NRC-13-0012, License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

ML13108A307
Person / Time
Site:	Fermi
Issue date:	04/17/2013
From:	Conner J DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-13-0012
Download: ML13108A307 (46)

Text

J. Todd Coiner Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: conneij@dteenergy.com DTE Energy" 7i 10 CFR 50.90 April 17, 2013 NRC-13-0012 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

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

2) FederalRegister Notice of Availability of Technical Specification Improvement to Modify Requirements Regarding Control Room Envelope Habitability Using the Consolidated Line Item Improvement Process, published January 17, 2007 (72 FR 2022)

Subject:

License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, DTE Electric Company (DTE) is submitting a request for an amendment to the technical specifications (TS) for Fermi 2.

The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. The proposed amendment is consistent with the Consolidated Line Item Improvement that adopts changes to TS Section 3.7.3, Control Room Emergency Filtration (CREF) System, and adds Technical Specification Section 5.5.14, Control Room Envelope Habitability Program, consistent with TSTF-448, Revision 3. provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean)

TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed changes, for information only.

USNRC NRC-13-0012 Page 2 DTE requests approval of the proposed License Amendment by October 18, 2013, with the amendment being implemented within 60 days.

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

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

Zackary W. Rad of my staff at (734) 586-5076.

Sincerely,

Enclosures:

1. Evaluation of the Proposed License Amendment

2. Marked-Up pages of Fermi 2's Operating License and Existing TS

3. Revised (clean) Fermi 2 Operating License and TS pages

4. Marked-up pages of Fermi 2 TS Bases (for information only) cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0012 Page 3 I, J. Todd Conner, 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.

J. T dd C nner Site i President, Nuclear Generation On this / 7 day of April, 2013 before me personally appeared J. Todd Conier, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. MARSHALL NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun 14, 2013 ACTING INCOUNTY OF

Enclosure 1 to NRC-13-0012 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Evaluation of the Proposed License Amendment

Enclosure 1 to NRC-13-0012 Page 1 Evaluation of the Proposed License Amendment 1.0 Description The proposed amendment would modify technical specification (TS) requirements related to control room envelope habitability in TS 3.7.3, "Control Room Emergency Filtration (CREF)

System" and TS Section 5.5, "Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-448, Revision 3. The availability of this TS improvement was published in the FederalRegister on January 17, 2007 as part of the consolidated line item improvement process (CLIIP). This change is consistent with the CLIIP except as described in Section 2.2 of this enclosure.

2.0 Assessment 2.1 Applicability of Published Safety Evaluation DTE Electric Company (DTE) has reviewed the safety evaluation dated January 9, 2007, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-448. DTE has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of the changes to the Fermi 2 TS.

2.2 Optional Changes and Variations DTE is not proposing any variations or deviations from the applicable parts of the NRC staff's model safety evaluation dated January 9, 2007. Evaluations 1, 5 and 6 of the safety evaluation dated January 9, 2007 are applicable to the proposed changes to Fermi 2 TS 3.7.3, "Control Room Emergency Filtration (CREF) System."

DTE is proposing the following variations or deviations from the TS changes described in TSTF-448, Revision 3, to provide consistency with the Fermi 2 licensing basis:

1. The proposed Required Action B.2 verifies that mitigating actions ensure Control Room Envelope (CRE) occupants are protected from smoke hazards, instead of verifying that CRE occupant exposures to smoke hazards will not exceed limits. This deviation is consistent with the NRC staff's model safety evaluation dated January 9, 2007 and Reference 6. Additionally, Reference 3, item 5, states: "The reference to smoke may be removed because quantitative limits on exposure to smoke do not exist."

to NRC-13-0012 Page 2

2. The proposed last sentence of TS 5.5.14.d regarding trending the CRE pressure measurement relative to external areas states: "The results shall be trended and assessed every 18 months" instead of: "The results shall be trended and used as part of the [18]

month assessment of the CRE boundary." This deviation is made as a clarification to distinguish the assessment of the pressure measurement trends from the CRE boundary assessment performed 3 years after successful inleakage testing as delineated in Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Section C.1, and specified by TS 5.5.14.c. The proposed wording is consistent with the NRC position in Reference 7.

3. The current TS Surveillance Requirement (SR) 3.7.3.3 for visually inspecting silicone sealant on CREF system ductwork is proposed to be deleted. This SR represents a maintenance activity that will be addressed by the Control Room Envelope Habitability Program in TS 5.5.14, as applicable.

4. The current Fermi 2 Operating License Condition C.(22) is proposed to be deleted.

Tracer Gas testing at Fermi 2 has successfully been performed in 2005 and 2011 consistent with this license condition; however, future tests and assessments will be performed in accordance with the proposed SR 3.7.3.4 and the program in TS 5.5.14.c.

5. A current historical footnote in the Fermi 2 TS 3.7.3 associated with Condition B is proposed to be deleted. The footnote allowed a one-time extension of the Completion Time in May 2010.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements DTE proposes the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.14.c.(i), the assessment of CRE habitability as required by Specification 5.5.14.c.(ii),

and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:

a) The first performance of SR 3.7.3.4, in accordance with Specification 5.5.14.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer gas test.

to NRC-13-0012 Page 3 b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer gas test.

c) The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 Regulatory Analysis 3.1 No Significant Hazards Consideration Determination DTE has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister dated January 9, 2007 as part of the CLIIP. DTE has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Fermi 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Commitments There are no new regulatory commitments contained in this submittal.

4.0 Environmental Evaluation DTE has reviewed the environmental evaluation included in the model safety evaluation dated January 9, 2007 as part of the CLIIP. DTE has concluded that the staff's findings presented in that evaluation are applicable to Fermi 2 and the evaluation is hereby incorporated by reference for this application.

to NRC-13-0012 Page 4 5.0 References

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

2. FederalRegister Notice of Availability of Technical Specification Improvement to Modify Requirements Regarding Control Room Envelope Habitability Using the Consolidated Line Item Improvement Process, published January 17, 2007 (72 FR 2022).

3. Memorandum from Timothy J. Kobetz, Chief Technical Specification Branch, NRR, to TSTF, Summary of NRC Staff Meeting With Industry on April 20, 2006, Regarding TSTF-448, Control Room Habitability (ML061310293).

4. Letter from William T. O'Conner, Jr. to Document Control Desk (USNRC) dated December 8, 2003, NRC-03-0090, "Detroit Edison's 180-Day Response to Generic Letter 2003-1, Control Room Habitability" (ML033510077).

5. Letter from David H. Jaffe, Senior Project Manager, to Donald K. Cobb, Assistant Vice President-Nuclear Generation, dated September 20, 2006, "FERMI 2 - Response to Generic Letter 2003-01, "Control Room Habitability" (TAC No. MB9804)"

(ML062400078).

6. Turkey Point Plant, Unit Nos. 3 and 4 - Issuance of Amendments Regarding Control Room Habitability Technical Specification Task Force (TSTF)-448 (TAC Nos. ME4277 and ME4278) (ML12067A176).

7. Email from J. Paige (NRC) to Bob Tomonto (FPL), "Turkey Point Units 3 and 4:

Requests for Additional Information," June 16, 2011 (ML11167A291).

Enclosure 2 to NRC-13-0012 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Marked-Up pages of Fermi 2's Operating License and Existing TS TS Pages:

3.7-6 3.7-7 3.7-8 3.7-9 3.7-10 5.0-19 Operating License Pages:

6 and 7

CREF System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Filtration (CREF) System LCO 3.7.3 The CREF System shall be OPERABLE.

---

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREF subsystem A.1 Restore CREF 7 days inoperable for reasons subsystem to OPERABLE other than Condition status.

B.

B. TweOne or more CREF B.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable actions.

CREeentrel-roem boundary in MODE 1, 2, AND or 3.

B.2 Verify mitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards.

AND B.13 Restore 24-her-sp90 days CREcentre1-rem Eoundary to OPERABLE status.

FERMI - UNIT 2 3.7-6 Amendment No. 14. 144, 1-49, 182

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 or AND B not met in MODE 1, 2, or 3. C.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 /> (continued)

ERMomletion Time is extcnded onetime to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 4 to omplete Repairs of Dlivision 2 Return Air Fan in May 2010.

FERM - NIT 3.-6 AendentNo. 4, 44, 49,.18

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and ------------- NOTE-------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A -----------------------------

not met during movement of recently D.1 Place OPERABLE CREF Immediately irradiated fuel subsystem in assemblies in the recirculation mode.

secondary containment, or during OPDRVs. OR D.2.1 Initiate action to Immediately suspend OPDRVs.

AND

---

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

Not required for a CREF System or subsystem inoperable due to failure to provide the required filtration efficiency, or due to replacement of charcoal filtration media.

D.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

(continued)

NO CHANGES TO THIS PAGE FERMI - UNIT 2 3.7-7 Amendment No. ,4, /f4 A9', 462

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREF subsystems or E.1 Enter LCO 3.0.3. Immediately a non-redundant component or portion of the CREF System inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

F. Two CREF subsystems or -----------NOTE----------

a non-redundant LCO 3.0.3 is not applicable.

component or portion -----------------------------

of the CREF System inoperable during F.1 Initiate action to Immediately movement of recently suspend OPDRVs.

irradiated fuel assemblies in the AND secondary containment, or during OPDRVs. ------------ NOTE-------------

Not required for a CREF OR System or subsystem inoperable due to failure to One or more CREF provide the required subsystems inoperable filtration efficiency, or due due to an inoperable to replacement of charcoal CRE boundary during filtration media.

movement of recently -----------------------------

irradiated fuel assemblies in the F.2 Suspend movement of Immediately secondary containment recently irradiated or during OPDRVs. fuel assemblies in the secondary containment.

FERMI - UNIT 2 3.7 -8 Amendment No. XZPX.fA'A,1 .162

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate one CREF subsystem for 10 31 days on a continuous hours with the heater operating STAGGERED TEST and operate the other CREF subsystem BASIS for 15 minutes.

SR 3.7.3.2 ------------------ NOTE---------------------

When the CREF system is made inoperable in MODE 1, 2, or 3 solely for VFTP required surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Perform required CREF filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Visually inpect slcone sealant on 12-months accessi ble porCtons of-CREF system duc it work outside the control room that are a conditions and for whic 1h ptential in-leakage wouitl not recei ve full filtration.

SR 3.7.3.43 Verify each CREF subsystem actuates on an 18 months actual or simulated initiation signal.

(continued)

FERMI - UNIT 2 3.7-9 Amendment No. -134

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.3.54 Verify ah CREF subsystm can maintain a 18-menths positieprssuire of 0.125 i nce wate.

-a~cf r on -a en-a

&TAGGERED during thc recirculation modle of operat ion TEST-BASISIn at a-makeup flow rateof- 1800 cfm.Perform accordance with required CRE unfiltered air inleakage the Control testing in accordance with the Control Room Room Envelope Envelope Habitability Program. Ha ita i ity Program FERMI - UNIT 2 3.7-10 Amendment No. 1-34. 18, 162

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Primary Containment Leakage Rate Testing Program.

f. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 High Density Spent Fuel Racks A program shall be provided for the high density storage racks containing Boraflex as the neutron absorber, which will ensure that any unanticipated degradation of the Boraflex will be detected and will not compromise the integrity of the racks.

5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filtration (CREF) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii)assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

(continued)

FERMI - UNIT 2 5.0-19 Amendment No. 1X. 141

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and assessed every 18 months.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

FERMI - UNIT 2 5.0-19a Amendment No.

(21) The schedule for performing surveillance requirements (SRs) that are new or revised in Amendment No. 134 shall be as follows:

- For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

- For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

- For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

- For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

(22) DeletedDE=o hall perform an integrated traccr gas test to masr Control Room i nlcacu--ing methds desribed Amn ASTM "Standard N7o. t-,,

Test Method for Determining Air Change in a Single Z ot by Means of aTaer Gas Dilution" n-This testll be performed by Marc lh 31T 2005.

erio dic assessm TT ents s testing will ft and Vfl be performed G1ff7Gl 7IFthr in accordance with the guidance pro'vided in NRC Regulator,' Guide 1.197, (May 2003)

"Demeotrating ConRtrol Room EnV&lope Integrity At Nuc1lear PoEr Reactors," Section ID,implementation, using the six year cycle rdescribed.

In accorrdance with the RegulatorFy G uirde, a self assessment will be performed after three years and a periodic test after 6.years.

Amendment No. 1*7, 1-3+ 1f62 Revised by letter dated August 23, 2007

(23) Mitiqation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize releases to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (24) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training plan, as appropriate.

(25) Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.14.c.(i), the assessment of CRE habitability as required by Specification 5.5.14.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:

a. The first performance of SR 3.7.3.4, in accordance with Specification 5.5.14.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer qas test.

Amendment No.

Revised by letter dated August 23, 2007

b. The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer qas test.

c. The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Amendment No.

Revised by letter dated August 23, 2007

Enclosure 3 to NRC-13-0012 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Revised (clean) Fermi 2 Operating License and TS pages TS Pages:

3.7-6 3.7-7 3.7-8 3.7-9 3.7-10 5.0-19 5.0-19a Operating License Pages:

6 and 7

CREF System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Emergency Filtration (CREF) System LCO 3.7.3 The CREF System shall be OPERABLE.

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREF subsystem A.1 Restore CREF 7 days inoperable for reasons subsystem to OPERABLE other than Condition status.

B.

B. One or more CREF B.1 Initiate action to Immediately subsystems inoperable implement mitigating due to inoperable CRE actions.

boundary in MODE 1, 2, or 3. AND B.2 Verify mitigating 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

FERMI - UNIT 2 3.7-6 Amendment No. 144, 149, 482

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 or AND B not met in MODE 1, 2, or 3. C.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 /> D. Required Action and ------------ NOTE -------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A -----------------------------

not met during movement of recently D.1 Place OPERABLE CREF Immediately irradiated fuel subsystem in assemblies in the recirculation mode.

secondary containment, or during OPDRVs. OR D.2.1 Initiate action to Immediately suspend OPDRVs.

AND

---

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

Not required for a CREF System or subsystem inoperable due to failure to provide the required filtration efficiency, or due to replacement of charcoal filtration media.

D.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

(continued)

FERMI - UNIT 2 3.7-7 Amendment No. ,,j.,,4AA9',.

. 62

CREF System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREF subsystems or E.1 Enter LCO 3.0.3. Immediately a non-redundant component or portion of the CREF System inoperable in MODE 1, 2, or 3 for reasons other than Condition B.

F. Two CREF subsystems or ------------ NOTE ------------

a non-redundant LCO 3.0.3 is not applicable.

component or portion -----------------------------

of the CREF System inoperable during F.1 Initiate action to Immediately movement of recently suspend OPDRVs.

irradiated fuel assemblies in the AND secondary containment, or during OPDRVs. ------------ NOTE-------------

Not required for a CREF OR System or subsystem inoperable due to failure to One or more CREF provide the required subsystems inoperable filtration efficiency, or due due to an inoperable to replacement of charcoal CRE boundary during filtration media.

movement of recently -----------------------------

irradiated fuel assemblies in the F.2 Suspend movement of Immediately secondary containment recently irradiated or during OPDRVs. fuel assemblies in the secondary containment.

FERMI - UNIT 2 3.7-8 Amendment No, If4, X44, 10, 1462

CREF System 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Operate one CREF subsystem for 10 31 days on a continuous hours with the heater operating STAGGERED TEST and operate the other CREF subsystem BASIS for > 15 minutes.

SR 3.7.3.2 ------------------ NOTE---------------------

When the CREF system is made inoperable in MODE 1, 2, or 3 solely for VFTP required surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Perform required CREF filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.7.3.3 Verify each CREF subsystem actuates on an 18 months actual or simulated initiation signal.

SR 3.7.3.4 Perform required CRE unfiltered air In accordance inleakage testing in accordance with the with the Control Room Envelope Habitability Program. Control Room Envelope Habitability Program FERMI - UNIT 2 3.7-9 Amendment No. 134

i THIS PAGE INTENTIONALLY LEFT BLANK f

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E i

E i

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F

'r FERMI - UNIT 2 3.7-10 Amendment No. 434, 4-58, 462-

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

e. The provisions of SR 3.0.2 do not apply to the test frequencies in the Primary Containment Leakage Rate Testing Program.

f. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 High Density Spent Fuel Racks A program shall be provided for the high density storage racks containing Boraflex as the neutron absorber, which will ensure that any unanticipated degradation of the Boraflex will be detected and will not compromise the integrity of the racks.

5.5.14 Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Filtration (CREF) System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

(continued)

FERMI - UNIT 2 5.0-19 Amendment No. 1X4. 141

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CREF System, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and assessed every 18 months.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

FERMI - UNIT 2 5.0-19a Amendment No.

(21) 'The schedule for performing surveillance requirements (SRs) that are new or revised in Amendment No. 134 shall be as follows:

- For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.

- For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

- For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.

- For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to the implementation of this amendment.

(22) Deleted (23) Mitiqation Strateqy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Amendment No. 4-147, 434, 462 Revised by letter dated August 23, 2007

(c) Actions to minimize releases to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (24) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training plan, as appropriate.

(25) Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.14.c.(i), the assessment of CRE habitability as required by Specification 5.5.14.c.(ii), and the measurement of CRE pressure as required by Specification 5.5.14.d, shall be considered met. Following implementation:

a. The first performance of SR 3.7.3.4, in accordance with Specification 5.5.14.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer gas test.

b. The first performance of the periodic assessment of CRE habitability, Specification 5.5.14.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 28, 2011, the date of the most recent successful tracer gas test.

c. The first performance of the periodic measurement of CRE pressure, Specification 5.5.14.d, shall be within 18 months, plus the 138 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Amendment No.

Revised by letter dated August 23, 2007

Enclosure 4 to NRC-13-0012 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process Marked-up pages of Fermi 2 TS Bases (for information only)

B 3.7.3-1 B 3.7.3-2 B 3.7.3-3 B 3.7.3-4 B 3.7.3-5 B 3.7.3-6 B 3.7.3-6a B 3.7.3-7 B 3.7.3-8 B 3.7.3-9

CREF System B 3.7.3 B 3.7 PLANT SYSTEMS B 3.7.3 Control Room Emergency Filtration (CREF) System BASES BACKGROUND The CREF System provides a radiologicall controlled envirenmet frm hich theu an be safely operated following a Design Basis Accident (DBAprotected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREF System is a single system that performs its safety function with redundant active components and non-redundant passive components, including a Control Room Envelope (CRE) boundary that limits the inleakage of unfiltered air. The CREF also includes associated ductwork, dampers, doors, barriers and instrumentation. During emergency operation, two emergency filter trains are automatically put in operation. The emergency makeup filter train consists of a mist eliminator, redundant divisional electric heater, a high efficiency particulate air (HEPA) filter, a two inch deep charcoal adsorber, and a second HEPA filter. The emergency recirculation filter train consists of a prefilter, a HEPA filter, a four inch deep charcoal adsorber, and a second HEPA filter. The mist eliminator removes water droplets from the airstream. Prefilters and HEPA filters remove particulate matter, which may be radioactive. The charcoal adsorbers provide a holdup period for gaseous iodine, allowing time for decay.

Air is drawn through these emergency filters by one of two redundant divisional emergency recirculation air fans.

Redundant air operated dampers are provided to direct the air to the proper components.

The redundant active components of the CREF System are independent and divisionally separated. Each division operates as a unit and therefore can be considered separate subsystems, although they share non-redundant passive components.

The emergency makeup air filter train is sized for a flow rate of 3000 cfm, but is restricted to a maximum emergency intake flow rate of 1800 cfm. The emergency recirculation filter train is sized for a flow rate of 3000 cfm.

FERMI - UNIT 2 B 3.7.3-1 Revision 0

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions.

This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE.

The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

The CREF System normal mode supplies outside air to mix with recirculated air, bypassing the emergency filters, during normal unit operations to maintain the centrel-reemCRE environment. Upon receipt of the initiation signal(s)

(indicative of conditions that could result in radiation exposure to control room persennelCRE occupants), the CREF System FERMI - UNIT 2 B 3.1.3 -1 Revision 0

CREF System B 3.7.3 BASES BACKGROUND (continued) automatically switches to the recirculation mode of operation to preventminimize infiltration of contaminated air into the centre1-r-eemCRE. A part of the recirculated air is routed through the emergency recirculation filter train. Outside air is taken in at one of two emergency outside air ventilation intakes and is passed through the emergency makeup filter train before being mixed with recirculated air. The air mixture is then returned to the centr-el--remCRE.

The CREF System is designed to maintain a habitable-he contre--eem environment in the CRE for a 30 day continuous occupancy after a DBA without exceeding 5 rem wh--e-bedy dose or its equt'alent to any prt of the bedyTotal Effective Dose Equivalent (TEDE). The recirculation mode with an outside air flow rate of s 1800 cfm will pressurize the £ent-el--r-GCRE to about 0.250 +/- 0.125 inches water gauge te-preventrelative to external areas adjacent to the CRE boundary to minimize infiltration of air from a surrounding areas adjacent to the CRE boundary. CREF System operation in maintaining ^entre1-

-eemCRE habitability is discussed in the UFSAR, Chapters 6 and 9 (Refs. 1 and 2, respectively).

APPLICABLE The ability of the CREF System to maintain the SAFETY ANALYSES habitability of the centrel-reemCRE is an explicit assumption for the safety analyses presented in the UFSAR, Chapters 6 and 15 (Refs. 1 and 3, respectively). The recirculation mode of the CREF System is assumed to operate following a DBAloss of coolant acci, fuel handling accident i nvolving recentl y irradiated fuel, main steam line break, and control rod drop accident, as discussed in the UFSAR 4Ref-316.4.2.3.1 (Ref. 4). "Recently irradiated fuel" i fuel th asoc ui part of a critical ceacto corewiof the previous days Handling new (non Rradiated fuel bundles over the oen reactir core r the spent fuel polis subject ofthe same -requ irements of handling r-.ecently _irradiated fuel, aslong as any fuel in the core or fuel pl isrecently irradiated. The radiological doses to control room pesneCRE occupants as a result of the various DBAs are also summarize in Reference 3. No single active failure will cause the loss of outside or recirculated air from the centre-reemCRE.

The CREF System provides protection from smoke and hazardous FERMI - UNIT 2 B 3.7.3-2 Revision 52

chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 5 and 10). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 6 and 10).

The CREF System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

FERMI - UNIT 2 B 3.7.3-2 Revision 52

CREF System B 3.7.3 BASES LCO The non-redundant passive components and both divisions of the redundant active components of the CREF System must be OPERABLE to ensure that the system safety function can be performed assuming any active single failure. Total system failure such as from a loss of both ventilation subsystems or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem whlid (rtseuven any part of the bedy)TEDE to the cntrol room-eperatorsCRE occupants in the event of a DBA.

Redundant components, of which both divisions must be OPERABLE, include:

a. Emergency inlet air heater;

b. Emergency recirculation fans;

c. Return fans;

d. Supply fans;

e. Emergency air intakes; and

f. Air handling dampers needed to support the system operation.

Non-redundant components required to be OPERABLE include:

a. Emergency recirculation air filter train;

b. Emergency makeup air filter train; and

c. Ductwork and other system structures needed to form the necessary air flow paths.

In-addition, the-scontrol room-boundary must be maintained, including _the integrity of the walls, floors, celings ducEtwo rk, and access doors.

In order for the CREF subsystems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a note allowing the centre-1-PemCRE boundary to be opened intermittently under administrative controls. This note only applies to openings in the CRE boundary that can be rapidly restored to the design condition such as doors, hatches, floor plugs and access panels. For entry and exit through doors, the a ministrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, FERMI - UNIT 2 B 3.7.3-3 Revision 12

these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the 0 erators in the CREeentpel-reem. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for contro-romCRE isolation is indicated.

APPLICABILITY In MODES 1, 2, and 3, the CREF System must be OPERABLE to ensure that the CRE will remain habitableont-r-ol eperator expsure during and following a DBA, since the DBA could lead to a fission product release.

FERMI - UNIT 2 B 3.7.3-3 Revision 12

CREF System B 3.7.3 BASES APPLICABILITY (Continued)

In MODES 4 and 5, the probability and consequences of a DBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREF System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:

a. During operations with a potential for draining the reactor vessel (OPDRVsTH and

b. During movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the CREF System is only required to be OPERABLE during fuel handling involving recently irradiated fuel. "Recently irradiated fuel" is fuel that has occupied part of a critical reactor core within the previous 6.3 days. Handling new (non-irradiated) fuel bundles over the open reactor core or the spent fuel pool is subject to the same requirements of handling recently irradiated fuel, as long as any fuel in the core or fuel pool is recently irradiated.

ACTIONS A.1 With one CREF subsystem inoperable, for reasons other than an inoperable CRE boundary, the inoperable CREF subsystem must be restored to OPERABLE status within 7 days. With the unit in this condition, the remaining OPERABLE CREF subsystem is adequate to perform the CRE occupantcenterel room radiation protection function. However, the overall reliability is reduced because a single-failure in the OPERABLE subsystem could result in loss of the-redueed CREF System functioneapab]ity. The 7 day Completion Time is based onthelow probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

FERMI - UNIT 2 B 3.7.3-4 Revision 52

CREF System B 3.7.3 BASES ACTIONS (Continued)

B.1, B.2 and B.3 If the control Poom-boundary is in OD Itopehaele 1 2 or

, fthe REF system caot p fotnmi t cointended f snction h CR mtution be taken t s RE canOPEsBLE Cntm boundary within 21-hours. Duig the perid -that the colonalr mesugrear c tnt h the intent of hC19) liens-n uisznased to pro consqel nr operalods tom poten hazar d, sh as raedi pactive cotainatio n oxic chemials, smoke, tempiats ur and relative humidity, and physiceal secuiy Preplane maues should be available to aa drdress these coce n o inteninal and unintentio-nal entry inte theconditin. The 24 hurCormpletion Time is reasonable based on the loew probai l ity of a DBA occurri ng during thie period t th AndCEtheb usof d, copensar measures. The 21hsr e nitien T o imp icalty ratonabletie diagnose pn R possibly fro the the test mest roblemswith the ontmust be bound It f2the unfiltered inleakage of potentially contaminated a t st the CRE boundary and into the CE can result in CRE occupant radiological dose greater than the calculated dose o the licensing basis analyses of DB consequences (allowed to be up to 5rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the GkE boundary is inoperable. Actions must be taken to restore an OPE tBLE CRE boundary within 90days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards o a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 ours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose ofte licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. Tese mitigating actions (i.e, actions that are taken to offset the consequences of the inoperable CRE boundary) shoul be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within FERMI - UNIT 2 B 3.7.3-5 Revision 12

analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion lime is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREF subsystem or the CREcentre1-ree boundary cannot be restored to OPERABLE status within the assec-i-a-tedrequired Completion Time, the unit must be placed in a MODE that minimizes accident risk.

To achieve this status, the unit must be placedin 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 in 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 reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1, D.2.1 and D.2.2 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

FERMI - UNIT 2 B 3.7.3-5 Revision 12

CREF System B 3.7.3 BASES ACTIONS (continued)

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if the inoperable CREF subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREF subsystem may be placed in the recirculation mode.

This action ensures that this remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE-ent-e1 Deem. This places the unit in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

A Note is applied to Required Action D.2.2. This Note allows these Required Actions to not be required when the system charcoal filter train filter media cannot provide the required efficiency or is being replaced. Dose calculations have shown that the CREF system is not needed during the activities that would otherwise be suspended by these Required Actions.

E.1 If both CREF subsystems or a non-redundant component or portion of the CREF System are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable CREcentroe-reem boundary (i.e., Condition B), the CREF System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be enteredimmediately.

FERMI - UNIT 2 B 3.7.3-6 Revision 29

CREF System B 3.7.3 BASES ACTIONS (continued)

F.1 and F.2 The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, with two CREF subsystems or a non-redundant component or portion of the CREF System inoperable, or with one or more CREF subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CREeent re em. This places the unit in a condition that minimizes the accident risk.

If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

A Note is applied to Required Action F.2. This Note allows these Required Actions to not be required when the system charcoal filter train filter media cannot provide the required efficiency or is being replaced. Dose calculations have shown that the CREF system is not needed during the activities that would otherwise be suspended by these Required Actions.

FERMI - UNIT 2 B 3.7.3-6a Revision 29

CREF System B 3.7.3 BASES SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts from the control room on demand and continues to operate.

Standby systems should be checked periodically to ensure that they start and function properly. As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system. Heater operation dries out any moisture that has accumulated in the charcoal as a result of humidity in the ambient air. One subsystem must be operated for 10 continuous hours with the heater energized and operating normally (i.e., cycling between operating and standby to maintain an elevated filter inlet air temperature). The other subsystem need only be operated for 15 minutes to demonstrate the function of the system.

Furthermore, the 31 day Frequency is based on the known reliability of the equipment and the two subsystem redundancy available. The STAGGERED TEST BASIS requires the 10-hour testing of the redundant portions of the subsystem be alternated each 31 day test, such that each redundant portion is operated for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each 62-day test cycle.

SR 3.7.3.2 This SR verifies that the required CREF testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test

-fFrequencies and additional information are discussed in detail in the VFTP.

The Note for this SR provides an allowance to delay entry into the associated Conditions and Required Actions for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in MODES 1, 2, and 3. This allowance prevents intentional entry into LCO 3.0.3 that would otherwise be caused by tests required by the VFTP. The tests that may be required while operating in MODE 1, 2, or 3 are: 1) the periodic charcoal sample; and 2) tests and samples required after exposing the filtration system to ventilation from painting, fire, or chemical release. Other VFTP required surveillances can be scheduled when the plant is not operating in MODE 1, 2, or 3.

FERMI - UNIT 2 B 3.7.3-7 Revision 0

CREF System B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.3.3 This SR verife ta the silicone sealant applie to REF system duct work; outdcof the CnrlRoom envelo rpe-h-as not degraded. The duct work of concern received a genear coating of seal ant on the duct sem. This i ncludresc a visual inspection fo cracking, db nn, and other abnormal degradation of the applied silicone seal ant. Such degradation could be ,indicati',e of l ack of duct i ntegrty.

Si'nce-a portion of- the duct work inspected is at n egatipe pressure under postulated system operation during accident conditions, the loss of duct integrity could-resulti excessive inleakage of r aactive-air during anaccient Only duct wr~k for which nl eaagee does not receifl filtr-ation is of concern. Other duct -work fr ih inl eakage -receives full filtration isnot of conersic the-infiltrating air is no differnt from the air already in th dc. in adtothese ducts didno recive thert general silicone sealant appication that isof nconcen although, there may besealant applied in certain speific instances-to-these-ports-of thesstem. Degprdation of thsl c selant does not necessarily iniaethat the CREF system is inoperable. Howeve r, the condi tionn musit be promptly investigated and resovlved. Th 2month Frqunc ibased on experience that shows the-condi tio of the sil ione does not change appreciably over this time period.

This SR erifies that on an actual or simulated initiation signal, each CREF subsystem starts, isolation valves close within 5 seconds, and operates. The LOGIC SYSTEM FUNCTIONAL TEST inSR 3.3.7.1.6 overlaps this SR to provide complete testing of the safety function. The-18-month-Frequency is specified inReference '1.The frequency of 18 months isbased on industry operating experience and is consistent with the typical refueling cycle.

SR 3.7.3.54 This SR verifies the inttegrity of the contrlro enclosure and the-assumed inleakage--rate~s of potentially cotmiae air. The-control room positive pressure, with respeto potentially contaminated adjacent areas, is periodicall tested toverify prope function rof the CREF System. During the emergency mode of operatonthe CREF System is designed to slightly epreer ssuiz the-control room 0 0.125iinche~s water gauge positive pressure wi th respect to-the atmosphere FERMI - UNIT 2 B 3.7.3-8 Revision 0

This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 7) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 8). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 9). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

FERMI - UNIT 2 B 3.7.3-8 Revision 0

CREF System B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (Cntinued) outsidfe o f the control roonm to prnevent unfitredinekac The CRESSystem is de-signed to maintain thi postiv presue i-th a-makeup flow-trate of 1800-cfmn to the control room in the recircul atin mode. The Frequencyo 18 months on a STAGERE TEST BASIS is consistent wvfith}

_industry practiGe-and other fi-ltration systems S°s.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 9.

3. UFSAR, Chapter 15.

4. Regul atory Guide 1.52 Re'isien 2, Mar 78.UFSAR, Section 6.4.2.3.1

5. UFSAR Section 6.4

6. UFSAR Section 9.4

7. Regulatory Guide 1.196

8. NEI 99-03, "Control Room Habitability Assessment," June 2001

9. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."

(ADAMS Accession No. ML040300694)

10. Letter from William T. O'Conner, Jr. to Document Control Desk (USNRC) dated December 8, 2003, NRC 0090, "Detroit Edison's 180-Day Response to Generic Letter 2003-01, Control Room Habitability" (ADAMS Accession No. ML033510077)

FERMI - UNIT 2 B 3.7.3-9 Revision 29