NRC-11-0013, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation.

License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation.

ML111010105
Person / Time
Site:	Fermi
Issue date:	04/08/2011
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-11-0013
Download: ML111010105 (27)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newportl, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 10 CFR 50.90 April 8, 2011 NRC-11-0013 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington DC 20555-0001

Reference:

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

Subject:

License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" In accordance with the provisions of Section 50.90 of Title 10 Code ofFederal Regulations (10 CFR), Detroit Edison Company (Detroit Edison) is submitting a request for an amendment to the Technical Specifications (TS) for Fermi 2.

The proposed amendment would revise the TS to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make TS Bases changes which reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. These changes are consistent with NRC-approved Revision 3 to TSTF Improved Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the FederalRegister on December 17, 2010 (Vol.

75 FR No. 242) as part of the consolidated line item improvement process (CLIIP).

• Enclosure 1 provides an evaluation of the proposed changes.

• Enclosure 2 provides the markup pages of existing TS to show the proposed changes.

USNRC NRC-11-0013 Page 2

• Enclosure 3 provides a markup of the existing TS Bases to show the proposed changes.

• Enclosure 4 provides the revised (clean) TS pages.

Detroit Edison requests approval of the proposed license amendment by approval of the proposed license amendment by October 18, 2011, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91(a)(1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91(b)(l), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Michigan Official.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

Sincerely,

Enclosures:

1. Evaluation of Proposed License Amendment

2. Markup of existing TS

3. Markup of existing TS Bases

4. Revised (Clean) TS pages cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-11-0013 Page 3 I, Joseph H. Plona, 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.

Josep9 H. Plona Site Vice President - Nuclear Generation On this day of 0 I , 2011 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.

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Enclosure 1 to NRC-11-0013 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Evaluation of the Proposed License Amendment NRC-11-0013 Page 1 1.0 Description The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable and make conforming TS Bases changes. These changes are consistent with NRC-approved Revision 3 to Technical Specification Task Force (TSTF)

Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the FederalRegister on December 17, 2010 (Vol. 75 FR No.

242) as part of the consolidated line item improvement process (CLIIP).

2.0 Proposed Change The proposed changes revise and add a new Condition D to TS 3.4.6, "RCS Leakage Detection Instrumentation," and revise the associated bases. New Condition D is applicable when the primary containment atmosphere gaseous radioactivity monitor is the only operable TS-required instrument monitoring RCS leakage, i.e., TS-required sump level and flow monitors are inoperable. New Condition D Required Actions require monitoring RCS leakage by obtaining and analyzing grab samples of the primary containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; monitoring RCS leakage using administrative means every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; and taking action to restore monitoring capability using another monitor within 7 days.

Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in Limiting Condition for Operation (LCO) Bases, delete discussion from the TS Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.6.

Detroit Edison is not proposing variations or deviations from the TS changes described in TSTF-514, Revision 3, other than minor clarifications to maintain consistency in the name description of the RCS leakage detection instrumentation currently used in the Fermi 2 TS. Similarly, the associated TS Bases are revised consistent with the proposed TS changes. Detroit Edison is not proposing any variations or deviations from the NRC staffs model safety evaluation (SE) published in the FederalRegister on December 17, 2010 (Vol. 75 FR No. 242) as part of the CLIIP Notice of Availability.

3.0 Background

NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity,"

dated August 3, 2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute leak within one hour.

Some licensees, in response to IN 2005-24, have taken action to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the primary containment atmosphere gaseous radiation monitor is often the first NRC-11-0013 Page 2 monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008 and April 14, 2009 to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radiation monitor in the LCO list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, to revise the Actions requiring additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmosphere gaseous radiation monitor is the only operable monitor.

4.0 Technical Analysis Detroit Edison has reviewed TSTF-514, Revision 3 and the model SE published on December 17, 2010 (Vol. 75 FR No. 242) as part of the CLIIP Notice of Availability. Detroit Edison has concluded that the technical bases presented in TSTF Traveler-514, Revision 3 and the model SE prepared by the NRC staff are applicable to Fermi 2.

The current Fermi 2 Technical Specification Bases, Section B 3.4.6, RCS Leakage Detection Instrumentation, states:

"Reference 2 (Regulatory Guide 1.45, May 1973) requires three separate unidentified leakage detection systems in the design. Fermi 2 meets this requirement with a drywell floor drain sump flow monitoring system, a supplementary drywell floor drain level monitor, and an airborne gaseous radioactivity monitor. The primary means of quantifying unidentified LEAKAGE in the drywell is the primary containment sump flow monitoring system.

The drywell floor drain sump flow monitoring system monitors the LEAKAGE collected in the drywell floor drain sump. This unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the closed cooling water systems, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump. The drywell floor drain sump has transmitters that supply level indications in the main control room.

The drywell floor drain sump flow monitoring system uses four basic leak detection methods to monitor the drywell floor drain sump. As the water in the sump is pumped out, the flow is metered by a flow integrator. Level switches are used to set fill time and pump-out time periods using adjustable reset timing devices. If the nominal pumping out or filling time for the sump is exceeded, an alarm is generated in the control room. In addition, if both pumps automatically start to handle the flow into the sump, an alarm is generated.

The supplementary drywell floor drain level monitor provides a continuous analog level measurement of the drywell floor drain level. This sump level monitor provides a rate-of-change measurement and alarm. The monitor has the sensitivity to detect a 1 gpm leak integrated over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period (Ref. 3: UFSAR, Section 5.2.7.1.3).

NRC-11-0013 Page 3 The primary containment atmosphere gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for airborne gaseous radioactivity. A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water LEAKAGE, is annunciated in the control room. The primary containment atmosphere gaseous radioactivity monitoring system is not capable of quantifying LEAKAGE rates; however, it is included to meet diversity requirements."

The current Fermi 2 UFSAR, Section 7.6.1.12.1, Primary Containment Radiation and Hydrogen/Oxygen Monitor Subsystem, states:

"The primary containment radiation monitor subsystem is incorporated for monitoring the radioactivity of the atmosphere within the primary containment to provide additional information related to primary coolant leak detection. This provision improves the total drywell leak-detection diversity and enhances the sensitivity of leak detection beyond that which is available with the drywell sump system. An alarm and annunciator are actuated when the radiation level reaches a predetermined setpoint level."

UFSAR, Section A. 1.45, Regulatory Guide 1.45 (May 1973). Reactor Coolant Pressure Boundary Leakage Detection System, states:

"Sources of leakage can be classified as identified and unidentified. Position 2 of this guide requires that unidentified sources be collected and monitored with a flow rate accuracy of 1 gpm. This sensitivity requirement is attained on the Fermi design by the drywell floor drain sump level rate-of-change monitor.

Regulatory Position 3 requires a minimum of three separate detection systems in the design.

These sensing systems must include a sump level and flow monitor and an airborne particulate radioactivity monitor. In addition, either an air cooler condensate flow rate or airborne gaseous radioactivity monitoring system must be included in the design. All global (i.e., general area) systems must use humidity, temperature, or pressure conditions of the containment atmosphere as the alarm setpoint indicator. The Fermi 2 design conforms with these system requirements by providing monitoring of sump level and flow, airborne gaseous radioactivity, and a supplementary drywell floor level monitor. Specific monitored parameters are sump level, sump level flow, airborne particulate matter, airborne gaseous radioactivity, primary containment pressure and temperature, low reactor water level, high steam flow indications, and drywell local temperature."

The Fermi 2 Safety Evaluation Report, NUREG-0798, Section 5.2.5, Leakage Detection, states:

"The applicant has used combinations of the following methods to monitor for RCPB leakage:

(1) Sump level and flow monitoring, (2) A supplementary drywell floor level monitor, and (3) Airborne gaseous radioactivity monitoring.

NRC-11-0013 Page 4 The applicant has used an alternative design for one of the recommendations of Regulatory Guide 1.45. The acceptability of the alternative is discussed below. Three separate detection methods were not provided as required by Regulatory Guide 1.45. In order to comply with the required leakage monitoring sensitivity of 1 gpm in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the applicant has provided for a supplementary drywell floor drain level monitor. This system is seismically qualified.

Regulatory Guide 1.45 recommended airborne particulate monitors not be used. The gaseous radioactivity monitor is to be retained. This alternative is acceptable since the two-level monitors are independent of each other and both monitor readouts can be directly converted into leakage equivalents. No significant loss of diversity in the detection methods has occurred."

It further states:

"Based on our review as described above, we conclude that the RCPB leakage detection system meets the guidelines of Regulatory Guide 1.45 and the requirements of General Design Criterion 30 and is, therefore, acceptable."

The administrative means of monitoring include diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. Detroit Edison will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: pressure and temperature in the primary containment, equipment drain and floor drain sump pump activity, drywell floor drain sump level, cooling water differential temperature of the closed cooling water system, reactor water level, and containment atmosphere radioactivity.

There are diverse alternative methods for determining that RCS leakage has not increased, from which appropriate indicators may be selected based on plant conditions. Detroit Edison will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: pressure and temperature in the primary containment, equipment drain and floor drain sump pump activity, drywell floor drain sump level, cooling water differential temperature of the closed cooling water system, reactor water level, and containment atmosphere radioactivity. Actions to verify that these indications have not increased since the required monitors became inoperable and analysis of primary containment atmospheric, grab samples are sufficient to alert the operating staff to an unexpected increase in RCS leakage.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Detroit Edison has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

An analysis of the issue of no significant hazards consideration is presented below:

NRC-11-0013 Page 5 Description of Amendment Request: The proposed amendment would revise TS 3.4.6, "RCS Leakage Detection Instrumentation" Conditions and Required Actions and the licensing basis for the primary containment atmospheric gaseous radiation monitor, as well as make associated TS Bases changes for TS 3.4.6.

Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91(a), the Detroit Edison analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1. Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the primary containment atmospheric gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the primary containment atmospheric gaseous radiation monitor. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the primary containment atmospheric gaseous radiation monitor. Reducing the amount of time the plant is allowed to NRC-11-0013 Page 6 operate with only the primary containment atmospheric gaseous radiation monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, Detroit Edison concludes that the requested change does not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment.

5.2 Applicable Regulatory Requirements A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the FederalRegister Notice of Availability on December 17, 2010 (Vol. 75 FR No. 242). Detroit Edison has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to Fermi 2.

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

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

Enclosure 2 to NRC-11-0013 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Marked-Up of the Existing TS Pages Pages: 3.4-13 through 3.4-15

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

a. Drywell floor drain sump flow monitoring system;

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

c. Drywell floor drain sump level monitoring system.

APPLICABILITY: MODES 1, 2, and 3.

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

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

inoperable.

C. Drywell floor drain C.1 --------- NOTE--------

sump level monitoring Not applicable when system inoperable, primary containment atmosphere gaseous radioactivity monitoring system is inoperable.

Perform SR 3.4.6.1. Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

FERMI - UNIT 2 3.4-13 Amendment No. 134, 163

RCS Leakage Detection Instrumentation 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE---------- D.1 Analyze grab samples Once per 12 Only applicable when the of the primary hours primary containment containment atmosphere gaseous atmosphere.

radiation monitor is the only OPERABLE monitor. AND D.2 Monitor RCS LEAKAGE by Once per 12 D. Drywell floor drain administrative means. hours sump flow monitoring system inoperable.

AND AND D.3.1 Restore drywell floor 7 days drain sump flow Drywell floor drain monitoring system to sump level monitoring OPERABLE status.

system inoperable.

OR D.3.2 Restore drywell floor 7 days drain sump level monitoring system to OPERABLE status DE. Primary containment DE.1 Restore primary 30 days atmosphere gaseous containment radioactivity atmosphere gaseous monitoring system radioactivity inoperable, monitoring system to OPERABLE status.

AND OR Drywell floor drain sump level monitoring DE.2 Restore drywell floor 30 days system inoperable, drain sump level monitoring system to OPERABLE status.

(continued)

FERMI - UNIT 2 3.4-14 Amendment No. 134

RCS Leakage Detection Instrumentation 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME EF. Required Action and EF.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, AND B, C, D, or ED not met. EF.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> FG. All required leakage FG.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Perform a CHANNEL CHECK of required primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere gaseous radioactivity monitoring system.

SR 3.4.6.2 Perform a CHANNEL FUNCTIONAL TEST of 31 days required leakage detection instrumentation.

SR 3.4.6.3 Perform a CHANNEL CALIBRATION of required 18 months leakage detection instrumentation.

FERMI - UNIT 2 3.4-15 Amendment No. 134

Enclosure 3 to NRC-11-0013 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Mark-Up Pages of the Existing TS Bases Pages: B 3.4.6-1 through B 3.4.6-8

RCS Leakage Detection Instrumentation B 3.4.6 BASES B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of 10 CFR 50, Appendix A (Ref. 1), requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45, Revision 0, (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref. 2).

Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates. In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms. The Bases for LCO 3.4.4, "RCS Operational LEAKAGE," discuss the limits on RCS LEAKAGE rates.

Systems for separating the LEAKAGE of an identified source from an unidentified source are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action.

Reference 2 requires three separate unidentified leakage detection systems in the design. Fermi 2 meets this requirement with a drywell floor drain sump flow monitoring system a supplementary drywell floor drain level monitor, and a airborne gaseous radioactivity monitor.LEAKAGE from the RCPB inside the drywell is detected by at least one of two or three independently monitored variables, such as sump level changes and drywell gaseous radioactivity level. The primary means of quantifying unidentified LEAKAGE in the drywell is the primary containment sump flow monitoring system.

The drywell floor drain sump flow monitoring system monitors the LEAKAGE collected in the drywell floor drain sump. This unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the closed FERMI - UNIT 2 B 3.4.6-1 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES BACKGROUND (continued) cooling water systems, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump. The drywell floor drain sump has transmitters that supply level indications in the main control room.

The drywell floor drain sump flow monitoring system uses four basic leak detection methods to monitor the drywell floor drain sump. As the water in the sump is pumped out, the flow is metered by a flow integrator. Level switches are used to set fill time and pump-out time periods using adjustable reset timing devices. If the nominal pumping out or filling time for the sump is exceeded, an alarm is generated in the control room. In addition, if both pumps automatically start to handle the flow into the sump, an alarm is generated.

The supplementary drywell floor drain level monitor provides a continuous analog level measurement of the drywell floor drain level. This sump level monitor provides a rate-of-change measurement and alarm. The monitor has the sensitivity to detect a 1 gpm leak integrated over a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period (Ref. 3).

The primary containment atmosphere gaseous radioactivity monitoring system continuously monitors the primary containment atmosphere for airborne gaseous radioactivity.

A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water LEAKAGE, is annunciated in the control room. The primary containment atmosphere gaseous radioactivity monitoring system is not capable of quantifying LEAKAGE rates; however, it is included to meet diversity requirements.

APPLICABLE A threat of significant compromise to the RCPB exists if the SAFETY barrier contains a crack that is large enough to propagate ANALYSES rapidly. LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB (Refs. 4 and 5). Each of the leakage detection systems inside the drywell is designed with the capability of detecting LEAKAGE less than the established LEAKAGE rate limits and providing appropriate alarm of excess LEAKAGE in the control room.

A control room alarm allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary, shut down the reactor for further investigation and FERMI - UNIT 2 B 3.4.6-2 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES APPLICABLE SAFETY ANALYSES (continued) corrective action. The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref. 6).

Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

The other monitoring systems provide early alarms to the will be mado to determine the extent of any correctinve action that may be required. With the leakage detection Rsyste indicates possible LEAKAGE de radatiis RCPB TdegradedThis LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires 3 instruments to be OPERABLE.

The drywell floor drain sump flow monitoring system is required to quantify the unidentified LEAKAGE rate from the RCS. Thus, for the system to be considered OPERABLE, it must be capable of determining the leakage rate. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell floor drain sump and it may take longer than one hour to detect 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump flow monitoring OPERABILITY.

The reactor coolant contains radioactivity that, when released to the primary containment, can be detected by the gaseous primary containment atmosphere radioactivity monitor. The airborne radioactivity detection system is included for monitoring gaseous activities because of its sensitivity and rapid response to RCS LEAKAGE, but has recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel FERMI - UNIT 2 B 3.4.6-3 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES LCO (continued) element cladding containment or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous primary containment atmosphere radioactivity monitor to detect 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation.

However, the gaseous containment primary atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design of the monitor (Ref. 7).

The drywell floor drain sump level monitoring system is capable of quantifying the unidentified LEAKAGE rate from the RCS. The system is considered to be OPERABLE, when it is capable of detecting an inleakage of 1 gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell floor drain sump and it may take longer than one hour to detect 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump level monitoring OPERABILITY.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell floor drain sump flow monitoring system, in combination with the gaseous primary containment atmosphere radioactivity monitor, and the drywell floor drain sump level monitoring system provides an acceptable minimum.

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

ACTIONS A.1 With the drywell floor drain sump flow monitoring system inoperable, the plant has lost one means to quantify leakage. However, the primary containment atmosphere gaseous radioactivity monitoring system and the drywell floor drain sump level monitoring system will provide indication of changes in leakage.

FERMI - UNIT 2 B 3.4.6-4 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES ACTIONS (continued)

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

B.1 With the primary containment atmosphere gaseous radioactivity monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the plant may continue operation since at least one other form of drywell leakage detection (i.e., drywell floor drain sump level monitoring system) is available.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect LEAKAGE.

C.1 With the drywell floor drain sump level monitoring system inoperable, SR 3.4.6.1 must be performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to provide periodic information of activity in the primary containment at a more frequent interval than the routine Frequency of SR 3.4.6.1. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action to be not applicable if the primary containment atmosphere gaseous radioactivity monitoring system is inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment.

D.1, D.2, D.3.1, and D.3.2 With the drywell floor drain sump flow monitoring system and the drywell floor drain sump level monitoring system inoperable, the only means of detecting LEAKAGE is the primary containment atmosphere gaseous radiation monitor. A Note clarifies this applicability of the Condition. The primary containment atmosphere gaseous radiation monitor typically cannot detect a 1 gpm leak within one hour when FERMI -UNIT 2 B 3.4.6-5 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES ACTIONS (continued)

RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection.

Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the primary containment atmosphere must be taken and analyzed and monitoring of RCS leakage by administrative means must be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to provide alternate periodic information.

Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. It is not necessary to utilize all of these methods, but a method or methods should be selected considering the currant plant conditions and historical or expected sources of unidentified leakage. The administrative methods are pressure and temperature in the primary containment, equipment drain and floor drain sump pump activity, drywell floor drain sump level, cooling water differential temperature of the closed cooling water system, reactor water level, and containment atmosphere radioactivity. These indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

DE.1 and DE.2 With both the primary containment atmosphere gaseous radioactivity monitoring system and the drywell floor drain sump level monitoring system inoperable, the only means of detecting LEAKAGE is the drywell floor drain sump flow monitoring system. This condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

FERMI - UNIT 2 B 3.4.6-6 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES ACTIONS (continued)

EF.1 and EF.2 If any Required Action of Condition A, B, C, D or DE cannot be met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems.

FG.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere gaseous radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.6.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.6.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Operating experience has proven this Frequency is acceptable.

FERMI -UNIT 2 B 3.4.6-7 Revision 0

RCS Leakage Detection Instrumentation B 3.4.6 BASES REFERENCES 1. 10 CFR 50, Appendix A, GDC 30.

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems,"

May 1973.

3. UFSAR, Section 5.2.7.1.3.

4. GEAP-5620, April 1968.

5. NUREG-75/067, October 1975.

6. UFSAR, Section 5.2.7.4.3.3.

7. NUREG/CR-6861, December 2004 FERMI - UNIT 2 B 3.4.6-8 Revision 0

Enclosure 4 to NRC-11-0013 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Revised (Clean) TS Pages: 3.4-13 through 3.4-15

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

a. Drywell floor drain sump flow monitoring system;

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

c. Drywell floor drain sump level monitoring system.

APPLICABILITY: MODES 1, 2, and 3.

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

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

inoperable.

C. Drywell floor drain C.1 --------- NOTE--------

sump level monitoring Not applicable when system inoperable, primary containment atmosphere gaseous radioactivity monitoring system is inoperable.

Perform SR 3.4.6.1. Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued)

FERMI - UNIT 2 3.4-13 Amendment No. 134, 163

RCS Leakage Detection Instrumentation 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

---

NOTE---------- D.1 Analyze grab samples Once per 12 Only applicable when the of the primary hours primary containment containment atmosphere gaseous atmosphere.

radiation monitor is the only OPERABLE monitor. AND D.2 Monitor RCS LEAKAGE by Once per 12 D. Drywell floor drain administrative means. hours sump flow monitoring system inoperable.

AND AND D.3.1 Restore drywell floor 7 days drain sump flow Drywell floor drain monitoring system to sump level monitoring OPERABLE status.

system inoperable.

OR D.3.2 Restore drywell floor 7 days drain sump level monitoring system to OPERABLE status E. Primary containment E.1 Restore primary 30 days atmosphere gaseous containment radioactivity atmosphere gaseous monitoring system radioactivity inoperable, monitoring system to OPERABLE status.

AND OR Drywell floor drain sump level monitoring E.2 Restore drywell floor 30 days system inoperable, drain sump level monitoring system to OPERABLE status.

(continued)

FERMI - UNIT 2 3.4-14 Amendment No. 134

RCS Leakage Detection Instrumentation 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, AND B, C, D, or E not met.

F.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. All required leakage G.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Perform a CHANNEL CHECK of required primary 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> containment atmosphere gaseous radioactivity monitoring system.

SR 3.4.6.2 Perform a CHANNEL FUNCTIONAL TEST of 31 days required leakage detection instrumentation.

SR 3.4.6.3 Perform a CHANNEL CALIBRATION of required 18 months leakage detection instrumentation.

FERMI - UNIT 2 3.4-15 Amendment No. 134