Text

Proposed License Amendment Request to Extend the Completion Time for Technical Specification 3.8.1 for an Inoperable Emergency Diesel Generator
	ML062000325
Person / Time
Site:	Fermi
Issue date:	07/12/2006
From:	Cobb D; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-06-0040
	Download: ML062000325 (52)
	v • d • e

Donald K. Cobb Assistant Vice President, Nuclear Generation Fermi 2 6400 North I)ixic lHw, Newport, N1l 48166 Tel: 734.586.5201 Fax: 734.586.4172 DTE Energy-10 CFR 50.90 July 12, 2006 NRC-06-0040 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. I\TF-43

Subject:

Proposed License Amendment Request to Extend the Completion Time for Technical Specification 3.8.1 for an Inoperable Emergency Diesel Generator Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License, Appendix A, Technical Specifications (TS) to extend the Completion Time associated with TS 3.8.1 Condition A from 7 days to 14 days for a single inoperable Emergency Diesel Generator (EDG). This proposal also creates a new Condition with a 3 day Completion Time for both EDGs inoperable in one division of onsite electrical power distribution and removes Required Actions for Combustion Turbine Generator 11-1 that are no longer necessary, as explained in , from the revised Condition A.

An additional change is being proposed to remove the second Completion Times contained in TS 3.8.1 for one inoperable EDG and for one inoperable offsite circuit.

This proposed change is in accordance with NRC approved TSTF-439, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," as noted on the NRC letter of January 11, 2006, from Thomas H. Boyce, Chief Technical Specifications Branch, to the Technical Specifications Task Force, "Status of TSTF-439, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO" (References 12 and 13).

The proposed changes would reduce EDG unavailability by allowing on-line performance of EDG maintenance activities in a single outage that are currently

USNRC NRC-06-0040 Page 2 performed over multiple outages, or during refueling outages. The proposed changes also provide flexibility to resolve EDG deficiencies and avoid potential unplanned plant shutdown should a condition occur requiring EDG corrective maintenance.

The proposed Completion Time extension is based on Detroit Edison's deterministic engineering analysis and a risk analysis which was developed in accordance with the guidelines established in Regulatory Guide 1.177, "An Approach for Plant-Specific Risk-Informed Decision-making: Technical Specifications," and NRC Regulatory Guide 1.174, "An Approach for using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis.

Enclosure I provides an evaluation of the proposed license amendment, including an analysis of significant hazards consideration using the standards of 10 CFR 50.92. provides the marked up pages of the existing TS to show the proposed changes. Enclosure 3 provides a typed version of the affected TS page with the proposed changes incorporated. 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.

USNRC NRC-06-0040 Page 3 Detroit Edison requests NRC approval of this license amendment by January 15, 2007, with an implementation period of within 30 days following NRC approval.

Should you have any questions or require additional information, please contact Mr. Ronald W. Gaston of my staff at (734) 586-5197.

Enclosures cc: D. H. Jaffe C. A. Lipa NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-06-0040 Page 4 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 -1 . 2006 before me personally appeared Donald K. Cobb, being first duly sworn and says that he executed the foregoing as his free act and deed.

7N Notary Public KAFM~ 14FM NOTARYK= TATE OFN MYCWOUIY OFMONROE MyoeWssMIEXPIRIEBSepZ 2011 ACTIN INCO(JNTYOF M tw-ap

ENCLOSURE 1 to NRC-06-0040 FERMI 2 NUCLEAR POWER PLANT EVALUATION OF THE PROPOSED LICENSE AMENDMENT REQUEST

FERMI 2 NUCLEAR POWER PLANT EVALUATION

SUBJECT:

Proposed License Amendment Request to Extend the Completion Time for a single inoperable Emergency Diesel Generator

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

Enclosure 1 to NRC-06-0040 Page 2 Evaluation of the Proposed License Amendment Request

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License, Appendix A, Technical Specifications (TS) to extend the Completion Time associated with TS 3.8.1 Condition A from 7 days to 14 days for a single inoperable Emergency Diesel Generator (EDG). This proposal also creates a new Condition with a 3 day Completion Time for both EDGs inoperable in one division of onsite electrical power distribution and removes Required Actions where they are no longer necessary, for Combustion Turbine Generator (CTG) 11-1, from the revised Condition A.

An additional change is being proposed to remove the second Completion Times contained in TS 3.8.1 for one inoperable EDG and for one inoperable offsite circuit. This proposed change is in accordance with NRC approved TSTF-439, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," as noted on the NRC letter of January 11, 2006, from Thomas H. Boyce, Chief Technical Specifications Branch, to the Technical Specifications Task Force, "Status of TSTF-439, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO" (References 12 and 13).

2.0 PROPOSED CHANGE

A brief description of the proposed TS changes is provided below.

Technical Specification 3.8.1, "AC Sources-Operating" Condition A Condition A is revised to apply to only one EDG in one division inoperable and the Completion Time is revised from 7 to 14 days.

The Required Actions and Completion Times A.3 and A.5 for CTG 11-1 are removed. The Required Actions and Completion Times for CTG 11-1 were added to TS 3.8.1 as part of Amendment 119 which changed the Completion Time for one or two inoperable EDGs from 3 to 7 days. This proposed change is a 14 day Completion Time for a single EDG inoperable and the addition of a new Condition for both EDGs in one division inoperable, with a 3 day Completion Time. Restoration of the 3 day completion time for both EDGs in one division inoperable removes the need for CTG 11-1 to be included in TS 3.8.1.

Enclosure I to NRC-06-0040 Page 3 The second Completion Time is removed in accordance with TSTF-439, as approved by the NRC.

Condition B A new Condition B is added with a 3 day Completion Time for both EDGs inoperable in one division of onsite electrical power.

Condition C The second Completion Time is removed in accordance with TSTF-439, as approved by the NRC.

Conditions Renumbered With the addition of new Condition B, Conditions B thru F are renumbered.

In summary, this amendment request proposes TS changes which will extend the EDG Completion Time to 14 days for a single EDG inoperable, creates a new Condition for both EDGs in one division inoperable with a 3 day Completion Time, removes unnecessary actions for CTG 11-1, and implements NRC approved TSTF-439 for TS 3.8.1.

3.0 BACKGROUND

Description of Fermi 2 Offsite and Onsite AC Power Fermi 2 Technical Specification 3.8.1 requires two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system. Offsite power is available for the auxiliary power requirements of Fermi 2 and is comprised of two physically independent circuits supplied at two different voltage levels, 345kV and 120kV.

Three (3) transmission lines provide 120kV power to the 120kV Switchyard located at the Fermi 1 site. The 120kV Switchyard is an arrangement of buses, breakers, disconnects, transformers, and transmission lines which connect the four Combustion Turbine Generators (CTGs-located at Fermi 1) and Fermi 2 Division 1 Essential Safeguard Feature (ESF) and Balance of Plant (BOP) loads with the Electrical System. Only one (1) of the above redundant 120kV lines is required to comply with Fermi 2 Technical Specifications in supplying one of the two required physically independent offsite circuits.

Two (2) transmission lines provide 345kV power from the Electrical System to the 345kV Switchyard located at the Fermi 2 site. The 345kV Switchyard is an arrangement of buses, breakers, disconnects, transformers, and transmission lines which connect the Fermi 2 Main Turbine Generator (MTG-2) and Fermi 2 Division 2 ESF and BOP loads with the Electrical

Enclosure 1 to NRC-06-0040 Page 4 System. Fermi 2 exports its generating capability via MTG -2, interconnecting via the 345 kV Switchyard to the Electrical System. Only one (1) of the above redundant 345 kV lines is required to comply with Fermi 2 Technical Specifications in supplying one of the two required physically independent offsite circuits.

The Fermi 2 Class IE distribution system consists of two physically and electrically independent and redundant power trains, Division 1 and Division 2, supplying electrical power to safety-related equipment. The ESF buses are divided into two (2) divisions, with different offsite power sources to each division, as discussed above. Each of the two (2) ESF divisions, Division 1 and 2, consist of two (2) separate buses. The loads on each ESF division are split between two (2)

EDGs. Either Division 1 or Division 2 has the capability and the capacity to supply the ESF AC power loads required for safe shutdown.

Manually operated tie breakers are provided to cross-tie Division 1 and Division 2 ESF Buses.

These tie breakers are normally maintained in the open and disconnected position.

Administrative controls limit the operation of these breakers.

Four (4) EDGs, each connected to their respective ESF Buses, provide an emergency source of power upon loss of the offsite power sources. In the event of a loss of offsite power, each EDG will receive an automatic start signal. Load shedding and bus isolation will occur automatically.

Following load shed and bus isolation, each EDG output breaker will automatically close, energizing the associated ESF Buses. Essential loads will then be automatically connected to their respective ESF Buses sequentially. Each EDG will receive a start signal on the following signals:

a. Loss of voltage

b. Degraded voltage

c. ESF actuation signal (High Drywell Pressure or Level 1-Low Reactor Water Level)

d. Manual start Four (4) Combustion Turbine Generators (CTG) can be used to supply power to Division 1 ESF Buses when a loss of offsite and on-site power occurs (station blackout). Plant procedures provide for operation of the CTGs and the Electrical System under station blackout conditions.

CTG 11-1 is the normal station blackout AC source with station blackout capability integrated within the unit. Additionally, a dedicated diesel generator can be manually aligned to provide station blackout power for starting CTG 11-2, 11-3, or 11-4, providing a backup station blackout AC source.

The Fermi 2 Electrical Power System is described in the Fermi 2 Updated Final Safety Analysis Report (UFSAR) Chapter 8. The safety related function of the EDGs is to provide an onsite standby source of AC electrical power to shut down and maintain the reactor in a safe condition under all conditions including a Loss of Coolant Accident (LOCA) coincident with a Loss of Offsite Power (LOOP) event.

Enclosure 1 to NRC-06-0040 Page 5 In the event of a unit trip, the offsite supply to the ESF buses would not be interrupted. The design of the 345kV switchyard utilizes a "breaker-and-one-half' design such that a unit trip does not isolate auxiliary power from the ESF buses.

Regulatory Guide 1.155 EDG Reliability Program Fermi 2 maintains an EDG reliability program based on Regulatory Guide (RG) 1.155, "Station Blackout." The program monitors and evaluates EDG performance and reliability consistent with guidance provided in NUMARC 87-00, "Guidelines for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors." The program requires remedial actions when one or more established reliability "trigger values" are exceeded, a root cause evaluation be performed and corrective actions taken. Table I shows the status of the EDG Reliability Program as of May 2006.

Failures in last Failures in last Failures in last 20 demands 50 demands 100 demands EDGs 0 0 0 The EDG reliability program will not be negatively impacted by the proposed amendment because EDG testing frequencies are unaffected.

Maintenance Rule Program The Maintenance Rule (MR) requires that an evaluation be performed when equipment covered by the MR does not meet its performance criteria.

The reliability and availability of the EDGs are monitored under the MR program. If the pre-established reliability or availability performance criteria are not achieved for the EDGs, they are considered for 10 CFR 50.65 (a)(1) actions. These actions would require increased management attention and goal setting in order to restore their performance to an acceptable level. The actual out of service time for the EDGs is minimized to ensure that the reliability and availability performance criteria are met. Fermi 2 EDG MR System Health was listed as 10 CFR 50.65 (a)(1) from April 8, 1997 to November 29, 2005. Actions taken to improve EDG MR System Health resulted in 10 CFR 50.65 (a)(2) classification on November 29, 2005.

Current TS Requirements and Limitations TS 3.8.1 requires two qualified circuits between the offsite transmission network and the onsite ESF power distribution system and two EDGs per ESF division. The safety related function of the EDGs is to provide an onsite standby source of AC electrical power to shut down and maintain the reactor in a safe condition under all conditions including a Loss of Coolant Accident (LOCA) coincident with a Loss of Offsite Power (LOOP) event.

Enclosure 1 to NRC-06-0040 Page 6 Planned EDG outages, including preventive maintenance to ensure EDG availability, elective maintenance activities, and surveillances, routinely require four to six days to complete. When more than half the Completion Time for an EDG outage is utilized for planned maintenance, there is less time available than desired for emergent maintenance and testing. Replacement of equipment such as bearings and pistons require significant run in time and surveillance testing, challenging our ability to complete maintenance activities within the current 7 day Completion Time. This undesirable situation occurred in February 2006, when Fermi 2 requested and was granted a one-time extension of the 7 day Completion Time in order to complete maintenance activities on an EDG (References 10 and 11).

When longer times are available for EDG outages, there is a reduction in unavailability time for performing protective tagging and untagging, system drain down and fill, placing an EDG into a standby lineup, and performing post maintenance testing and surveillance testing.

4.0 TECHNICAL ANALYSIS

This section provides the technical analysis of the proposed changes with regard to the principles that adequate defense-in-depth is maintained, sufficient safety margins are maintained, and the proposed increases in core damage frequency and risk are small and consistent with the guidance of RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Bases," dated November 2002 and RG 1.177, "An Approach for Plant- Specific, Risk-Informed Decisionmaking: Technical Specifications," dated August 1998 (References 1 and 2).

Current TS 3.8.1 for EDG Completion Time Under the current TS, if one or both EDGs in one division is inoperable, action is taken to restore the EDG to operable status within 7 days, provided CTG 11-1 is operable. In this Condition, the two or three remaining operable EDGs and offsite to onsite paths are adequate to supply electrical power to the onsite ESF division. The 7 day Completion Time takes into account the capacity and capability of the remaining AC sources.

Proposed TS 3.8.1 Changes and Benefits The proposed changes will allow, for a single inoperable EDG, a Completion Time of 14 days for EDG maintenance or testing activities. This will permit an additional 7 days beyond the current TS allowed Completion Time and avoid or minimize TS required plant shutdowns due to EDG maintenance or testing.

The extended TS Completion Time for EDGs improves effectiveness of the allowed maintenance period. A significant portion of on-line maintenance activities is associated with preparation and return to service activities, such as, tagging, fluid system drain down, fluid system fill and vent, to NRC-06-0040 Page 7 and cylinder block heat-up. The duration of these activities is relatively constant. Longer Required Action Completion Time durations allows more maintenance to be accomplished during a given on-line maintenance period and therefore, would improve maintenance efficiency.

Thus, the total EDG unavailability is expected to be reduced with this proposed change.

This change will allow some maintenance activities to be performed on-line which would otherwise require performance during a refueling outage. On-line preventive maintenance and scheduled overhauls provide the flexibility to focus more quality resources on any corrective or elective diesel generator maintenance. For example, during refueling outages, resources are required to support many system outages; and during on-line maintenance, plant resources are focused on the EDG overhaul.

Performance of more EDG maintenance on-line will improve EDG availability during plant refueling outages. Performing EDG overhaul activities on-line should reduce the risk and synergistic effects on risk due to EDG unavailability occurring concurrently with other activities and equipment outages during a refueling outage.

If both EDGs in one division are inoperable, a 3 day Completion Time is proposed. In Amendment 119, Fermi 2 increased the Completion Time for the inoperability of one or both EDGs in one division, such that the CTG 11-1 Required Action was added to TS 3.8.1.

Returning to a 3 day Completion Time, removes the need for the CTG 11-1 Required Actions.

Summary of Risk Impact Evaluation Results An extension of the allowed Completion Time to 14 days for TS 3.8.1 will allow the required repairs and post-maintenance testing for a single EDG to be completed without requiring that this be performed in multiple shorter duration EDG outages or placing this workload into the Refueling outage scope.

The Incremental Conditional Core Damage Probability (ICCDP) and Incremental Conditional Large Early Release Probability (ICLERP) resulting from extending the EDG Completion Time to 14 days were computed in accordance with the definitions in Reference 1. These results were then compared with the risk significance guidance contained in Reference 2 for changes in the annual average Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) and in Reference I for ICCDP and ICLERP. The values obtained for the ICCDP (1.6E-07) and ICLERP (9.5E-9) demonstrate that the proposed Completion Time change has only a small quantitative impact (less than the threshold values of 5.OE-7 for ICCDP and 5.0E-8 for ICLERP listed in Reference 1) on plant risk. This satisfies the risk criteria for permanent as well as for temporary changes for plant maintenance configurations.

In addition to examining the CDF and LERF from internal events, shutdown risk and external events were reviewed. The impacts on both shutdown risk contributions and external events were evaluated on a qualitative basis. Based on these quantitative and qualitative evaluations,

Enclosure 1 to NRC-06-0040 Page 8 extending the Completion Time for an inoperable EDG to 14 days will have minimal effect on plant risk.

Evaluation of Risk Impact The risk impact of the proposed EDG Completion Time has been evaluated and found to be acceptable per regulatory guidance for risk-informed permanent TS changes. The effect on risk of the proposed increase in Completion Time for restoration of an inoperable EDG has been evaluated using NRC's three-tier approach provided in RG 1.177 (Reference 1):

Tier 1 - PRA Capability and Insights; Tier 2 - Avoidance of Risk-Significant Plant Configurations; and Tier 3 - Risk-Informed Configuration Risk Management.

Tier 1: PRA Capability Risk impacts due to internal events are assessed using the FermiV7 revision of the Level 1 and Level 2 PRA. Risk-informed support for this proposed change is based on PRA calculations performed to quantify the change in CDF and LERF resulting from the increased Completion Time for the EDGs.

The Fermi PRA model (FermiV7) used for the risk determinations is an upgrade to the Individual Plant Examination (IPE) submitted to the NRC (Reference 3) along with a revision (Reference 4). The NRC (by letter Reference 5) documented their conclusion that the Fermi 2 IPE submittal met the intent of Generic Letter 88-20.

The current PRA addresses internal events (including internal flooding) at full power. The model incorporates recent advances in PRA technology across many elements (through several upgrades) and is technically adequate to evaluate the risk impact of increased Completion Time for the EDGs. These elements include the proper characterization of initiating events involving LOOP, treatment of time dependant offsite power recovery, treatment of operator actions to implement bus ties and other Emergency Operating Procedures (EOPs), equipment success criteria calculations, data analysis of key parameters (such as EDG failure rates), maintenance unavailabilities, and common cause failure probabilities.

In the Level 2 analysis, Containment Fault Trees (CFTs) are developed to provide the link between the plant damage states associated with core damage mitigation and containment integrity with the possible radionuclide releases of varying timing and magnitudes. As required by Reference 8, the model considers the performance of the reactor building and sprays in the assessment of radionuclide mitigation. The spectrum of radionuclide releases that could result from the core damage condition is then calculated for the postulated discrete end states of the CFTs. The CFTs model the various potential radionuclide release paths to the environment and provide an estimate of their relative likelihoods. This process is an iterative one, requiring to NRC-06-0040 Page 9 technical feedback between the system fault trees, the CFTs, and the plant response evaluation.

The purpose of containment fault trees is to provide estimates of the conditional probabilities of various radionuclide releases and timing given the core damage sequences defined in the Fermi Level 1 PRA. The LERF is represented by one of these linked CFTs. This approach to the LERF evaluation also supports realistic quantification of systematic contributions to containment isolation failures (bypass sequences that are actually linked to the Level 1 model).

The Fermi 2 internal events PRA (including Level 2) received a formal industry PRA Peer Review in 1997. The purpose of the Peer Review process is to provide a method for establishing the technical quality of a PRA for the spectrum of potential risk-informed plant licensing applications for which the PRA may be used. The PRA Peer Review process uses a team composed of PRA and system analysts, each with significant expertise in both PRA development and applications. This team provides both an objective review of the PRA technical elements and a subjective assessment, based on their experience, regarding the acceptability of the PRA elements. The team uses a set of checklists as a framework within which to evaluate the scope, comprehensiveness, completeness, and fidelity of the PRA products available. The peer review process for Fermi 2 resulted in 65 important (i.e., level 'A' or 'B') Fact & Observation (F&O) findings. There were 5 level 'A' and 60 level 'B' F&O findings identified during the review.

Additionally, there were 3 'S' findings denoting a strength or superior modeling process. The important F&Os (i.e., level 'A' or 'B') were addressed as part of the 1999 through 2006 PRA model updates. Currently, there are no 'A' level items that are open. There are four 'B' F&O items dealing with documentation that remain open, but they have no impact on the EDG Completion Time extension results.

The scope, level of detail, and quality of the Fermi PRA is sufficient to support a technically defensible and realistic evaluation of the risk change for this proposed Completion Time extension. Significant improvements in quality of the Fermi PRA Model have been made since the 1997 peer review. These improvements include (but are not limited to):

1. A re-analysis of the Fermi Human Reliability Analysis (HRA) using the HRA Calculator software package.

2. A complete internal review of the Level 1 model top logic.

3. Improvements to address the aforementioned 'A' and 'B' Peer Review F&Os.

4. Re-evaluation and formal documentation of PSA thermal-hydraulic and electrical success criteria for the site implementation or the Mitigating System Performance Index (MSPI).

5. Development of an improved fault tree based Level 2 model.

6. An analysis of revised industry data to determine Fermi-specific Loss of Offsite Power (LOOP) frequencies.

7. Revision of basic event probabilities and initiating event frequencies to reflect revised plant and industry data.

8. Incorporation of plant modifications into the model.

9. Modifications to reflect revised plant operating procedures.

Enclosure I to NRC-06-0040 Page 10

10. Enhanced risk monitoring capabilities for the performance of Maintenance Rule (a)(4) assessments.

It should be noted that since the one-time emergency license amendment (Reference 10) was granted on February 5, 2006 credit for the dedicated diesel generator which enables the starting capability of CTGs 11-2, 11-3, and 11-4 for station blackout support, has been added to the model.

Tier 1: PRA Insights Risk Assessment for 14 Day Completion Time The criterion for a permanent license basis change (RG 1.177, "An Approach for Plant-Specific Risk-Informed Decision-making: Technical Specifications") was followed to analyze the risk of this 14 day Completion Time request. This quantifies the risk increase for a single system or train being out of service while other systems have a nominal chance of unavailability. This approach allows the NRC to compare Fermi's request with recent submittals from other plants for EDG Completion Time extensions to 14 days as a permanent Tech Spec change.

Key Assumptions:

I. The "baseline" PRA model, FermiV7, is utilized to perform the assessment. This model represents normal plant operation at full power and includes nominal maintenance and failure terms for all systems, as well as nominal initiating event frequencies.

2. A single EDG is taken out of service and assumed to be returned to service 14 days from the initial LCO entry.

3. All calculations were performed with a 1E-9 truncation limit.

4. The model (FermiV7) includes credit for the blackstart diesel generator, which allows CTG 11-2, 11-3, and 11-4 to be used as a source of electrical power in the event of a loss of offsite power.

5. No credit is taken for the improved availability of each EDG due to the ability to schedule a single outage during a fuel cycle versus two shorter duration outages (with tagout, return to service ,and post maintenance testing required for each system outage).

Enclosure 1 to NRC-06-0040 Page 11 Calculation of risk with EDG 14 unavailable for 14 days at full power To determine the effect of the proposed 14-day Completion Time for restoration of an inoperable EDG, the guidance in RG 1.174 and 1.177 (References 1 and 2) was used.

The following table contains necessary data to perform risk significance calculations.'

ITEM VALUE Baseline CDF with nominal expected equipment 1.05E-5/yr unavailabilities.

Conditional CDF with EDG 14 failed and other equipment's 1.47E-5/yr nominal expected equipment unavailabilities.

Baseline LERF with nominal expected equipment 3.01 E-7/yr unavailabilities.

Conditional LERF with EDG 14 failed and other 5.48E-7/yr equipment's nominal expected equipment unavailabilities.

In order to address Regulatory Guide 1.174 criteria the following risk metrics were used to evaluate the risk impacts of extending the EDG Completion Time from 7 days to 14 days:

DCDF = Change in the annual CDF due to the increased on-line maintenance unavailability of EDGs that could result from the increased Completion Time. This risk metric is used to compare against the criteria in RG 1.174 to determine whether a change in CDF is regarded as risk significant. These criteria are a function of the baseline annual core damage frequency.

DLERF = Change in the annual LERF due to any increased on-line maintenance unavailability of EDGs that could result from the increased Completion Time. RG 1.174 criteria were also applied to judge the significance of changes in this risk metric.

The increase in CDF and LERF with the future expected unavailabilities for the EDGs are considered to be "very small" if they are less than 1.0E-6/yr and 1.OE-7/yr, respectively. The current maintenance terms are based on actual plant data and reflect the on-line maintenance that is currently performed on each EDG. It should be noted that although the Completion Time may be relaxed, Fermi 2 does not intend to relax the EDG performance criteria established in response to Station Blackout (10CFR 50.63) and the maintenance rule (10CFR 50.65).

It is assumed for the purposes of this analysis that the Preventive Maintenance (PM) term will increase as a result of performing the 4 additional EDG major overhauls on line. The existing PM term is conservatively assumed to increase to account for a 14 day major overhaul once per refueling cycle for each EDG. The refueling cycle length is assumed to be 18 months with an 1Based on a sensitivity study, EDG 14 was found to be the most risk significant. Therefore, all numerical values are based upon having EDG 14 out of service for the duration of the Completion Time.

Enclosure I to NRC-06-0040 Page 12 assumed total planned and unplanned outage duration of 30 days, which yields a cycle length of 518 days.

For comparison to RG 1.174 guidelines the following formulas were used to calculate DCDF and DLERF:

1. DCDF = [(conditional CDF with the subject equipment out of service) - (baseline CDF with nominal expected equipment unavailabilities)] (duration of additional OOS due to change)/Cycle length.

2. DLERF = [(conditional LERF with the subject equipment out of service) - (baseline LERF with nominal expected equipment unavailabilities)] (duration of additional OOS due to change)/Cycle length.

Therefore, DCDF = [(1.47E-5/yr) - (l.05E-5/yr)] * (14 days) *(4 EDGs /518 days)

= 4.5E-7/yr DLERF = [(5.48E-7/yr) - (3.01E-7/yr)] * (14 days) *(4 EDGs / 518 days)

= 2.7E-8/yr Therefore, the increases in CDF and LERF with the assumed unavailabilities for the EDGs are considered "very small" since they are less than 1E-6/yr and 1E-7/yr, respectively.

In order to address RG 1.177, the Incremental Conditional Core Damage Probability (ICCDP) and Incremental Conditional Large Early Release Probability (ICLERP) resulting from extending the EDG Completion Time to 14 days were computed in accordance with the definitions in RG 1.177.

Per RG 1.177, the following formulas are to be used to calculate ICCDP and ICLERP:

1. ICCDP = [(conditional CDF with the subject equipment out of service) - (baseline CDF with nominal expected equipment unavailabilities)] (duration of single Completion Time under consideration).

2. ICLERP = [(conditional LERF with the subject equipment out of service) - (baseline LERF with nominal expected equipment unavailabilities)] (duration of single Completion Time under consideration).

Enclosure 1 to NRC-06-0040 Page 13 Therefore, ICCDP = [(1.47E-5/yr) - (1.05E-5/yr)] * (14 days) *(I YR/365.25 days)

= 1.6E-7 ICLERP = [(5.48E-7/yr) - (3.01 E-7/yr)] * (14 days) *(1 YR/365.25 days)

= 9.5E-9 Both of these results would qualify as "small", according to criteria for a permanent Technical Specification Completion Time change according to the RG 1.177, which states:

"The licensee has demonstrated that the TS Completion Time change has only a small quantitative impact on plant risk. An ICCDP of less than 5.0E-7 is considered small for a single TS Completion Time change. An ICLERP of 5.OE-8 or less is also considered small."

In addition to the above analysis, a sensitivity study was performed to account for any potential inclement weather that may occur during the duration of the 14 day Completion Time (by increasing the loss of offsite power initiating event frequency by a factor of 2.0). The results of this analysis show that the calculated values are still below the RG 1.177 criteria (ICCDP = 2.4E-7 and ICLERP = 2.7E-8).

Required Actions for CTG 11-1 are proposed to be removed from the TS. If CTG 11-1 is inoperable at the same time that any single EDG is inoperable for the entire proposed 14 day period with no other equipment in maintenance, the risk remains within the RG 1.174 (Reference

2) threshold, for a "small" risk increase classification. Additionally, the calculated potential for core damage as a result of inoperability of CTG 11-1 has decreased since the CTG 11-1 Required Actions were added to TS 3.8.1 in Amendment 119. The decrease is due to:

1. The inclusion of blackstart capability for CTG Units 11-2, 11-3, and 11-4.

2. A more realistic Loss of Offsite Power (LOOP) frequency and recovery values, for both total and divisional LOOP, have been incorporated into the PRA, utilizing several sources of industry data.

Tier 2: Avoidance of Risk-Significant Plant Configurations Maintenance and testing during the proposed Completion Time would be scheduled as warranted to minimize aggregate risk. This will specifically include:

1. Work performed on safety significant systems and their applicable support systems will be reviewed and rescheduled as necessary based upon routine and emergent Maintenance Rule 10 CFR 50.65 (a)(4) evaluations performed per MMR12 (the site risk management procedure).

Enclosure 1 to NRC-06-0040 Page 14

2. No work will be performed that could potentially jeopardize the availability of the opposite division EDGs. This is ensured by restricting and/or controlling access to this equipment via controls provided in existing plant procedure MOP05, "Control of Equipment."

3. For two EDGs in the same division, the Completion Time will revert to the original (pre-Amendment 119) TS Completion Time of 3 days.

Tier 3: Risk-Informed Configuration Risk Management While in the EDG Completion Time period, overall plant risk will be managed by the existing Maintenance Rule (a)(4) program. This program evaluates increases in risk posed by potential combinations of equipment out-of-service and potential increases in initiating event frequency and requires that risk recommendations be implemented as appropriate for a given plant configuration. The 10 CFR 50.65 (a)(4) program at Fermi fully satisfies the configuration risk management program requirements stated in Reference 1.

Other Risk Related Impacts In addition to examining the CDF and LERF from internal events, shutdown risk and external events were reviewed. The impacts on both shutdown risk contributions and external events are evaluated on a qualitative basis. External events are evaluated based on a review of the Fermi Individual Plant Examination of External Events (IPEEE) submittal (Reference 6) and the Fermi 2 Safe-Shutdown Analyses.

Shutdown Risk This change will allow some maintenance activities to be performed on-line which would otherwise be required to be performed during a refueling outage. On-line preventive maintenance and scheduled overhauls provide the flexibility to focus more resources on required or elective EDG maintenance. For example, during refueling outages, resources are required to support many system outages, but during on-line maintenance, plant resources can be more focused on the EDG overhaul. Performance of EDG maintenance on-line will maximize EDG availability during plant refueling outages. Performing EDG overhaul activities on-line should minimize the overall risk due to the synergistic effects on shutdown risk due to EDG unavailability occurring concurrently with other activities and equipment outages during a refueling outage.

Fire Risk A qualitative impact on the Fermi fire risk due to the EDG Completion Time extensions was performed based on insights drawn from the Fermi IPEEE fire PRA results and the Fermi 2 Appendix R analyses.

Enclosure 1 to NRC-06-0040 Page 15 The Fermi plant risk due to internal fires was evaluated in 1996 as part of the Fermi Individual Plant Examination of External Events (IPEEE) Submittal (Reference 6). The NRC in Reference 7 documented their conclusion that the Fermi 2 IPEEE submittal met the intent of Supplement 4 to Generic Letter 88-20. The EPRI FIVE Methodology and Fire PRA Implementation Guide screening approaches and data were used to perform the Fermi IPEEE fire PRA study. Consistent with the FIVE Methodology and the requests of the NRC IPEEE Program, the Fermi IPEEE fire PRA is an analysis that identifies the most risk significant fire areas in the plant using a screening process and by calculating conservative core damage frequencies for fire scenarios. As such, the accident sequence frequencies calculated for the Fermi fire PRA are not a best estimate calculation of plant fire risk and are not conducive to aggregation with the best estimate Fermi internal events PRA results for comparison with Regulatory Guide 1.174 (Reference 2) acceptance guidelines. Therefore, qualitative insights from this analysis are utilized for the Completion Time evaluation.

Safe-shutdown analyses were performed for Fermi 2 to evaluate compliance to 10 CFR 50, Appendix R, Section III.G. These analyses included safe-shutdown capability evaluations and associated circuits of concern (for example, common power supply, common enclosure, spurious operation, and high/low-pressure interfaces). For fires in most of the zones, safe shutdown is accomplished from the main control room using one of the divisions of safe shutdown equipment in accordance with the technical requirements of Section III.G.2 of Appendix R. For fires occurring in one of the dedicated shutdown areas of concern (Fire Zones 03AB, 07AB, 08AB, 09AB, I lAB, or 13AB), safe shutdown is accomplished from outside the main control room using the alternative shutdown system (including the dedicated shutdown panel) as described in UFSAR Section 7.5.2.5, in accordance with the technical requirements of Sections III.G.3 and III.L of Appendix R. This shutdown system does not rely on the EDGs, but instead relies on power provided by a Combustion Turbine Generator (CTG 11-1).

It is useful to identify (for further reference) a number of facts relative to a potential risk increase due to internal fires in light of the proposed TS Completion Time extension for the EDGs:

1. The extension of the TS Completion Time for the EDGs is an administrative change and does not have any significant impact on the likelihood of occurrence of fires at Fermi 2.

2. The purpose for the EDGs (relative to plant safety) is to start and run to provide onsite power to ESF equipment in the event that offsite power becomes unavailable.

3. Appendix R analyses are conservative since they assume a concurrent LOOP with the fire initiating event.

4. Even if one of the fires of concern occurs during the small fraction of the year in which an EDG is assumed to be unavailable for maintenance, the additional capability of non-fire affected AC sources would remain available.

5. Fermi 2 has three CTG Units in addition to CTG 11-1. These additional CTGs provide support for mitigation of fire scenarios but are not credited in the Appendix R and IPEEE to NRC-06-0040 Page 16 analyses. If they were credited in some of these fire scenarios, they would further reduce the risk significance of the EDG Completion Time extension.

Given Items I through 5 above, the additional plant risk from fire induced loss of offsite power was evaluated by considering the equipment which would be remaining for unscreened compartments identified in the Fermi IPEEE (Reference 7), and Appendix R analyses.

Considering the impact of removing EDG 14 (the most risk significant EDG) from service, the impact on unscreened fire areas is as follows:

Fire Area Challenge due to Reason EDG 14 OOS NE Quadrant Reactor Negligible Both divisions of offsite power are still Building available; therefore, EDGs are not required.

Relay Room Negligible The most risk significant scenarios depend on CTG 11-1 for AC Power rather than EDGs.

Division 1 Small Division 2 offsite power and EDG 13 are Switchgear Room still available.

2nd floor of Reactor Negligible Both divisions of offsite power are still Building available; therefore, EDGs are not required.

Control Room Negligible The most risk significant scenarios depend on CTG 11-1 for AC Power rather than EDGs.

3rd Floor of Negligible The most risk significant scenarios depend Auxiliary Building on CTG 11-1 for AC Power rather than EDGs.

Division 2 Negligible The most risk significant scenarios have Switchgear Room Division 2 equipment failed and therefore, success depends on Division 1 ECCS that is supported by Division 1 EDGs and CTG

__________________ 11-1.

Based on this review of the IPEEE quantifications for unscreened compartments and Appendix R analyses, the Fermi internal fire risk due to the EDG Completion Time extension is considered small.

Enclosure 1 to NRC-06-0040 Page 17 Seismic Risk The evaluation of seismic events performed as part of the IPEEE used the Electric Power Research Institute (EPRI) Seismic Margins Assessment methodology. All four trains of EDG were included in the list of components analyzed for safe shutdown following an earthquake.

The RHR building where the EDGs are located was also analyzed. The evaluation provided adequate evidence of the ability of Fermi to resist a seismic event and initiate a safe shutdown of the unit. No significant seismic concerns were identified and it was concluded that the plant possesses significant seismic margin. During a design basis Safe Shutdown Earthquake (SSE),

the plant switchyard is assumed to fail resulting in a loss of offsite power. The probability of an SSE occurring during the 14 day period that an EDG may be inoperable due to maintenance is very low. With all other EDG remaining operable and with the intradivisional crosstie capability between 4 kV buses, the proposed change to the EDG Completion Time has negligible effect on the seismic risk profile at Fermi.

Other External Events Risk Evaluation of high winds, external floods and other external events in the Fermi IPEEE per NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities" (Reference 9), revealed no potential vulnerabilities. The proposed change to the EDG Completion Time has negligible effect on the risk profile at Fermi from these other external events.

Evaluation of Risk Impact Conclusion Based on this evaluation, extending the Completion Time for an inoperable EDG from 7 to 14 days will have a "small" effect on plant risk. Therefore, an extension of the allowed Completion Time from 7 days to 14 days for TS 3.8.1 will not have significant impact to the safety of the public.

Industry Precedents The NRC has recently approved requests to extend the Completion Times for Emergency Diesel Generators for Columbia Generating Station, Beaver Valley Power Station, D.C. Cook Nuclear Plant, and Seabrook Nuclear Power Plant.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. The proposed change to TS 3.8.1 does not involve a significant hazards consideration for the following reasons:

to NRC-06-0040 Page 18

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

This license amendment request proposes a change to extend the Technical Specification 3.8.1, "AC Sources-Operating," Completion Time. This change allows a single EDG to be inoperable for 7 days more than Technical Specification 3.8.1 currently provides. The Required Actions for CTG 11-1 are also removed from Condition A and TSTF-439 is implemented for TS 3.8.1, removing the second Completion Times.

The EDGs are safety related components which provide backup electrical power supply to the onsite ESF power distribution system. CTG 11-1 provides backup electrical power to the Division 1 power distribution system. Neither the EDGs nor CTG 11-1 are accident initiators, thus these changes do not increase the probability of a previously evaluated accident.

The plant ESF power distribution systems consist of two divisions for 100% redundancy.

Accident analyses demonstrate that only one division is required for accident mitigation.

Thus, with one division inoperable the other division is capable of performing the required safety function. Design basis analyses are not required to be performed assuming extended loss of all power supplies to the plant ESF power distribution system.

Thus, this change does not involve a significant increase in the consequences of a previously analyzed accident.

The proposed change also eliminates the second Completion Time from TS 3.8.1. These second Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Times are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change.

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

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The changes do not alter any assumptions made in the safety analysis.

Enclosure 1 to NRC-06-0040 Page 19 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The change does not involve a significant reduction in the margin of safety.

This license amendment request proposes Technical Specification changes to extend the Technical Specification 3.8.1, "AC Sources-Operating," Completion Time for an inoperable EDG to 14 days. These changes allow an emergency diesel generator to be inoperable for 7 days more than TS 3.8.1 currently provides.

Deterministic and probabilistic risk assessments evaluated the effect of the proposed TS changes on the availability of an electrical power supply to the plant emergency safeguards features systems. These assessments concluded that the proposed TS changes do not involve a significant increase in the risk of power supply unavailability.

This license amendment request proposes TS changes to remove the Required Actions for CTG 11-1 from TS 3.8.1 Condition A. If CTG 11-1 is inoperable at the same time that any single EDG is inoperable for the entire proposed 14 day period with no other equipment in maintenance, the risk remains within RG 1.174 (Reference 2) thresholds for a "very small" classification.

The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change.

The proposed changes will not result in plant operation in a configuration outside of the design basis.

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

Based on the above, Detroit Edison has determined that the proposed license amendment does not involve a significant hazards consideration.

5.2 Applicable Regulatory Requirements / Criteria

1. 10 CFR 50.36, "Technical Specifications."

2. NUREG-1433, "Standard Technical Specifications General Electric Plants, BWR/4 Rev. 3."

3. 10 CFR 50, Appendix A, GDC 17, "Electric Power Systems."

to NRC-06-0040 Page 20 6.0 Environmental Considerations 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 References

1. NRC Regulatory Guide 1.177, "An Approach for Plant-Specific Risk-Informed Decision-making: Technical Specifications," dated August 1998.

2. NRC Regulatory Guide 1.174, "An Approach for using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," dated November 2002.

3. NRC-92-0099, "Submittal of the Fermi 2 IPE Report," dated September 1 1992.

4. NRC-93-0075, "Revised Submittal of the Fermi 2 IPE Report," dated September 22 1993.

5. Letter from NRC, "Fermi 2 Generic Letter (GL) 88-20, Individual Plant Examination (IPE) Submittal - Internal Events - Completion of Staff Review" dated November 16, 1994.

6. NRC-96-0036, "Submittal of Detroit Edison Individual Plant Examination for External Events (IPEEE) Report- Response to Generic Letter 88-20, Supplement 4," dated March 29, 1996.

7. Letter from NRC, "Fermi 2 - Completion of Licensing Action For Generic Letter (GL) 88-20, Supplement 4, 'Individual Plant Examination for External Events (IPEEE) for Severe Accident Vulnerabilities,' June 28, 1991 (TAC No. M83621)" dated July, 5, 2000.

8. NUREG-1335, "Individual Plant Examination: Submittal Guidance" dated July 1989.

9. NUREG-1407, "Procedural and Submittal Guidance for the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities", dated June 1991.

10. NRC-06-0010, "Emergency License Amendment Request for One-Time Extension of Allowed Outage Time for the Fermi 2 Emergency Diesel Generator 12," dated February 5, 2006.

11. NRC-06-001 1, "Response to Request for Additional Information Regarding Emergency License Amendment Request for One-Time Extension of Allowed Outage Time for the Fermi 2 Emergency Diesel Generator 12," dated February 5, 2006.

12. TSTF-439, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO".

to NRC-06-0040 Page 21

13. NRC letter from Thomas H. Boyce, Chief Technical Specifications Branch, to the Technical Specifications Task Force, "Status of TSTF 439, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," dated January 11, 2006.

ENCLOSURE 2 to NRC-06-0040 PROPOSED TECHNICAL SPECIFICATION CHANGE Marked-Up Pages 3.8-1 3.8-2 3.8-2a 3.8-2b

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

..... : ACTIONS........................ NOTE .....................................

LCO 3.0.4.b is not applicable to EDGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One-er-b-EDGO'4m. 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 r\ for OPERABLE offsite inoperabl e. 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 EDGY', inoperable when concurrent with the redundant i noperabi li ty of required feature(s) redundant are inoperable, required feature(s)

A.3 Verh!y tUh= status f'-,yzr thou,of G'T- 11 1;-

AND (continued)

FERMI - UNIT 2 3.8-1 Amendment No. AA4, 163

AC Sources -- Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A/ 1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3 EDG(s) are not inoperable due to common cause failure.

OR A.(.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE EDG(s).

j r-l L..IC a vC n T_

-1 - -T Go ition A eeineurrent

........ ýe:ith days CGTC II1 inot AND the Restore -boh EDGK4H-- , -dfY,. 14 days 4 -t-he-kdiii-en- to OPERABLE status.

,dio._ays oef Insert new Conditions B fi~nl* " p n4÷...

4 4-

~ ULIJ (II ~J IUY~~3 UI *J- .. ,.~ .. ~ ~ ~ 1 r~nA~t. - ~ r I I II~

.3n -lffr

.nVr~I~ LU; ~'. ~. I~V.* .1 - U4.U~ I LUtAI .3. hhIUJ LII.. LAL~hIU~U by an additiona1 7 4

'~.3 L. :~rnpktc rop'~" ~ +nrting zf EDO 12.

FERMI - UNIT 2 3.B-2 RAmendment No. 40K. 7,t. 170

Insert 1 CONDITION REQUIRED ACTION COMPLETION TIME B. Both EDGs in one B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months division for OPERABLE inoperable. offsite AND circuit(s).

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s), discovery of supported by the the inoperable EDGs, inoperable inoperable when EDGs the redundant concurrent required with feature(s) are inoperability inoperable. of redundant required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EDG(s) are not inoperable due to common cause failure.

OR 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B.3.2 Perform SR 3.8.1.2 for OPERABLE EDG(s).

AND B.4 Restore one EDG in 3 days the division to OPERABLE status

AC Sources -- Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C ,9' One or both EDGs in e. Restore both EDGs in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months both divisions C one division to inoperable. OPERABLE status.

D ., One offsite circuit /,I Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. D for. OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND (continued)

FERMI - UNIT 2 3.8-2 EIAmendment No. %XK. 177, 170

AC Sources- Operating 3.8.1 ACTIONS CONDITION J REQUIRED ACTION COMPLETION TIME 11 ((continued) -12 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no discovei-y of no D offsite power offsite power available inoperable to one division when the redundant concurrent with required feature(s) inoperability are inoperable, of redundant required feature(s)

AND

/3 Restore offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months D circuit to OPERABLE status.

E Two offsite circuits ý.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable. E feature(s) inoperable discovery of when the redundant Condition D required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s)

AND 2 Restore one offsite 24 hou-rs E circuit' to OPERABLE status.

(continued)

FERMI - UNIT 2 3.8-2a UAmendment No. 170

AC Sources -- Operating 3.8.1 ACTIONS (continued)

CONDITION j REQUIRED ACTION J COMPLETION TIME F /. One offsite circuit ............ NOTE ........

inoperable. Enter applicable Conditions and Required Actions of AND LCO 3.8.7, "Dis J Systems - Operating., whe One or bothlEDGs in Conditionk.lis entered with one Division no AC power source to one or F inoperable. more 4160 V buses 64B. 64C.

65E or 65F.

Restore offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F circuit to OPERABLE status.

OR.

9.2 Restore both EDGs in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F the Division to OPERABLE status.

Required Action and .I Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Associated Completion G C Time of Condition A, B, C,-9-9--r-not met. AND D, E or F 1.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G

FERMvI - UNIT 2 3.8-2b Amendment No. 17

ENCLOSURE 3 to NRC-06-0040 PROPOSED TECHNICAL SPECIFICATION CHANGE Revised Pages 3.8-1 3.8-2 3.8-2a 3.8-2b

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 EDG inoperable. 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 for OPERABLE offsite 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 EDG, inoperable when concurrent with the redundant inoperability of required feature(s) redundant are inoperable. required feature(s)

AND J l

A.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EDG(s) are not inoperable due to common cause failure.

OR (continued)

FERMI - UNIT 2 3.8-1 Amendment No. AI, A ,

AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE EDG(s).

AND A.4 Restore the EDG to 14 days OPERABLE status.

B. Both EDGs in one B. 1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months division inoperable. for OPERABLE offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.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 by the inoperable the inoperable EDGs, inoperable when EDGs concurrent the redundant with required feature(s) inoperability are inoperable. of redundant required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months EDG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE EDG(s).

AND B.4 Restore one EDG in 3 days the division to OPERABLE status.

(continued)

FERMI - UNIT 2 3.8-2 Amendment No. Z3',/ -VX,XI7,0,

AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. One or both EDGs in C.1 Restore both EDGs in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months both divisions one division to inoperable. OPERABLE status.

D. One offsite circuit D.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable, for OPERABLE offsite circuit. AND AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

D.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable, redundant required feature(s)

AND D.3 Restore offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status.

E. Two offsite circuits E.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable, feature(s) inoperable discovery of when the redundant Condition E required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s)

AND E.2 Restore one offsite 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months circuit to OPERABLE status.

(continued)

FERMI - UNIT 2 3.8-2a Amendment No. X'9', ,27ff

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit ............. NOTE ----------- I inoperable. Enter applicable Conditions and Required Actions of AND LCO 3.8.7, "Distribution Systems - Operating," when One or both EDGs in Condition F is entered with one Division no AC power source to one or inoperable, more 4160 V buses 64B, 64C, 65E or 65F.

F.1 Restore offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR F.2 Restore both EDGs in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the Division to OPERABLE status.

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

G.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months FERMI - UNIT 2 3.8-2b Amendment No. 2'3/, IVY

ENCLOSURE 4 to NRC-06-0040 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES Revised Pages B.3.8.1-5 B.3.8.1-5a B.3.8.1-6 B.3.8.1-7 B.3.8.1-7a B.3.8.1-7b B.3.8.1-7c B.3.8.1-7d B.3.8.1-7e B.3.8.1-8

AC Sources -Operating B 3.8.1 BASES ACTIONS 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.

A.1 To ensure a highly reliable power source remains with oneA1r-beoth ED( in one divisicv inoperable, it is necessary to verify the availability of the OPERABLE offsite circuits on 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-ea-bet4 EDG 4n. one-diviziz, 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 featureon the other division (Division 1 or 2) that is redundant to a feature supported by the inoperable EDG(s) is inoperable.

FERMI - UNIT 2 B 3.8.1-5 .Revision 30

AC Sources -Operating B 3.8.1 BASES ACTIONS (Continued)

If, at any time during the existence of this Condition (one

~-~behEDGAin one divisioninoperable), 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 3.8.1-5a Revision 30 1

AC Sources -Operating B 3.8.1 BASES ACTIONS (continued) events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE EDGs and offsite circuits are adequate to supply electrical power to the onsite Class IE Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

To minim the impact of operation with an i ableEFG, it is necessar periodically ensure t vailability of CTG 11-1. The ven ion of the st-Xus of CTG 11-1 is performed by an administr eck of breaker and line availability, and the C . ity to supply Division I loads. Since thi quired Action o specifies 'verify the status," en when CTG 11-1 is not av ble it does not resul his Required Actions being not met, ever, I discovery that CTG 11-1 is unavailable, the limi ions of Required Ac-t-in A-5 are imposed A I and A.Y.2 3

Required Action A.,,.I provides an allowance to avoid unnecessary testing of OPERABLE EDGs. If it can be determined that the cause of the inoperable EDG7<does not exist on the OPERABLE EDGs, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other EDG~sý, they are declared inoperable upon discovery, and Condition _31of LCO 3.8.1 may be entered. Once the failure is repaired, and the common cause failure no longer exists, Required Action *".'I is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG~tsý, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those EDGs.

In the event the inoperable EDGfsT are restored to OPERABLE status prior to completing either A.<.1 or A.A.2, the plant 5 "3 FERMI - UNIT 2 B 3.8.1- 6 Revision 0

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued) corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition A.

According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time to confirm that the OPERABLE EDGs are not affected by the same problem as the inoperable EDG.

.-AzrdgtcRgltr Guide 1.93 (ReQf. 6). prtinr, ntinue with no OPERABLE EDGs to one division for a perio th t should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one or both EDGs one ivision inoperable, the remaining OPERABLE EDGs a 4-v'ý offsi circuits are adequate to supply electrical po er to the ons* e Class 1E Distribution System. Required tion A.5 impos s this 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time from the iscovery of the non-Mvailability CTG 11-1. However, if C 11-1 is available to Iupply Division I loads (determin by administrative check of breaker, line availa lity. and CTG 11-1 status) Re ired Action A.5 would be t and Required Action A.6 would low the restoration ti eof 7 days.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completio Time to restor to at least one EDG in the division in OPE BLE status t es into account the capacity and capability the rem ning AC sources, reasonable time for repair , and ow probability of a DBA occurring during this perio e 7 day Completion Time to restore all EDGs to OPERABLE atus takes into account the capacity and capability of e maining AC Sources, as well as the additional reliabil y af rded by the availability of CTG 11-1.

The second Completio ime for Require Action A.6 establishes a limit n the maximum time llowed for any combinatiOn of re ired AC power sources be inoperable during any singl contiguous occurrence of ailing to meet the LCO. If C dition A is entered whiIe, f instance, an offsite circ t is inoperable, and that circui is subsequent restored OPERABLE, the LCO may alre dy have been not et for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This situation uld lead toa to 1 of 10 days. since initial failure of the CO, to resto the EDO. At this time, an offsite circuit co Id agai become inoperable, the EDG restored OPERABLE, an an ad tional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 13 days) allowed pri complete restoration of the LCO. The 10 day Completion T~ime pro~vides a limTit an the tiffl allowed in ase ife FERMI - UNIT 2 B 3.8.1-7 Revision 35

TS Bases Insert for Condition A.4 In Condition A with one EDG inoperable, the remaining OPERABLE EDGs and offsite circuits are adequate to supply electrical power to the onsite Class lE Distribution System. The 14 day Completion Time to restore the EDG to OPERABLE status takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

TS Bases Insert for new Condition B B.1 To ensure a highly reliable power source remains with both EDGs in one division inoperable, it is necessary to verify the availability of the OPERABLE offsite circuits on 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.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that both EDGs in one division are 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. Both EDGs in one division are inoperable; and

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

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

Discovering both EDGs in one division 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 events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE EDGs and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required

feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE EDGs. If it can be determined that the cause of the inoperable EDGs does not exist on the OPERABLE EDGs, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other EDGs, they are declared inoperable upon discovery, and Condition C of LCO 3.8.1 may be entered. Once the failure is repaired, and the common cause failure no longer exists, Required Action B.3.1 is satisfied. If the cause of the initial inoperable EDGs cannot be confirmed not to exist on the remaining EDGs, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of those EDGs.

In the event the inoperable EDGs are restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time to confirm that the OPERABLE EDGs are not affected by the same problem as the inoperable EDG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue with no OPERABLE EDGs to one division for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With both EDGs in one division inoperable, the remaining OPERABLE EDGs and offsite circuits are adequate to supply electrical power to the onsite Class lE Distribution System. Required Action B.4 imposes this 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time to restore one EDG in the division in OPERABLE status takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and low probability of a DBA occurring during this period.

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued) condition after disco'.'ry3 of failurc te meet the 6C9. This l*is considered reasonable for situations in whic:h Condit- A and C are entered concurrently. Th "

connector be .n the 7 day and 10 day Comp on Times means that both etion Times appl ultaneously, and the more restrictive m be met.

As in Required Action ,he Co tion Time allows for an exception to the al "time zero" fo -- inning the allowed outa ime "clock." This exceptio suits in estab> *ng the "time zero" at the time that the was i ally not met, instead of the time that Condition s 41ý V\5 -rY\ e Lo d. f With one or both EDGs on both divisions inoperable, there covy\iv. may be no remaining standby AC source. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for a significant percentage of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than-that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability,'which could result in a total loss of AC power.) Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this'level of degradation.

According to Regulatory Guide 1.93 (Ref. 6), with both divisions with EDGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining required offsite circuit on 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 not met.

However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable and Condition)ýfor two offsite circuits inoperable, is entered.

FERMI - UNIT 2 B 3.8.1-7a Revision 35

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)

Required ActionX,2, which only applies if the division cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated EDG 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 no offsite power.

The Completion Time for Required Action3.2 is intended to allow time for the operator to evaluate and repair any discovered inoperabilities. This Completion Time also allows 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. The division has no offsite power supplying its loads and

b. A required feature on the other division is inoperable.

If, at any time during the existence of this Condition (one offsite circuit inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering no offsite power to one 4160 V ESF bus of the onsite Class 1E Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with any other ESF bus that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown.

The remaining OPERABLE offsite circuit and EDGs -are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable FERMI - UNIT 2 B 3.8.1-7b Revision 35

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued) required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition* for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition, however, the remaining OPERABLE offsite circuit and EDGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The_ SAcGAnd CoMPjetiAo Timc- for Requiped Aetion G.3 tablishes a limit on the maximum time allowed for any Sntion of required AC power sources to be inopera e dunn any single contiguous occurrence of failing meet the LCD. If Condition C is entered while, for in ance, an EDG is mo rable, and that EDG is subsequentl/r eturned OPERABLE the LCO may already have been not et for up to 7 days. This sit tion could lead to a toýý of 10 days, since initial fail e to meet the LCD, restore the offsite circuit. At is time, an E could again become inoperable, the circuit estored RABLE, and an additional 7 days (for a total Of 17 ys) lowed prior to complete restoration of the LCD. e day Completion Time provides a limit on the time allowe in specified condition after discovery of failure to'eet the . This limit is considered reasonabl or situations which Conditions A and C are entered ncurrently. The connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and day Completion Times m s that both Completion Ti s apply simultaneously, and tlmore restrictiv ompletion Time must be met. As in equired Action C , the Completion Time allows for an exc tion to the n nal "time zero" for beginning the allowed out e time

'cl k." This exception results in establishing the " e ro" at the time the LCD was initially not met, instead

-t th-4im! that Comditiam C wae eintered.

FERMI -UNIT 2 B 3.8.1-7c Revision 35

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)

,k.1 andD-2 Required Action fl addresses actions to be taken in the event of inoperability of redundant required features concurrent with inoperability of two offsite circuits.

Required Action.1 reduces the vulnerability to a loss of function. The Completion Time for taking these actions is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed ith one division without offsite power (Required ActionýV2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety divisions are OPERABLE.

When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are designed with redundant safety related divisions, (i.e.,

single division systems are not included in the list).

Redundant required features failures consist of any of these features that are inoperable because any inoperability-is on a division redundant to a division with inoperable offsite circuits.

The Completion Time for Required Action2B3.1 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. All required offsite circuits are inoperable and

b. A required feature is inoperable.

If, at any time during the existence of this Condition (two offsite circuits inoperable), a required feature subsequently becomes inoperable, this-Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Conditiorne for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been FERMI - UNIT 2 B 3.8.1-7d Revision 35

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued) degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more EDGs inoperable. However, two factors tend to decrease the severity of this degradation level:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Regulatory Guide 1.93 (Ref. 6), with the available offsite AC sources two less than required by-the LCO, operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If two offsite

sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition.

.1 andf.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable, resulting in de-energization. Therefore, the Required Actions of Conditiorn are modified by a Note to indicate that when ConditionE4is entered with no AC source to any ESF bus, ACTIONS for LCO 3.8.7, "Distribution Systems -

FERMI - UNIT 2 B 3.8.1-7e Revision 35

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)

Operating," must be immediately entered. This allows Condition/Mo provide requirements for the loss of the offsite circuit and one EDG without regard to whether a division is de-energized. LCO 3.8.7 provides the appropriate restrictions for a de-energized division.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Conditionl,_or a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In Condition-findividual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition2,Ualoss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

P I and,-ý.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE The AC sources are designed to permit inspection and testing REQUIREMENTS of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, GDC 18 (Ref. 8). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the EDGs are based on the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10),

as addressed in the UFSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3740 V is 90% of the nominal 4160 V output voltage. This value,-which is FERMI - UNIT 2 B 3.8.1-8 Revision 35

NRC-06-0040, Proposed License Amendment Request to Extend the Completion Time for Technical Specification 3.8.1 for an Inoperable Emergency Diesel Generator

Contents

Text

Reference:

Subject:

SUBJECT:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

Navigation menu

NRC-06-0040, Proposed License Amendment Request to Extend the Completion Time for Technical Specification 3.8.1 for an Inoperable Emergency Diesel Generator

Text

Reference:

Subject:

SUBJECT:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

Navigation menu

Search