Text

License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, Using the Consolidated Line Item Improvement Proces
	ML16207A433
Person / Time
Site:	Fermi
Issue date:	07/25/2016
From:	Polson K; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC-16-0036
	Download: ML16207A433 (57)
	v • d • e

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, M1 48166 Tel: 734,586.4849 Fax: 734.586.4172 Email: polsonk@dteenergy.com DTE Energy-July 25, 2016 10 CFR 50.90 NRC-16-0036 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) TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," Revision 3, dated October 21, 2015 (ML15294A555)

3) Federal Register, Volume 81, Page 17208, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," dated March 28, 2016

4) NRC Letter to DTE Electric Company, "Fermi 2 - Alternative Request PVRR-001 Concerning the Third 10-Year Inservice Testing Program,"

dated July 16, 2014 (ML14176A929)

Subject:

License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS Inservice Testing Program Removal

& Clarify SR Usage Rule Application to Section 5.5 Testing,"

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 to address Regulatory Issue Summary 2012-10, "NRC Staff Position on Applying Surveillance Requirement 3.0.2 and 3.0.3 to Administrative Controls Program Tests," by revising the TS to eliminate the Section 5.5, "Inservice Testing and Inspection Program." A new defined term, "INSERVICE TESTING PROGRAM," is added to the TS Definitions section. This request is consistent with TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify [Surveillance Requirement] SR Usage Rule Application to Section 5.5 Testing" (Reference 2). A Federal Register notice of the availability of TSTF-545

USNRC NRC-16-0036 Page 2 was published on March 28, 2016 (Reference 3). The proposed amendment would also modify Section 5.5, "Radioactive Effluent Controls Program," to clarify that Surveillance Requirements 3.0.2 and 3.0.3 are applicable to that program. This change, which has been previously reviewed and approved by the NRC as part of TSTF-258-A, Revision 4, is being made at this time for consistency with the BWR/4 Standard Technical Specifications (STS) in NUREG-1433 and to prevent unintended consequences from the adoption of TSTF-545.

Note that TSTF-545 includes an optional attachment to adopt American Society of Mechanical Engineers (ASME) Code Case OMN-20, "Inservice Test Frequency." The optional attachment is not included in this proposed amendment since DTE has already received NRC approval of relief request PVRR-001 to adopt OMN-20 (Reference 4). provides a description and assessment of the proposed change. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. Enclosure 4 is provided for information only.

DTE requests approval of the proposed License Amendment by July 31, 2017, with the amendment being implemented within 120 days.

No new commitments are being made in this submittal.

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

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager, Licensing at (734) 586-5076.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 25, 2016 Keith J. Polson Site Vice President Nuclear Generation

USNRC NRC-16-0036 Page 3

Enclosures:

1.

Evaluation of the Proposed License Amendment

2.

Marked-up Pages of Existing Fermi 2 TS

3.

Clean Pages of Fermi 2 TS with Changes Incorporated

4.

Marked-up Pages of Existing 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 Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

to NRC-16-0036 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, Using the Consolidated Line Item Improvement Process Evaluation of the Proposed License Amendment to NRC-16-0036 Page 1 Evaluation of the Proposed License Amendment

1. DESCRIPTION The proposed change eliminates the Technical Specifications (TS), Section 5.5, Inservice Testing Program, to remove requirements duplicated in American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code),

Case OMN-20, Inservice Test Frequency. A new defined term, INSERVICE TESTING PROGRAM, is added to TS Section 1.1, Definitions. The proposed change to the TS is consistent with TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing.

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation DTE Electric Company (DTE) has reviewed the model safety evaluation dated December 11, 2015 (NRC ADAMS Accession No. ML15314A305). This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-545. DTE concluded that the justifications presented in TSTF-545, and the model 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.

Fermi 2 was issued a construction permit in September 1972 and the provisions of 10 CFR 50.55a(f)(2) are applicable.

2.2 Optional Changes and Variations DTE is proposing the following variation from the TS changes described in the TSTF-545 or the applicable parts of the NRC staffs model safety evaluation dated December 11, 2015. This variation does not affect the applicability of TSTF-545 or the NRC staffs model safety evaluation to the proposed license amendment.

DTE proposes to revise Specification 5.5.4, Radioactive Effluent Controls Program, to add a statement that the provisions of Surveillance Requirement (SR) 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency. In the Fermi 2 TS, Specification 5.5.4 does not currently include an explicit reference to SR 3.0.2 and SR 3.0.3.

TSTF-545 includes changes to the TS Bases for SR 3.0 to explicitly clarify that SR 3.0.2 and SR 3.0.3 apply in Chapter 5 only when invoked by a Chapter 5 Specification. Therefore, it is necessary to explicitly add the reference to SR 3.0.2 and SR 3.0.3 in Specification 5.5.4 in order to prevent unintended consequences due to the other changes being made to adopt TSTF-545.

The change to Specification 5.5.4 proposed by DTE is identical to the change included in TSTF-258-A, Revision 4 (ML040620102). TSTF-258-A, Revision 4, which was previously reviewed and approved by the NRC on June 29, 1999, states that The provision of SR 3.0.2 are to NRC-16-0036 Page 2 applied to the Radioactive Effluent Controls Program surveillance frequencies and further states that this change has no effect on the outcome of the calculations. In addition, the change to Specification 5.5.4 was previously adopted into the BWR/4 Standard Technical Specifications (STS) in NUREG-1433. Many of the TS changes associated with TSTF-258-A that were incorporated into the STS in NUREG-1433 were previously adopted by DTE as part of the conversion to Improved Standard Technical Specifications (DTE letter NRC-98-0043 dated April 3, 1998); however, the change to Specification 5.5.4 was not. This proposed variation, while not explicitly discussed in TSTF-545, has been previously reviewed and approved by the NRC as part of TSTF-258-A, Revision 4, is already included in NUREG-1433, is required to be consistent with the intent of TSTF-545, and has no impact on the NRC staffs model safety evaluation.

In addition to the proposed variation discussed above, the following administrative differences from TSTF-545 are noted. These administrative differences do not affect the applicability of TSTF-545 or the NRC staffs model safety evaluation to the proposed license amendment.

Table 1 on the following page provides a detailed comparison between the changes to the NUREG-1433 and the Fermi 2 TS.

TSTF-545 deletes Specification 5.5.7, Inservice Testing Program, and renumbers all subsequent Specifications in Section 5.5. DTE proposes to delete the Specification and replace it with Not Used such that no renumbering is required. The specific differences between the Fermi 2 TS and TSTF-545 due to not renumbering are indicated by Footnote 1 in Table 1. This will prevent a large administrative impact requiring the potential renumbering of the existing TS, revision of the associated surveillance procedures, and the revision of other plant operating procedures that refer to these TS.

This proposal is consistent with TSTF-545 Section 2.2.1 which states that, It is anticipated that plant-specific requests to adopt this Traveler will mark the Section 5.5 program deleted and will not renumber the subsequent programs.

The Fermi 2 TS utilize different numbering than the NUREG-1433 TS on which TSTF-545 was based. The specific differences between the Fermi 2 TS numbering and the TSTF-545 numbering are indicated by Footnote 2 in Table 1. These differences are administrative and do not affect the applicability of TSTF-545 to the Fermi 2 TS.

The Fermi 2 TS contain some SRs that refer to the Inservice Testing Program whereas the corresponding SRs in the NUREG-1433 TS on which TSTF-545 were based do not refer to the Inservice Testing Program. These specific Fermi 2 SRs are indicated by Footnote 3 in Table 1. For each Fermi 2 SR that refers to the Inservice Testing Program, DTE is proposing to capitalize the text INSERVICE TESTING PROGRAM. This proposal is consistent with TSTF-545 Section 2.2.1 which states that The phrase Inservice Testing Program may appear in difference locations in plant-specific TS.

Revising this phrase to be capitalized wherever it may appear is within the scope of this proposed change.

to NRC-16-0036 Page 3 Table 1 - Comparison between NUREG-1433 and Fermi 2 Technical Specifications TSTF-545 Markup of NUREG-1433 TS Fermi 2 Equivalent TS Markup Title Change Fermi 2 Title Fermi 2 Change 1.1, Definitions Added definition 1.1, Definitions Same as TSTF-545 3.0, Limiting Condition for Operation (LCO)

Applicability Renumbered a TS in LCO 3.0.6 3.0, Limiting Condition for Operation (LCO)

Applicability None(1) 3.1.7, Standby Liquid Control (SLC)

System Revised SR 3.1.7.7 3.1.7, Standby Liquid Control (SLC)

System Same as TSTF-545 3.4.3, Safety/Relief Valves (S/RVs)

Revised SR 3.4.3.1 3.4.3, Safety Relief Valves (SRVs)

Same as TSTF-545 3.4.5, RCS Pressure Isolation Valve (PIV)

Leakage Revised SR 3.4.5.1 3.4.5, RCS Pressure Isolation Valve (PIV)

Leakage Same as TSTF-545 3.5.1, ECCS -

Operating Revised SR 3.5.1.7 3.5.1, ECCS -

Operating Revised SRs 3.5.1.8(2) and 3.5.1.9(3) 3.5.2, ECCS -

Shutdown Revised SR 3.5.2.5 3.5.2, ECCS -

Shutdown Revised SR 3.5.2.6(2) 3.6.1.3, Primary Containment Isolation Valves (PCIVs)

Revised SRs 3.6.1.3.6 and 3.6.1.3.8 3.6.1.3, Primary Containment Isolation Valves (PCIVs)

Revised SRs 3.6.1.3.5(2),

3.6.1.3.7(2), and 3.6.1.3.11(3) 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling Revised SR 3.6.2.3.2 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling Same as TSTF-545 3.6.2.4, Residual Heat Removal (RHR) Suppression Pool Spray Revised SR 3.6.2.4.2 3.6.2.4, Residual Heat Removal (RHR) Suppression Pool Spray Same as TSTF-545 3.6.4.2, Secondary Containment Isolation Valves (SCIVs)

Revised SR 3.6.4.2.2 3.6.4.2, Secondary Containment Isolation Valves (SCIVs)

Same as TSTF-545 5.5, Programs and Manuals None 5.5, Programs and Manuals Revised Section 5.5.4(4) to NRC-16-0036 Page 4 Table 1 - Comparison between NUREG-1433 and Fermi 2 Technical Specifications TSTF-545 Markup of NUREG-1433 TS Fermi 2 Equivalent TS Markup Title Change Fermi 2 Title Fermi 2 Change 5.5, Programs and Manuals Deleted Section 5.5.7 and renumbered Specifications 5.5.8 through 5.5.17 5.5, Programs and Manuals Deleted Section 5.5.6(2) without renumbering(1)

Footnotes:

(1)

The TSTF-545 changes include deletion of Specification 5.5.7 and renumbering of subsequent Specifications 5.5.8 through 5.5.17. This results in changes to other Specifications that reference these numbers. DTE will delete the Specification without renumbering subsequent Specifications such that no changes associated with renumbering are required.

(2)

The corresponding Fermi 2 Specification number and/or SR number are different from those specified in the BWR/4 STS NUREG-1433 that is marked-up in TSTF-545 for the same or equivalent specification.

(3)

The Fermi 2 Specifications contain some SRs that refer to the Inservice Testing Program where NUREG-1433 does not. These SRs are revised to capitalize INSERVICE TESTING PROGRAM in a manner consistent with TSTF-545.

(4)

BWR/4 STS NUREG-1433 Section 5.5.4 contains a statement that SR 3.0.2 and SR 3.0.3 are applicable, consistent with TSTF-258-A, Revision 4. Fermi 2 had not previously adopted this specific change, but are adopting the change now to meet the intent of TSTF-545.

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration DTE requests adoption of the TS changes described in TSTF-545, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Fermi 2 TS.

The proposed change revises the TS Chapter 5, Administrative Controls, Section 5.5, Programs and Manuals, to delete the Inservice Testing (IST) Program specification.

Requirements in the IST Program are removed, as they are duplicative of requirements in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code, as clarified by Code Case OMN-20, Inservice Test Frequency. Other requirements in Section 5.5 are eliminated because the Nuclear Regulatory Commission (NRC) has determined their appearance in the TS is contrary to regulations. A new defined term, Inservice Testing Program, is added, which references the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.55a(f). DTE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

to NRC-16-0036 Page 5

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises TS Chapter 5, Administrative Controls, Section 5.5, Programs and Manuals, by eliminating the Inservice Testing Program specification.

Most requirements in the Inservice Testing Program are removed, as they are duplicative of requirements in the ASME OM Code, as clarified by Code Case OMN-20, Inservice Test Frequency. The remaining requirements in the Section 5.5 IST Program are eliminated because the NRC has determined their inclusion in the TS is contrary to regulations. A new defined term, Inservice Testing Program, is added to the TS, which references the requirements of 10 CFR 50.55a(f).

Performance of inservice testing is not an initiator to any accident previously evaluated. As a result, the probability of occurrence of an accident is not significantly affected by the proposed change. Inservice test frequencies under Code Case OMN-20 are equivalent to the current testing period allowed by the TS with the exception that testing frequencies greater than 2 years may be extended by up to 6 months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to mitigate any accident previously evaluated as the components are required to be operable during the testing period extension. Performance of inservice tests utilizing the allowances in OMN-20 will not significantly affect the reliability of the tested components.

As a result, the availability of the affected components, as well as their ability to mitigate the consequences of accidents previously evaluated, is not affected.

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

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

Response: No.

The proposed change does not alter the design or configuration of the plant. The proposed change does not involve a physical alteration of the plant; no new or different kind of equipment will be installed. The proposed change does not alter the types of inservice testing performed. In most cases, the frequency of inservice testing is unchanged. However, the frequency of testing would not result in a new or different kind of accident from any previously evaluated since the testing methods are not altered.

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

to NRC-16-0036 Page 6

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

Response: No.

The proposed change eliminates some requirements from the TS in lieu of requirements in the ASME Code, as modified by use of Code Case OMN-20. Compliance with the ASME Code is required by 10 CFR 50.55a. The proposed change also allows inservice tests with frequencies greater than 2 years to be extended by 6 months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to respond to an accident as the components are required to be operable during the testing period extension. The proposed change will eliminate the existing TS SR 3.0.3 allowance to defer performance of missed inservice tests up to the duration of the specified testing frequency, and instead will require an assessment of the missed test on equipment operability. This assessment will consider the effect on a margin of safety (equipment operability). Should the component be inoperable, the TS provide actions to ensure that the margin of safety is protected. The proposed change also eliminates a statement that nothing in the ASME Code should be construed to supersede the requirements of any TS. The NRC has determined that statement to be incorrect. However, elimination of the statement will have no effect on plant operation or safety.

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

Based on the above, DTE concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4. ENVIRONMENTAL EVALUATION 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 20, or 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.

to NRC-16-0036 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, Using the Consolidated Line Item Improvement Process Marked-up Pages of Existing Fermi 2 TS

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, I-132. 1-133. 1-134.

and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844.

AEC. 1962. "Calculation of Distance Factors for Power and Test Reactor Sites."

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e.. the valves travel to their required positions, pump discharge pressures reach their required values. etc.).

Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential.

overlapping, or total steps so that the entire response time is measured.

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions.

Times shall include diesel' generator starting and sequence loading delays. where applicable. The response time may be measured by means of any series of sequential.

overlapping. or total steps so that the entire response time is measured.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

(continued)

FERMI - UNIT 2 1.1-3 Amendment No.-134-

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each SLC subsystem manual valve in In accordance the flow path that is not locked, sealed, with the or otherwise secured in position is in the Surveillance correct position, or can be aligned to the Frequency correct position.

Control Program SR 3.1.7.7 Verify each pump develops a flow rate In accordance 41.2 gpm at a discharge pressure with the

> 1215 psig.

inservGe Tetggram INSERVICE TESTING PROGRAM SR 3.1.7.8 Verify flow through one SLC subsystem from In accordance pump into reactor pressure vessel.

with the Surveillance Frequency Control Program SR 3.1.7.9 Verify all piping between storage tank and In accordance explosive valve is unblocked.

with the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored > 48*F SR 3.1.7.10 Verify sodium pentaborate enrichment is Prior to z 65 atom percent B-10.

addition to SLC tank FERMI - UNIT 2 3.1-22 Amendment No. -34, -2M-

SRVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift setpoints In accordance of the required SRVs are as follows:

with the Inservie Number of Setpoint Testing-Pregram SRVs (psig)

INSERVICE 5

1145 +/- 34.35 TESTING 5

1155 i 34.65 PROGRAM Following testing, lift settings shall be within i 1%.

SR 3.4.3.2 Verify each required SRV is capable of In accordance being opened.

with the Surveillance Frequency Control Program FERMI - UNIT 2 3.4-8 Amendment No. 134 19. -201-

RCS PIV Leakage 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and 8.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND 8.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1

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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV.

In accordance at an RCS pressure t 1035 and s 1055 psig:

with the 6nervc-e

a. For PIVs other than LPCI loop A and B Test-ng-P-r-ogram injection isolation valves is s 0.5 gpm per nominal inch of valve INSERVICE size up to a maximum of 5 gpm:

TESTING

b.

For LPCI loop A and B outboard PROGRAM injection isolation valves is s 0.4 gpm. through-seat, and s 5 ml/min external leakage: and

c. For LPCI loop A and B inboard injection isolation testable check valves is s 10 gpm.

FERMI UNIT 2 3.4-12 Amendment No.

ECCS -Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.8 Verify the following ECCS pumps develop the In accordance specified flow rate against a system head with the corresponding to the specified reactor TIsev4ee pressure.

Test4ing SYSTEM HEAD Pregram NO.

CORRESPONDING INSERVICE OF TO A REACTOR TESTING SYSTEM FLOW RATE PUMPS PRESSURE OF PROGRAM Core Spray 5725 gpm 2

100 psig LPCI z 10,000 gpm 1

> 20 psig SR 3.5.1.9

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

IN S ERV IC E

Verify, with reactor pressure s 1045 and In accordance TESTING z 945 psig, the HPCI pump can develop a with the PROGRAM flow rate z 5000 gpm against a system head Inserv4e corresponding to reactor pressure.

Test4ng-P-regram SR 3.5.1.10

NOTE----

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure < 215 psig, In accordance the HPCI pump can develop a flow rate with the 2 5000 gpm against a system head Surveillance corresponding to reactor pressure.

Frequency Control Program (continued)

FERMI - UNIT 2 3.5-6 Amendment No. 134 84, 20-1

ECCS-Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5 -----------------NOTE--------------------

LPCI subsystem(s) may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS injection/spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path, that is Surveillance not locked, sealed, or otherwise secured in Frequency position, is in the correct position.

Control Program SR 3.5.2.6 Verify each required ECCS pump develops the In accordance specified flow rate against a system head with the corresponding to the specified reactor ve pressure.

TT c

g SYSTEM HEAD PrgramINSERVICE NO.

CORRESPONDING OF TO A REACTOR TESTING SYSTEM FLOW RATE PUMPS PRESSURE OF PROGRAM CS

> 5725 gpm 2

100 psig LPCI z 10,000 gpm 1

> 20 psig SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray In accordance subsystem actuates on an actual or with the simulated automatic initiation signal.

Surveillance Frequency Control Program FERMI - UNIT 2 3.5-11 Amendment No. 44 184, -2e1-

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.3

NOTES--------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment Prior to isolation manual valve and blind flange entering MODE 2 that is located inside primary or 3 from containment and is not locked, sealed, MODE 4 if or otherwise secured and is required to primary be closed during accident conditions is containment was closed.

de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing In accordance incore probe (TIP) shear isolation valve with the explosive charge.

Surveillance Frequency Control Program SR 3.6.1.3.5 Verify the isolation time of each power In accordance INSERVICE operated automatic PCIV, except for with the TESTING MSIVs, is within limits.

Mservi-ce PROGRAM Testing Preogram (continued)

FERMI - UNIT 2 3.6-15 Amendment No. 134,-201-

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Perform leakage rate testing for each In accordance primary containment purge valve with with the resilient seals.

Surveillance Frequency Control Program AND Once within 92 days after opening the valve INS ERVICE SR 3.6.1.3.7 Verify the isolation time of each MSIV In accordance TESTING is 3 seconds and s 5 seconds.

with the.-

cPROGRAM SR 3.6.1.3.8 Verify each automatic PCIV actuates to In accordance the isolation position on an actual or with the simulated isolation signal.

Surveillance Frequency Control Program SR 3.6.1.3.9 Verify a representative sample of In accordance reactor instrumentation line EFCVs with the actuates on a simulated instrument line Surveillance break to restrict flow.

Frequency Control Program SR 3.6.1.3.10 Remove and test the explosive squib from In accordance each shear isolation valve of the TIP with the System.

Surveillance Frequency Control Program (continued)

FERMI UNIT 2 3.6-16 Amendment No. 1 P,13.21-

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.11 Verify the combined leakage rate for all In accordance secondary containment bypass leakage with the paths that are not provided with a seal Primary system is S 0.10 L. when pressurized to Containment k 56.5 psig.

Leakage Rate Testing Program and inse-4ce Testing-Program INSERVICE TESTING SR 3.6.1.3.12 Verify combined MSIV leakage rate for In accordance PROGRAM all four main steam lines is 5 250 scfh with the and S 100 scfh for any one steam line Primary when tested at k 25 psig.

Containment Leakage Rate Testing Program SR 3.6.1.3.13

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

Only required to be met in MODES 1, 2.

and 3.

Verify combined leakage rate through In accordance hydrostatically tested lines that with the penetrate the primary containment is Primary within limits.

Containment Leakage Rate Testing Program FERNMI - UNIT 2 3.6-17 Amendment No.

,-+69-

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate > 9,250 gpm through the with the associated heat exchanger while operating T-see-iee in the suppression pool cooling mode.

TestingR-Pegam INSERVICE TESTING PROGRAM FERMI - UNIT 2 3.6-34 Amendment No. 134 191,-261-

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.4.2 Verify each RHR pump develops a flow rate In accordance

> 500 gpm through the heat exchanger and with the suppression pool spray sparger while nerw-e operating in the suppression pool spray Testing Program mode.

INSERVICE TESTING PROGRAM FERMI - UNIT 2 3.6-36 Amendment No. 434,-2O1-

SCIVs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1

NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment In accordance isolation manual valve and blind flange with the not locked, sealed, or otherwise secured Surveillance that is required to be closed during Frequency accident conditions is closed.

Control Program INSERVICE SR 3.6.4.2.2 Verify the isolation time of each power In accordance TESTING operated automatic SCIV is within limits.

with the PROGRAM Testing-Program SR 3.6.4.2.3 Verify each automatic SCIV actuates to In accordance the isolation position on an actual or with the simulated actuation signal.

Surveillance Frequency Control Program FERMI - UNIT 2 3.6-46 Amendment No. 134, Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program (continued)

f. Limitations on the functional capability and use of the.

liquid and gaseous effluent treatment systems to ensure that appropriate portions of.these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2X of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50.

Appendix I:

g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the site boundary conforming to the following:

1. For noble gases: s 500 mrem/yr to the total body and s 3000 mrem/yr to the skin; and

2. For Iodine-131. for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives

> 8 days: s 1500 mrem/yr to any organ;

h. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, conforming to 10 CFR 50.

Appendix I:

i.

Limitations on the.annual and quarterly doses to a member of the public from iodine-131. iodine-133, tritium. and all radionuclides in particulate form with half lives > 8 days in gaseous effluents released to areas beyond the site boundary, conforming to 10 CFR 50. Appendix I:

j.

Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190; and

k. Limitations on venting and purging of the Mark I containment through the Standby Gas Treatment System or the Reactor Building Ventilation System to maintain releases as low as reasonably achievable.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

K>

(continued)

FERMI - UNIT 2 5.0-10 Amendment No.-134-

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.5 Component Cyclic or Transient Limit This program provides controls to track the UFSAR Section 5.2.1.2 cyclic and transient occurrences to ensure that components are maintained within the design limits.

5.5.6 ot Used shalln i n c l u d t h e

f o l l i n g ACME Boiler and Preszurc Vessel Cde and ineric ctigand tcsting and inspection Weekly At least once per 7 days Monthly At

-cs ncper 31 days Quartcrel y or ever (continued FEttleast.oncenen 92 M 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are applicable t h bv testing and inspectonatiite; n (continued)

FERMI

.UNIT 2

5.0-11 Amendment No. -134-

to NRC-16-0036 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, Using the Consolidated Line Item Improvement Process Clean Pages of Fermi 2 TS with Changes Incorporated

Definitions 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

(continued)

FERMI - UNIT 2 1.1-3 Amendment No. 134

SLC System 3.1.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.7.6 Verify each SLC subsystem manual valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position, or can be aligned to the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.1.7.7 Verify each pump develops a flow rate 41.2 gpm at a discharge pressure 1215 psig.

In accordance with the INSERVICE TESTING PROGRAM SR 3.1.7.8 Verify flow through one SLC subsystem from pump into reactor pressure vessel.

In accordance with the Surveillance Frequency Control Program SR 3.1.7.9 Verify all piping between storage tank and explosive valve is unblocked.

In accordance with the Surveillance Frequency Control Program AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after solution temperature is restored 48°F SR 3.1.7.10 Verify sodium pentaborate enrichment is 65 atom percent B-10.

Prior to addition to SLC tank FERMI - UNIT 2 3.1-22 Amendment No. 134, 201

SRVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety function lift setpoints of the required SRVs are as follows:

Number of Setpoint SRVs (psig) 5 1135 +/- 34.05 5

1145 +/- 34.35 5

1155 +/- 34.65 Following testing, lift settings shall be within +/- 1%.

In accordance with the INSERVICE TESTING PROGRAM SR 3.4.3.2 Verify each required SRV is capable of being opened.

In accordance with the Surveillance Frequency Control Program FERMI - UNIT 2 3.4-8 Amendment No. 134 190, 201

RCS PIV Leakage 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1

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

Not required to be performed in MODE 3.

Verify equivalent leakage of each RCS PIV, at an RCS pressure 1035 and 1055 psig:

a.

For PIVs other than LPCI loop A and B injection isolation valves is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm;

b.

For LPCI loop A and B outboard injection isolation valves is 0.4 gpm through-seat, and 5 ml/min external leakage; and

c.

For LPCI loop A and B inboard injection isolation testable check valves is 10 gpm.

In accordance with the INSERVICE TESTING PROGRAM FERMI - UNIT 2 3.4-12 Amendment No. 134

ECCS Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.1.8 Verify the following ECCS pumps develop the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO.

CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 5725 gpm 2

100 psig LPCI 10,000 gpm 1

20 psig In accordance with the INSERVICE TESTING PROGRAM SR 3.5.1.9

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1045 and 945 psig, the HPCI pump can develop a flow rate 5000 gpm against a system head corresponding to reactor pressure.

In accordance with the INSERVICE TESTING PROGRAM SR 3.5.1.10

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 215 psig, the HPCI pump can develop a flow rate 5000 gpm against a system head corresponding to reactor pressure.

In accordance with the Surveillance Frequency Control Program (continued)

FERMI - UNIT 2 3.5-6 Amendment No. 134 184, 201

ECCS Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

LPCI subsystem(s) may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each required ECCS pump develops the specified flow rate against a system head corresponding to the specified reactor pressure.

SYSTEM HEAD NO.

CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF CS 5725 gpm 2

100 psig LPCI 10,000 gpm 1

20 psig In accordance with the INSERVICE TESTING PROGRAM SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify each required ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.

In accordance with the Surveillance Frequency Control Program FERMI - UNIT 2 3.5-11 Amendment No. 134 184, 201

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.3

NOTES----------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation manual valve and blind flange that is located inside primary containment and is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed.

Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing incore probe (TIP) shear isolation valve explosive charge.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.5 Verify the isolation time of each power operated automatic PCIV, except for MSIVs, is within limits.

In accordance with the INSERVICE TESTING PROGRAM (continued)

FERMI - UNIT 2 3.6-15 Amendment No. 134, 201

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.6 Perform leakage rate testing for each primary containment purge valve with resilient seals.

In accordance with the Surveillance Frequency Control Program AND Once within 92 days after opening the valve SR 3.6.1.3.7 Verify the isolation time of each MSIV is 3 seconds and 5 seconds.

In accordance with the INSERVICE TESTING PROGRAM SR 3.6.1.3.8 Verify each automatic PCIV actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.9 Verify a representative sample of reactor instrumentation line EFCVs actuates on a simulated instrument line break to restrict flow.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.10 Remove and test the explosive squib from each shear isolation valve of the TIP System.

In accordance with the Surveillance Frequency Control Program (continued)

FERMI - UNIT 2 3.6-16 Amendment No. 134 137, 201

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.11 Verify the combined leakage rate for all secondary containment bypass leakage paths that are not provided with a seal system is 0.10 La when pressurized to 56.5 psig.

In accordance with the Primary Containment Leakage Rate Testing Program and INSERVICE TESTING PROGRAM SR 3.6.1.3.12 Verify combined MSIV leakage rate for all four main steam lines is 250 scfh and 100 scfh for any one steam line when tested at 25 psig.

In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.3.13

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

Only required to be met in MODES 1, 2, and 3.

Verify combined leakage rate through hydrostatically tested lines that penetrate the primary containment is within limits.

In accordance with the Primary Containment Leakage Rate Testing Program FERMI - UNIT 2 3.6-17 Amendment No. 134, 160, 169

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.2.3.2 Verify each required RHR pump develops a flow rate 9,250 gpm through the associated heat exchanger while operating in the suppression pool cooling mode.

In accordance with the INSERVICE TESTING PROGRAM FERMI - UNIT 2 3.6-34 Amendment No. 134 191, 201

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray subsystem manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position or can be aligned to the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.6.2.4.2 Verify each RHR pump develops a flow rate 500 gpm through the heat exchanger and suppression pool spray sparger while operating in the suppression pool spray mode.

In accordance with the INSERVICE TESTING PROGRAM FERMI - UNIT 2 3.6-36 Amendment No. 134, 201

SCIVs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1

NOTES------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for SCIVs that are open under administrative controls.

Verify each secondary containment isolation manual valve and blind flange not locked, sealed, or otherwise secured that is required to be closed during accident conditions is closed.

In accordance with the Surveillance Frequency Control Program SR 3.6.4.2.2 Verify the isolation time of each power operated automatic SCIV is within limits.

In accordance with the INSERVICE TESTING PROGRAM SR 3.6.4.2.3 Verify each automatic SCIV actuates to the isolation position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program FERMI - UNIT 2 3.6-46 Amendment No. 134, 201

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.4 Radioactive Effluent Controls Program (continued)

f.

Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50, Appendix I;

g.

Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the site boundary conforming to the following:

1.

For noble gases: 500 mrem/yr to the total body and 3000 mrem/yr to the skin; and

2.

For Iodine-131, for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives

> 8 days: 1500 mrem/yr to any organ;

h.

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I;

i.

Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives > 8 days in gaseous effluents released to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I;

j.

Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190; and

k.

Limitations on venting and purging of the Mark I containment through the Standby Gas Treatment System or the Reactor Building Ventilation System to maintain releases as low as reasonably achievable.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Radioactive Effluent Controls Program surveillance frequency.

(continued)

FERMI - UNIT 2 5.0-10 Amendment No. 134

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.5 Component Cyclic or Transient Limit This program provides controls to track the UFSAR Section 5.2.1.2 cyclic and transient occurrences to ensure that components are maintained within the design limits.

5.5.6 Not Used (continued)

FERMI - UNIT 2 5.0-11 Amendment No. 134

to NRC-16-0036 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, Using the Consolidated Line Item Improvement Process Marked-up Pages of Existing Fermi 2 TS Bases (For Information Only)

SR Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.2 and 3.0.3 apply in Chapter 5 only when invoked by a Chapter 5 Specification.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a Surveillance within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to be OPERABLE when the associated SRs have been met. Nothing. in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified.

The SRs associated with a Special Operations LCO are only applicable when the Special Operations LCO is used as an allowable exception to the requirements of a Specification.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a given MODE or other specified condition.

FERMI - UNIT 2 B 3.0-19 Revision l

SR Applicability 3.0 BASES SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per..."

interval.

SR 3.0.2 permits a 25% extension of the interval specified When a Section 5.5, in the Frequency.

This extension facilitates Surveillance "Programs and Manuals,"

scheduling and considers plant operating conditions that may specification states that the not be suitable for conducting the Surveillance (e.g.,

provisions of SR 3.0.2 are transient conditions or other ongoing Surveillance or maintenance activities).

applicable, a 25% extension of the testing interval, The 25% extension does not significantly degrade the whether stated in the reliability that results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance by reference, is permitted.

being performed is the verification of conformance with the SRs.

The exceptions to SR 3.0.2 are those Surveillances for Start new paragraph which he 25% extension of the interval specified in the requency does not apply. These exceptions are stated in the individual Specifications.

An -xample of -here SR 3.0.2 Spe cifiatio.5.12.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per..." basis.

The 25%

extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time.

One reason for not allowing the 25%

extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with The requirements of regulations take precedence over the TS. Examples of where SR 3.0.2 does not apply are the Primary Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the inservice testing of pumps and valves in accordance with applicable American Society of Mechanical Engineers Operation and Maintenance Code, as required by 10 CFR 50.55a. These programs establish testing requirements and Frequencies in accordance with the requirements of regulations. The TS cannot, in and of themselves, extend a test interval specified in the regulations directly or by reference.

FERMI - UNIT 2 B 3.0-21 Revision 55 l

SR Applicability 3.0 BASES SR 3.0.3 SR 3.0.3 establishes-the flexibility to defer declaring affected equipment inoperable or an affected variable When a Section 5.5, outside the specified l imits when a Surveillance has not "Programs and Manuals,"

been completed wi.thin the specified Frequency.

A delay specification states that the period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater, applies from the point in provisions of SR 3.0.3 are time that it is discovered that the Surveillance has not applicable, it permits the been performed in accordance with SR 3,0.2, and not at the flexibility to defer declaring time that the specified Frequency was not met.

the testing requirement not This delay period provides adequate time to complete met in accordance with SR Surveillances that have been missed.

This delay period 3.0.3 when the testing has permits the completion of a Surveillance before complying not been completed within with Required Actions or other remedial measures that might the testing interval (including preclude completion of the Surveillance.

the allowance of SR 3.0.2 if The basis for this delay period includes consideration of invoked by the Section 5.5 unit conditions, adequate planning, availability of specification).

personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence.

Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance FERMI - UNIT 2 B 3.0-22 Revision SLC System B 3.1.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.7.5 This Surveillance requires an examination of the sodium pentaborate solution by using chemical analysis to ensure that the proper concentration of boron exists in the storage tank. SR 3.1.7.5 must be performed anytime boron or water is added to the storage tank solution to determine that the boron solution concentration is within the specified limits.

SR 3.1.7.5 must also be performed anytime the temperature is restored to z 48'F to ensure that no significant boron precipitation occurred. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.1.7.7 Demonstrating that each SLC System pump develops a flow rate z 41.2 gpm at a discharge pressure 1215 psig ensures that pump performance has not degraded during the fuel cycle.

This minimum pump flow rate requirement ensures that, when combined with the sodium pentaborate solution concentration requirements, the rate of negative reactivity insertion from the SLC System will adequately compensate for the positive reactivity effects encountered during power reduction, cooldown of the moderator, and xenon decay.

This test confirms one point on the pump design curve and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this Surveillance is in accordance with the Inervice-Testing-Progra.

INSERVICE SR 3.1.7.8 and SR 3.1.7.9 TESTING PROGRAM These Surveillances ensure that there is a functioning flow path from the boron solution storage tank to the RPV, including the firing of an explosive valve.

The replacement charge for the explosive valve shall be from the same manufactured batch as the one fired or from another batch that has been certified by having one of that batch successfully fired.

FERMI - UNIT 2 B 3.1.7-5 Revision 64-

SRVs B 3.4.3 BASES APPLICABILITY (continued)

In MODE 4, decay heat is low enough for the RHR System to provide adequate cooling, and reactor pressure is low enough that the overpressure limit is unlikely to be approached by assumed operational transients or accidents. In MODE 5, the reactor vessel head is unbolted or removed and the reactor is at atmospheric pressure. The SRV function is not needed during these conditions.

ACTIONS A.1 and A.2 With less than the minimum number of required SRVs OPERABLE, a transient may result in the violation of the ASME Code limit on reactor pressure. If the safety function of any required SRVs cannot be maintained, 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 MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.3.1 REQUIREMENTS This Surveillance requires that the required SRVs will open at the pressures assumed in the safety analysis of Reference 1. The demonstration of the SRV safe lift settings must be performed during shutdown, since this is a bench test, to be done in accordance with the Inervi-e Test-ing-Program. The lift setting pressure shall correspond INSERVICE to ambient conditions of the valves at nominal operating TESTING temperatures and pressures. The SRV setpoint is i 3% for PROGRAM OPERABILITY, however, the valves are reset to i 1% during the Surveillance to allow for drift.

The SR gives set pressures for all 15 SRVs installed.

However, since only 11 SRVs are required, the SR is met if '

11 SRVs are set properly.

FERMI - UNIT 2 B 3.4.3-3 Revision-O-

SRVs B 3.4.3 BASES INS ERVIC E SURVEILLANCE REQUIREMENTS (continued)

TETIG TESTING The Frequency is required by the inservice Testing Progrm PROGRAM and is consistent with the fact that Surveillance must be performed during shutdown conditions.

SR 3.4.3.2 Valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME Code requirements, prior to valve installation. Actuation of each required SRV is performed to verify that mechanically the valve is functioning properly. This requires that the pilot stage be tested to show:

That each SRV pilot stage actuates when required and opens the associated main stage when the pneumatic actuator is pressurized; and That each SRV main stage opens and passes steam when the associated pilot stage actuates.

The actuators and main stages are bench tested, together or separately, as part of the certification process.

Maintenance procedures ensure that the SRV actuators and main stages are correctly installed in the plant, and that the SRV and associated piping remain clear of foreign material that might obstruct valve operation or full steam flow. This approach provides adequate assurance that the required SRVs will operate as required, while minimizing the challenges to the SRVs and the likelihood of leakage or spurious operation. Two-stage actuator assemblies are not tested in-situ due to a probability of causing unseating or leakage of the pilot stage which can lead to spurious actuation or failure to reclose.

For the purpose of this test, pilot actuation in the safety mode or relief mode is acceptable to satisfy the test requirements. Testing of the related solenoid valves is not required because they do not affect the safety mode operation of the SRV. However, the solenoid valves are also tested in the IST program to support relief mode operation of the SRVs for other functions.

This SR does not preclude manually opening SRVs; for example, in accordance with the IST Program or as corrective action for an SRV with excessive leakage.

FERMI - UNIT 2 B 3.4.3-4 Revision-&7-

RCS PIV Leakage B 3.4.5 BASES SURVEILLANCE SR 3.4.5.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve. A reduced leakage acceptance criteria and an external leakage acceptance criteria are specified for the LPCI injection isolation valves, E1150F015 A and B, to assure adequate water is maintained inboard of these valves such that the associated primary containment penetration can be classified as a water tested penetration under Appendix J to 10 CFR 50. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

INSERVICE TESTING The Frequency required by the inservice Testing Program is PROGRAM within the ASME Code,Section XI, Frequency requirement and is based on the need to perform this Surveillance during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

This SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3.

Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.

FERMI - UNIT 2 B 3.4.5-5 Revision-O--

ECCS - Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Therefore, SR 3.5.1.9 and SR 3.5.1.10 are modified by Notes that state the Surveillances are not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the reactor steam pressure INSERVICE and flow are adequate to perform the test.

TESTING PROGRAM The Frequency for R 3.5.1.8 and SR 3.5.1.9 is in accordance with the ins@rvi Testing Program requirements.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.1.11 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCI, CS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup and actuation of all automatic valves to their required positions. This SR also ensures that the HPCI System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the CST to the suppression pool.

The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlaps this Surveillance to-provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

FERMI - UNIT 2 B 3.5.1-17 Revision 64-

ECCS-Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

I That each ADS SRV main stage opens and passes steam when TETIN C

the associated pilot stage actuates.

PROGRAM The solenoid valves ar unctionally tested once per cycle as part of the ins*rvice Testing Program. The actuators and main stages are bench tested, together or separately, as part of the certification process. Maintenance procedures ensure that the SRV actuators and main stages are correctly installed in the plant, and that the SRV and associated piping remain clear of foreign material that might obstruct valve operation or full steam flow. This approach provides adequate assurance that the required ADS valves will operate when actuated, while minimizing the challenges to the valves and the likelihood of leakage or spurious operation. Two-stage actuator assemblies are not tested in-situ due to a probability of causing unseating or leakage of the pilot stage which can lead to spurious actuation or failure to reclose. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL Test performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

This SR does not preclude manually opening SRVs; for example, in accordance with the IST Program or as corrective action for an SRV with excessive leakage.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.1.14 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. Response time testing acceptance criteria are included in Reference 16.

This SR is modified by a Note stating that the ECCS instrumentation response times are not required to be measured. The contribution of

'the instrument response times to the overall ECCS response time are assumed based on guidance of Reference 17.

FERMI - UNIT 2 B 3.5.1-19 Revision PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.5 Verifying the isolation time of each power operated automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7.

The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the requirements of the Inseri-se INSERVICE Tes-ing-P-gr-am.

TESTING PROGRAM SR 3.6.1.3.6 For primary containment purge valves with resilient seals (6 inch, 10 inch, 20 inch, and 24 inch), additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B (Ref. 3), is required to ensure OPERABILITY. This will ensure that leakage is < 0.05 La when tested at Pa. Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Additionally, this SR must be performed once within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that which occurs to a valve that has not been opened). Thus, performing this SR within 92 days is a prudent measure after a valve has been opened.

The primary containment purge valves are only required to meet leakage rate testing requirements in MODES 1, 2, and 3.

(i.e., no isolation instrumentation functions of LCO 3.3.6.1 are required to be OPERABLE for purge system isolation outside of MODES 1, 2, and 3).

If a LOCA inside primary containment occurs in these MODES, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

FERMI - UNIT 2 B 3.6.1.3 -14 Revision PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.1.3.7 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. This ensures that the calculated radiological consequences of these events remain within 10 CFR 100 or 10 CFR 50.67 limits. The minimum stroke time ensures that isolation does not result in a pressure spike more rapid than assumed in the transient analyses.

The Frequency of this SR is in accordance with the requirements of the rnser'ice TeStn gram.

INSERVICE SR 3.6.1.3.8 PROGRAM PROGRAM Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.5 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.9 This SR requires a demonstration that a representative sample of reactor instrumentation line excess flow check valves (EFCVs) are OPERABLE by verifying that each tested valve restricts flow on a simulated instrument line break.

The representative sample consists of an approximately equal number of EFCVs (about 15), from different plant locations and operating environments, such that each EFCV is periodically tested. The representative sample testing reflects the operability status of all EFCVs in the plant (Ref. 6).

This SR provides assurance that the instrumentation line EFCVs will perform so that predicted radiological consequences will not be exceeded during the postulated instrument line break event evaluated in Reference 5.

FERMI - UNIT 2 B 3.6.1.3-15 Revision 44-

PCIVs B 3.6.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)

Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. Additionally, some secondary containment bypass paths (refer to UFSAR 6.2.1.2.2.3) use non-PCIVs and therefore are not addressed by the testing Frequency of 10 CFR 50, Appendix J, testing.

To address the testing for these valves, the Frequency also INSERVICE includes a requirement to be in accordance with the TESTING D

Tt nr m PROGRAM Secondary containment bypass leakage is also considered part of La.

SR.3.6.1.3.12 The analyses in References 1 and 4 are based on leakage that is less than the specified leakage rate. Leakage through all four main steam lines must be s 250 scfh, and

< 100 scfh for any one steam line, when tested at z Pt (25 psig). This leakage test is performed in lieu of 10 CFR 50, Appendix J, Type C test requirements, based on an exemption to 10 CFR 50, Appendix J. MSIVs have separate leakage limits, and the dose consequence of this leakage path is evaluated separately and added to those calculated from primary containment La leakage, including secondary containment bypass leakage. As such, this leakage is not combined with the Type B and C leakage rate totals. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 4 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the number of valves per penetration, not to exceed 3 gpm, when tested at 1.1 Pa (z 62.2 psig). Additionally, a combined leakage rate limit of 5 gpm when tested at 1.1 Pa (z 62.2 psig) is applied for all hydrostatically tested PCIVs that penetrate containment. The combined leakage rates must be demonstrated in accordance with the leakage rate test Frequency required by Primary Containment Leakage Rate Testing Program.

This SR has been modified by a Note that states that these valves are only required to meet the combined leakage rate FERMI - UNIT 2 B 3.6.1.3-17 Revision S--

LLS Valves B 3.6.1.6 BASES ACTIONS (continued)

C.1 and C.2 If two or more LLS valves are inoperable, there could be excessive short duration SRV cycling during an overpressure event. The plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable,based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.1.6.1 REQUIREMENTS Valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME Code requirements, prior to valve installation. Actuation of each required LLS valve is performed to verify that mechanically the valve is functioning properly. Tests are required to demonstrate:

That each LLS SRV solenoid valve ports pneumatic pressure to the associated SRV actuator when energized; e

That each LLS SRV pilot stage actuates to open the associated main stage when the pneumatic actuator is pressurized; and That each LLS SRV main stage opens and passes steam when INSERVICE the associated pilot stage actuates.

TESTING PROGRAM The solenoid valve re functionally tested once per cycle as part of the Testing

. The actuators and main stages are bench tested, together or separately, as part of the certification process. Maintenance procedures ensure that the SRV actuators and main stages are correctly installed in the plant, and that the SRV and associated piping remain clear of foreign material that might obstruct valve operation or full steam flow. This approach provides adequate assurance that the required LLS valves will operate when actuated, while minimizing the challenges to the valves and the likelihood of leakage or spurious operation. Two-stage actuator assemblies are not tested in-situ due to a high probability of causing unseating or leakage of the pilot stage which can lead to spurious actuation or failure to reclose.

FERMI UNIT 2 B 3.6.1.6-4 Revision RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE REQUIREMENTS (continued) manually initiated.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate 9,250 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance required by ASME Code,Section XI (Ref. 3). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Iserv.e Testing Program INSERVICE TESTING REFERENCES

1.

UFSAR, Section 6.2.

PROGRAM

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

3.

ASME, Boiler and Pressure Vessel Code,Section XI.

FERMI

- UNIT 2 B 3.6.2.3-5 Revision RHR Suppression Pool Spray B 3,6.2.4 BASES SURVEILLANCE REQUIREMENTS (continued) trend performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this SR is in accordance with the Inserv.e Testing Program INSERVICE TESTING REFERENCES

1.

UFSAR, Section 6.2.

PROGRAM

2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

3. ASME, Boiler and Pressure Vessel Code,Section XI.

FERMI - UNIT 2 B 3.6.2.4-5 Revision SCIVs B 3.6.4.2 BASES SURVEILLANCE REQUIREMENTS (continued)

MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these SCIVs, once they have been verified to be in the proper position, is low.

A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open.

SR 3.6.4.2.2 Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate OPERABILITY.

The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the lnser-e INSERVICE Testhg Pr-g-am.

TESTING PROGRAM SR 3.6.4.2.3 Verifying that each automatic SCIV closes on a secondary containment isolation signal is required to prevent leakage of radioactive material from secondary containment following a DBA or other accidents. This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1. UFSAR, Section 15.6.5.

2.

UFSAR, Section 15.7.4.

3.

Technical Requirements Manual.

FERMI

- UNIT 2 B 3.6.4.2 -7 Revision 64-

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