Functions other than Functions 1.f. 2.a. 2.c.

and 6.b PI 1

B. One or e automatic B.1 Restore isolation 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Functions 'th capability.

isolation cap ility not maintained.

Note--------------- (continued)

With a Table 3.3.6.1-1 Function 5.c channel inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room FERMI - UNIT 2 3.3-50 Amendment No. 134

Primary Containment IsolatiOn Instrumentation 3.3.6.1

b. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5 (other than non-redundant circuitry of 5.a)

(provided the associated Function maintains isolation capability. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5.c provided Function 5.b is OPERABLE in the affected room; ...... ..........

each Primary

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to::

a. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Function 5.a when testing non-redundant circuitry that results in loss of isolation capability associated with this

,s Function, provided Functions 5.b. 5.c. and 5.e are OPERABLE:

c .be 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1. 2.-i; (other than non -e-ndainircuitrfy-of-

5. a. and 6. provided the associated Function maintains isolation capability: and d z, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Functions 3 and 4. provided the associated Function maintains isolation capabilil:y.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Verify the trip unit setpoint. 92 days SR 3.3.6.1.4 Perform CHANNEL CAL.IBRATION. 18 months SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months SR 3.3.6.1.6 Perform CHANNEL FUNCTIONAL TEST. 18 months (continued)

FERMI - UNIT 2 3.3-53 Amendment No. 134

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 4 of 4)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS NODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

5. Reactor Water Cleanup (RWCU) System Isolation

a. Differential 1.2.3 1 F SR 3.3.6.1.1 5 63.4 gpm Flow - High SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Area 1.2.3 1 per SR 3.3.6.1.1 s 183F Temperature - High area SR 3.3.6.1.2 SR 3.3.6.1.4 (d) SR3.3.6.1.5

c. Area Ventilation 1.2.3 1 per SR 3.3.6.1.1 s 53'F Differential room SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.4 SR 3.3.6.1.5

d. SLC System Initiation 1.2 2 (b) SR 3 .3.6.1.5 NA

e. Reactor Vessel Water 1.2.3 2 F SR 3.3.6.1.1 x 103.8 inches Level - Low Low. SR 3.3.6.1.2 Level 2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

f. Manual Initiation 1.2.3 1ver G SR 3.3.6.1.6 NA va ve

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1.2.3 1 F SR 3.3.6.1.1 ' 95.5 psig Pressure - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Reactor Vessel Water 3.4.5 2(c) J SR 3.3.6. 1.1 & 171.9 inches Level - Low. Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

c. Manual Initiation 1.2.3 G SR 3.3.6.1.6 NA 9a ve (b) SLC System Initiation only inputs into one of the two trip systems.

(c) Only one trip system required in NODES 4 and 5 when RHR Shutdown Cooling System integrity maintained.

(d) For Function 5.c, Reactor Water Cleanup (RWCU) System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room.

FERMI - UNIT 2 3.3 -58 Amendment No. 134

ENCLOSURE 3 to NRC-06-0001 PROPOSED TECHNICAL SPECIFICATION REVISED PAGE INCLUDED PAGE:

TS 3.3-50 TS 3.3-53 TS 3.3-58

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.6.1-1.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for channels inoperable. trip. Functions 1.f, 2.a, 2.c, and 6.b AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Functions other than Functions 1.f, 2.a, 2.c, and 6.b

NOTE-----------

With a Table 3.3.6.1-1 B.1 Restore isolation 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Function 5.c channel capability.

inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room.

B. One or more automatic Functions with isolation capability not maintained.

(continued)

FERMI - UNIT 2 3.3-50 Amendment No. AA,

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

NOTES------------------..........

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to:

a. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for Function 5.a when testing non-redundant circuitry that results in loss of isolation capability associated with this Function, provided Functions 5.b, 5.c, and 5.e are OPERABLE;

b. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Function 5 (other than non-redundant circuitry of 5.a) provided the associated Function maintains isolation ca a ility.

hours for Function 5.c provided Function 5.b is OPERABLE in the affected room;

c. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 1, 2, and 6, provided the associated Function maintains isolation capability; and

d. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Functions 3 and 4, provided the associated Function maintains isolation capability.

SURVEILLANCE: FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Verify the trip unit setpoint. 92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months SR 3.3.6.1.6 Perform CHANNEL FUNCTIONAL TEST. 18 months (continued)

FERMI -UNIT 2 3.3-53 Amendment No. Ad

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 4 of 4)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

5. Reactor Water Cleanup (RWCU) System Isolation

a. Differential 1,2.3 1 F SR 3.3.6.1.1 S 63.4 gpm Flow - High SR 3.3.6.1.2 SR 3,3.6.1.4 SR 3.3.6.1.5

b. Area Temperature - 1.2.3 1 per F SR 3.3.6.1.1 5 1830 F High area SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5

c. Area Ventilation 1.2.3 1 per (d) F SR 3.3.6.1.1 s 530F Differential room SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.4 SR 3.3.6.1.5

d. SLC System Initiation 1.2 2 (b) I SR 3.3.6.1.5 NA

e. Reactor Vessel Water 1.2.3 2 F SR 3.3.6.1.1 2 103.8 inches Level - Low Low, SR 3.3.6.1.2 Level 2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

f. Manual Initiation 1.2,3 G SR 3.3.6.1.6 NA

6. Shutdown Cooling System Isolation

a. Reactor Steam Dome 1.2.3 1 F SR 3.3.6.1.1 s 95.5 psig Pressure - High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

b. Reactor Vessel Water 3.4.5 2(c) J SR 3.3.6.1.1 2 171.9 inches Level - Low, Level 3 SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5

c. Manual Initiation 1.2.3 1 prr G SR 3.3.6.1.6 NA valve (b) SLC System Initiation only inputs into one of the two trip systems.

(c) Only one trip system required in MODES 4 and 5 when RHR Shutdown Cooling System integrity maintained.

(d) For Function 5.c. Reactor Water Cleanup (RWCU) System Isolation, Area Ventilation Differential Temperature - High, the required channels is 1 per room.

FERMI - UNIT 2 3.3-58 Amendment No. AX4,

ENCLOSURE 4 to NRC-06-0001 PROPOSED TECHNICAL S]PECIFICATION BASES CHANGES (FOR INFORMATION ONLY)

INCLUDED PAGES:

B .3.3.6.1- 1 B .3.3.6.1- 4 B .3.3.6.1-19 B .33.6.1-24 B .3.3.6.1-25 B .3.3.6.1-29 B ;3.3.6.1-32

Primary Containment Isolation Instrumentation B 3.3.6.1 B 3.3 INSTRUMENTATION B 3.3.6.1 Primary Containment Isolation Instrumentation BASES BACKGROUND The primary containment isolation instrumentation automatically initiates closure of appropriate primary containment isolation valves (PCIVs). The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (OBAs). Primary containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.

The isolation instrumentation includes the sensors, relays, and switches that are necessary to cause initiation of primary containment and reactor coolant pressure boundary (RCPB) isolation. Most channels include electronic equipment (e.g., trip units) that compares measured input signals with pre-established setpoints. When the setpoint is exceeded, the channel output relay actuates, which then outputs a primary containment isolation signal to the isolation logic. Functional diversity is provided by monitoring a wide range of independent parameters. The input parameters to the isolation logics are (a) reactor vessel water level, (b) area ambient and differential temperatures, (c)main steam line (MSL) flow and radiation, (d) Standby Liquid Control (SLC) System initiation, (e) condenser pressure, (f)main steam line pressure, (g) high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) steam line flow, (h) drywell pressure, (i) HPCI and RCIC steam line pressure, (j) HPCI and RCIC turbine exhaust diaphragm pressure, (k) reactor water cleanup (RWCU) differential flow, and (1) reactor steam dome pressure. Redundant sensor input signals from each parameter are typically provided for initiation of isolation. The only exceptions are SLC System initiation and RWCU differential flow. In addition, manual isolation of the valves is provided.

Primary containment isolation instrumentation has inpu 0to the trip logic of the isolation functions listed bel

, RWCU differential temperature FERMI - UNIT 2 B 3.3.6.1- 1 Revision 0

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES BACKGROUND (continued) and Drywell Pressure-High Functions. These Functions receive inputs from four turbine exhaust diaphragm pressure and four steam supply pressure channels for each system.

The outputs from the turbine exhaust diaphragm pressure and steam supply pressure channels are each connected to two two-out-of-two trip systems. Each trip system isolates one valve per associated penetration.

HPCI and RCIC Functions isolate the HPCI and RCIC isolation valves.

5. Reactor Water Cleanup System Isolation The Reactor Vessel Water Level -Low Low, Level 2 Isolation Function receives input from four reactor vessel water level channels. The outputs from the reactor vessel water level channels are connected into two two-out-of-two trip systems.

The Differential Flow-High function is derived from three non-redundant flow transmitters and a non-redundant flow summer. The output of the summer is fed to two trip units, the outputs of which are channeled through relays into two trip systems. One trip system isolates the inboard isolation valve, while the other trip system isolates the two outboard isolation valves.

SLC System Initiation Functions receive input from two channels, with each channel in one trip system using a one-out-of-one logic. Both channels are only input to the trip systems that isolates the outboard isolation valves.

The Area Temperature -High Function receives input from twelve temperature monitors, six to each trip system. The Area Ventilation Differential Temperature -High Function receives input from four differential temperature monitors, two in each trip system. These are configured so that any one input will trip the associated trip system. One of the two trip systems is connected to the inboard valve and the other trip system is connected to the two outboard valves on each RWCU penetration.

Insert 1 -e RWCU Functions isolate the RWCU isolation valves.

FERMI - UNIT 2 B 3.3.6.1- 4 Revision 0

Insert 1 The Area Temperature-High, and Area Ventilation Differential Temperature-High, Functions act together to provide protection from small leaks in the monitored areas and rooms of the RWCU system.

Primary Containment Isolation Instrumentation B 3.3.6.1 Area Ventilation Differential Temperature-High BASES Ax APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

The Differential Flow-High Allowable Value ensures hat break of the RWCU piping is detected.

This Function isolates the RWCU isolation valves.

5.b.. 5.c. Area and Area Ventilation Differential Temperature - Hi gh RWlJ an. and apea ventilation difforontial temperatures are Area TerTperature-High rovided to detect a leak from the RWCU System. The isolation occurs even when very small leaks have occurred and is diverse to th 4ih diferential flo-instrumentation for the hot portio of the RWCU System. If the small leak continuesw isolation, offsite dose limits may be Credit for these instruments is not taken in any Differen tial Flow High transient or accident analysis in the UFSAR, since boundin analyses are performed for large breaks such as ecirculation or MSL breaks.

and eca venrt-ilatien-diffeien 4al-4emnatw. signals are initiated from temperature elements that are located in the area or room that is being monitored. Twelve thermocouples provide input to the Area Temperature-High

,sixareas Function (two per are ). Two channels per area are required tn he nIPFRARIEt sure that no single instrument failure can preclude the isolation function.

Eight thermocouples provide input to the Area Ventilation Differential Temperature-High Function. The output of these thermocouples is used to determine the differential temperature in four rooms containing RWCU piping and equipment. Each channel consists of a differential four rooms tomperatuxe-instrument that receives inputs from thermocouples tha e located in the inlet and outlet of the room cooling syst m and for a total of four available channels (one per room,.

The Area and Area Ventilation Differential Temperature-High Allowable Values are set low enough to detect a leak equivalent to 25 gpm.

These Functions isolate the RWCU isolation valves, as appropriate.

A note has been added to Table 3.3.6.1-1 for Function 5.c, RWCU Area Differential Temperature - High, clarifying the required channels per room is one. Function 5.c has only one trip system per room.

FERMI - UNIT 2 B 3.3.6.1 -19 Revision 0

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued)

Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable primary containment isolation instrumentation channel.

A.1 Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Functions 1.f, 2.a, 2.c, and 6.b and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Functions other than Functions 1.f, 2.a, 2.c, and 6.b has been shown to be acceptable (Refs. 5 and 6) to permit restoration of any inoperable channel to OPERABLE status. This out of service time is only acceptable provided the associated Function is still maintaining isolation capability (refer to Required Action B.1 Bases). If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action A.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability. restore capability to accommodate a single failure, and allow operation to continue with no further restrictions. Alternately, if it is not desired to place the channel in trip (e.g.. as in the case where placing the inoperable channel in trip would result in an isolation). Condition C must be entered and its Required Action taken. As in admini:tratie coantrol (refcre-ci 12)

-witi UU it vi tmu c U Area Vye it i1at Di 4ffzrntiO l

-Temperature High instrumcntz inopcrablc TS 3.3.6.1, ii n .. shue nt--o-rd B.1 Required Action B.1 is intended to ensure that appropriate actions are taken if multiple, inoperable. untripped channels within the same Function result in redundant automatic isolation capability being lost for the associated penetration flow path(s). The MSL Isolation Functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip, such that both trip systems will generate a trip signal from the given Function on a valid signal. The other isolation functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip, such that one Revision 21 B 3.3.6.1-24 UNIT 2 FERMI - UNIT 2 B 3.3.6.1-24 Revision 21

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES ACTIONS (continued) trip system will generate a trip signal from the given Function on a valid signal. This ensures that one of the two PCIVs in the associated penetration flow path can receive an isolation signal from the given Function. For Functions 1.a. l.b. 1.d4 and 1.f. this would require both trip systems to have one channel OPERABLE or in trip. For Function 1.c. this would require both trip systems to have one channel, associated with each MSL, OPERABLE or in trip.

For Functions L.e and 1.g. each Function consists of channels- that monitor several locations within a given area (e.g., different locations within the main steam tunnel area). Therefore, this would require both trip systems to have one channel per location OPERABLE or in trip. For Functions 2.a, 2.b, 2.c. 3.b. 3.c. 4.b, 4.c, 5.e. and 6.b, this would require one trip system to have two channels, each OPERABLE or in trip. For Functions 3.a, 3.d, 4.a. 4.d.

5.a, 5.d. and 6.a, this would require one trip system to have one channel OPERABLE or in trip. For Functions 5.b Insert 2 and 5.c, each Function consists of channels that monitor several different locations. Therefore, this would require one channel per location to be OPERABLE or in trip (the channels are not required to be in the same trip system).

The Condi-tion does not include the Manual Initiation Functions (Functions 1.h, 2.d. 3.f, 4.f, 5.f, and 6.c),

since they are not assumed in any accident or transient analysis. Thus, a total loss of manual initiation capability for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (as allowed by Required Action A.1) is allowed.-As ei administrnt+e cartrcol (rQferecn 1e-121-Ccisdition B 1 is *h ho B;cra fnr an inopcrablc Rk!CU Ar:c~

Ver&4 D+vtk,-,ifFe Trnmperaturw High instrument. It iz rzegnired thidt dpicatitmeof Condit4eR B whei a cingle chnncel of RWCU Aie& funtf H4igh 4_ inperebl !tCni'PPiontex~t.u hs j Ircwc'.r. in the rea.t restrictive rcading of Condition e -

-Icoation c-atbi~~ty for R ea Vea,...l...tio Differential

-T-er t' eHinb 9;dr: a i not a ffainalcled TV the

-g-eRoo cnhndnl i+p5 The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channel s.

Revision 21 UNIT 2 B 3.3.6.1-25 FERMI - UNIT 2 B 3.3.6.1-25 Revision 21

Insert 2 As noted, with a Table 3.3.6.1-1 Function 5.c channel inoperable, isolation capability is considered maintained provided Function 5.b is OPERABLE in the affected room. There is diversity in the RWCU temperature isolation instrumentation in that Area Ventilation Differential Temperature-High and the Area Temperature-High monitor for a small leak in the same rooms. The reliability of the RWCU system isolation function remains high even in the presence of single or multiple failures of differential temperature channels because of the redundancy and diversity of the RWCU Leakage Detection System. A steam leak will cause a coincidental trip of both the Area Ventilation Differential Temperature-High and the Area Temperature-High channels in the same room.

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SIRVEILLANCE REQIIREJENTS (continued)

(Refs. 5 and 6) assumption of the average time required to perform channel surveillance. That analysis demonstrated that the testing allowance does not significantly reduce the probability that the PCIVs will isolate the penetration flow path(s) when necessary.

Insert 3 SR 3.3.6.1.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the as ion that instrument channels monitoring the same parame should read approximately the same value. Significant deviations between the lnstfwent channels could be an indication of excessive instrument drift In one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus. it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel Instrument uncertainties.

including indication and readability. If a channel is outside the criteria. It may be an Indication that the instrument has drifted outside its limit.

The Frequency is Ibased on operating experience that demonstrates charnel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent. checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.6.1.2 and SR 3.3.6.1.6 A CHANNEL RJNCTIGLAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FERMI~dT 2 3..6.129 Rvisin 2 FERMI - UNIT 2 B 3.3.6.1-29 .Revision 27

Insert 3 Note 2.b clarifies that the isolation function is maintained for Function 5.c, RWCU Area Differential Temperature - High, provided a Function 5.b, RWCU Area Temperature -

High channel, is OPERABLE in the affected room.

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE REQUIREMENTS (continued)

ISOLATION SYSTEM RESPONSE TIME tests are conducted on an 18 month STAGGERE1D TEST BASIS. The 18 month Frequency is consistent with ithe typical Industry refueling cycle and is based upon plant operating experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

REFERENCES 1. UFSAR, Section 6.3.

2. UFSAR, Chapter 15.

3. NEDO-31466. uTedhnical Specification Screening Criteria Appilication and Risk Assessment,"

November 1917.

4. UFSAR, Section 4.5.2.4.

5. NEDC-31677P-A. Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation,"

July 1990.

6. NEDC-30851P-4 Supplement 2, 'Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, March 1989.

7. UFSAR. Section 7.3.

8. UFSAR. Section 6.2.

9. NEDO-31400. 'Safety Evaluation for Eliminating the BWR MSIV Closure Function and Scram Function of the MSL Radiation Monitor," Licensing Topical Plant Report for BWROG.

10. NEDO-32291. "System Analysis for Elimination of Selected Response Time Testing Requirements," January 1994: and Fermi-2 SER for Amendment 111, dated April 18, 1997.

11. NEDO-32291-A, Supplement 1, 'System Analyses for The Ellmination of Selected Response Time Testing Requirement,' October 1999.

2- RC Administfativeo Letter 98 10, "D; osI 1IW 1 n. IF Techncal S eiiatiams That Ape insum-gc~ent to-FEM 2. .. .2 .NI eiin2 FERMI - UNIT 2 B 3.3.6.1-32 Revision 21

v t e Letter Sequence Request
TAC:MC9690, (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers 12 July 2006 Results Approval Other: ML062200440
MONTHYEAR2006-07-12 [Table View]

NRC-06-0001, Revision to License Amendment Request to Revise Technical Specification 3.3.6.1, Primary Containment Isolation Instrumentation.

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6.0 ENVIRONMENTAL CONSIDERATION

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NRC-06-0001, Revision to License Amendment Request to Revise Technical Specification 3.3.6.1, Primary Containment Isolation Instrumentation.

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Enclosure:

Enclosures:

SUBJECT:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REF17ERENCES

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