NRC-18-0019, Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

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Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.
ML18094A165
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/04/2018
From: Polson K
DTE Electric Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-18-0019, TSTF-542
Download: ML18094A165 (24)
v • d • e


Text

Keith J. Polson Senior Vice President and CNO DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.1431 Email: keith.polson@dteenergy.com April 4, 2018 NRC-18-0019 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

References:

1) DTE Electric Letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-17-0067, dated August 31, 2017 (ML17243A422)

In Reference 1, DTE Electric Company (DTE) submitted a license amendment request (LAR) to replace existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. In an email from Ms. Sujata Goetz to Mr. Jason Haas dated March 6, 2018, the NRC sent DTE a request for additional information (RAI) regarding this LAR. The response to the RAI is included in Enclosure 1. to this letter includes a description of revisions to the TS to resolve a generic issue that was recently identified by the industry Technical Specification Task Force in TSTF-542, Revision 2 and to make additional minor editorial corrections to align the proposed TS with the TSTF-542, Revision 2 model application. Enclosure 3 provides the existing TS pages marked to show the proposed changes. Enclosure 4 provides revised (clean) TS pages.

No new commitments are being made in this submittal.

USNRC NRC-18-0019 Page 2 Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

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

Executed on April 4, 2018 Keith J. Polson Senior Vice President and CNO

Enclosures:

1. Response to Request for Additional Information
2. Description of Additional Technical Specification Revisions
3. Proposed Technical Specification Changes (Mark-Up)
4. Revised Technical Specification Pages (Clean) 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)

Enclosure 1 to NRC-18-0019 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Response to Request for Additional Information to NRC-18-0019 Page 1 Response to Request for Additional Information By application dated August 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17243A422, DTE Electric Company, requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, ADAMS Accession No ML16074A448, which would change the technical specifications (TSs) related to operations with a potential for draining the reactor vessel (OPDRVs) with new requirements on reactor pressure vessel water inventory control to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your August 31, 2017, LAR and requests the following additional information.

RAI EICB-1 In Enclosure 1 of the LAR, page 2, the licensee proposed the following variation:

1. The proposed Fermi 2 TS 3.3.5.3, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation, Table 3.3.5.3-1 does not include functions corresponding to STS Table 3.3.5.1-1, Function 1.d, Core Spray Pump Discharge Flow - Low, and Function 2.g, Low Pressure Coolant Injection Pump Discharge Flow - Low, since the Fermi TS do not currently contain these functions in TS Table 3.3.5.1-1.

The Fermi 2 Updated Final Safety Analysis Report, Sections 6.3.2.2.3.3 and 6.3.2.2.4.4, describes the minimum flow instruments which protect the associated low pressure emergency core cooling system (ECCS) pumps from overheating when they are operating and the associated injection valves are not fully open. This protective function automatically signals opening or closing of the valves in the minimum flow bypass lines for the core spray (CS) and low pressure coolant injection (LPCI) pumps.

TSTF-542 states that overall successful reactor pressure vessel water inventory control is based, in part, on the capability of an operable ECCS pump to inject water as needed to make up the inventory.

The presence or absence of a requirement in a current TS is not in and of itself justification for the proposed TS. Since the proposed TS changes omit the equivalent of the TSTF-542 instrumentation requirements for both CS and LPCI pump discharge flow-low (bypass) from the proposed TSs, please describe how there is reasonable assurance that an ECCS pump required by Fermi 2 TS 3.3.5.3 will operate as expected (e.g., the bypass line will not lessen expected discharge flow, and said pump will not overheat when the associated injection valve is not fully open).

to NRC-18-0019 Page 2

RESPONSE

Regarding the Core Spray Pump Discharge Flow - Low (Bypass) and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass) functions, the technical evaluation in Section 3.3.4.2 of TSTF-542 states:

The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not fully open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.

In addition, TSTF-542 states that overall successful reactor pressure vessel water inventory control is based, in part, on the capability of an operable Emergency Core Cooling System (ECCS) pump to inject water as needed to make up the inventory. The proposed Fermi 2 TS 3.3.5.3, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation supports the manual initiation of Core Spray (CS) and Low Pressure Coolant Injection (LPCI) rather than automatic initiation.

The Core Spray and Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass) functions described in TSTF-542 as TS 3.3.5.2 Functions 1.b and 2.b, are based on a design where manual initiation of CS or LPCI is accomplished via single manual pushbutton or hand switch. By design, the Fermi 2 ECCS subsystems do not include a single manual pushbutton or hand switch that activates a manual ECCS initiation. Instead, manual initiation is provided by means of individual component controls as specified in TS Table 3.3.5.3-1 Footnote (c). The necessary alignments and component surveillances are accomplished through use of approved plant procedures and Operators that are trained on the use of these procedures. In Modes 4 or 5, alignment of either CS or LPCI from the normal standby system alignment consists of starting the associated CS or LPCI pump and opening of the injection valve. Both manipulations are performed from the main control room and guidance including the expected minimum flow valve response is provided in system operating procedures.

Therefore, the corresponding automatic support functions are not proposed to be added to the Fermi 2 TS with the adoption of TSTF-542, consistent with these functions not being included in the current Fermi 2 TS. The absence of these functions in the current Fermi 2 TS was previously documented in correspondence NRC-99-0057, Transmittal of Revision 12 to Fermi 2 Improved Technical Specification Submittal (TAC No. MA1465), dated August 4, 1999 and accepted by the NRC as part of License Amendment 134 dated September 30, 1999. The manual operating procedures required to perform the manual initiation of CS and LPCI functions of TS 3.3.5.3 provide reasonable assurance that the pumps will operate as expected and adequate pump protection will be provided.

to NRC-18-0019 Page 3 RAI EICB - 2:

In Enclosure 1 of the LAR, page 3, item 3, you proposed the following variation:

The required channels per function in Fermi 2 TS Table 3.3.5.1-1, Function 1.d, Manual Initiation of the Core Spray system and 2.h, Manual Initiation of the LPCI system, are modified by a footnote stating, Individual Component Controls. The footnote is retained for the manual initiation functions of Core Spray System and LPCI system in the proposed TS Table 3.3.5.3-1, RPV Water Inventory Control Instrumentation as footnote (c) consistent with the current Fermi 2 TS requirements.

The TS bases provided with the LAR, page 3.3.5.3-3, section 1.b, 2b. Manual Initiation, states that the manual initiation channel provides initiation capability by means of individual component controls. The staff interprets this as a CS or LPCI subsystem can be started by manipulating the buttons that control each individual pump and valve. However, the second sentence in that section states that there is one manual initiation channel for each of the CS and LPCI subsystems (i.e., four for CS and four for LPCI).

The design of manual initiation for the CS and LPCI subsystems is unclear to the staff. Does Fermi 2 have the capability to actuate an entire subsystem of CS or LPCI by pressing one or two buttons, or must each subsystems components be actuated individually? Please provide the initiation process for the CS and LPCI.

RESPONSE

Fermi 2 does not have the capability to actuate an entire subsystem of CS or LPCI by a single manual pushbutton, as described in the response to RAI EICB-1. Instead, a CS or LPCI subsystem is actuated by manually controlling each individual component of that subsystem in accordance with approved plant procedures. In this context, the phrase manual initiation channel in the proposed TS Bases page B 3.3.5.3-3 is used to collectively describe all of the individual components required to manually initiate a subsystem and is not intended to imply that pushing one or two buttons actuates an entire subsystem. Collectively referring to the individual component controls of a subsystem as a manual initiation channel in the proposed TS Bases page B 3.3.5.3-3 was done to maintain consistency with the previous usage of the phrase in the Fermi 2 TS Bases, such as shown on page B 3.3.5.1-10 included in the original LAR.

As described in the proposed TS Bases page B 3.5.2-2, a CS or LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the source to the reactor pressure vessel. Since there are four CS pumps and four LPCI pumps, the proposed TS Bases 3.5.2 definition results in four CS subsystems and four LPCI subsystems that can be used for to NRC-18-0019 Page 4 compliance with TS 3.5.2. This variation was described in Section 2.2 of the original LAR on page 3. The parenthetical statement in the proposed TS Bases page B 3.3.5.3-3 that there are four manual initiation channels for CS and four manual initiation channels for LPCI is consistent with this subsystem definition and the intent of the phrase manual initiation channel as described above.

Enclosure 2 to NRC-18-0019 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Description of Additional Technical Specification Revisions to NRC-18-0019 Page 1 In Reference 1, DTE Electric Company (DTE) submitted a license amendment request (LAR) to replace existing Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. The purpose of this enclosure is to describe updates to TS pages to resolve a generic issue identified by the industry Technical Specification Task Force in TSTF-542, Revision 2 and to make editorial changes to align the proposed TS with the TSTF-542, Revision 2 model application. Enclosure 3 provides the TS pages marked-up to show the proposed changes and Enclosure 4 provides revised (clean)

TS pages. Enclosures 3 and 4 supersede the version of those pages previously provided in the Reference 1 LAR.

Prior to TSTF-542, NUREG-1433 TS Table 3.3.5.1-1 Function 1.c (Core Spray System Reactor Steam Dome Pressure - Low (Injection Permissive)) and Function 2.c (LPCI System Reactor Steam Dome Pressure - Low (Injection Permissive)) had a Mode 4 and 5 applicability modified by a note specifying that these functions were only required when the associated ECCS subsystems were required to be operable per LCO 3.5.2, ECCS Shutdown. In TSTF-542, Functions 1.c and 2.c were transferred to Table 3.3.5.2-1 as Functions 1.a and 2.a; however, the note was not transferred with the functions, although the last paragraph of the applicable TS Bases indicates that it had been. Without the note, Functions 1.a and 2.a would be required to be Operable for all low pressure ECCS subsystems regardless of whether the subsystem is credited to meet TS 3.5.2. In Modes 4 and 5, these functions only serve to allow opening of the ECCS injection valves. Since reactor pressure is at atmospheric pressure in Modes 4 and 5, the functions are not needed to protect low pressure piping from excessive pressure. Requiring the functions when the corresponding ECCS subsystems are not required is unnecessary and is therefore an acceptable variation from TSTF-542, Revision 2.

To resolve the issue, the following note is added to Functions 1.a and 2.a of the proposed Table 3.3.5.3-1 (page 3.3-49c), RPV Water Inventory Control Instrumentation, for Fermi 2:

(a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

In addition, the following editorial changes are made to align the proposed Fermi 2 TS with the TSTF-542, Revision 2 model application:

1. An editorial change is made to the DRAIN TIME definition b.1 to remove the word or from the end of the paragraph. Use of the word or is not required as it is implied that there are three independent options for item b).
2. On page 3.3-49a, the word function is capitalized in LCO 3.3.5.3.
3. On page 3.3-49a, the word each is added to the note so it now states Separate Condition entry is allowed for each channel.
4. For LCO 3.5.2 missing periods are added for new Conditions C, D & E.

to NRC-18-0019 Page 2 DTE has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Sections 3.1 and 4.0 of of the Reference 1 LAR. The supplemental information provided in this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

References

1. DTE Electric Letter to NRC, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, NRC-17-0067, dated August 31, 2017 (ML17243A422)

Enclosure 3 to NRC-18-0019 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Proposed Technical Specification Changes (Mark-Up)

Revised Pages 1.1-3 (1.1 Definitions) 3.3-49a (3.3.5.3 RPV Water Inventory Control Instrumentation) 3.3-49c (Table 3.3.5.3-1 RPV Water Inventory Control Instrumentation) 3.5-9 (3.3.5.3 RPV Water Inventory Control Instrumentation Actions) 3.5-9a (3.3.5.3 RPV Water Inventory Control Instrumentation Actions) 3.5-9b (3.3.5.3 RPV Water Inventory Control Instrumentation Actions)

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."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths; -a=

Delete Per NRC-18-0019 (continued)

FERMI - UNIT 2 1.1-3 Amendment No. 134

NEW TS 3.3.5.3 RPV Water Inventory Control Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

Revise Per NRC-18-0019 APPLICABILITY: According to Table 3.3.5.3-1.

Add Per NRC-18-0019 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition referenced Immediately inoperable. in Table 3.3.5.3-1 for the channel.

B. As required by Required B.1 Declare associated penetration Immediately Action A.1 and referenced flow path(s) incapable of in Table 3.3.5.3-1. automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action A.1 and referenced in Table 3.3.5.3-1.

D. As required by Required D.1 Restore channel to OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Action A.1 and referenced status.

in Table 3.3.5.3-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

FERMI - UNIT 2 3.3-49a Amendment No.

NEW TS 3.3.5.3 RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM FUNCTION SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System Add Per NRC-18-0019
a. Reactor Steam Dome Pressure -

4, 5 4(a) SR 3.3.5.3.1 > 441 psig SR 3.3.5.3.2 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per D SR 3.3.5.3.3 NA subsystem (a), (c)
2. Low Pressure Coolant Injection (LPCI) System Add Per NRC-18-0019
a. Reactor Steam Dome Pressure -

4, 5 4(a) C SR 3.3.5.3.1 > 441 psig SR 3.3.5.3.2 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per D SR 3.3.5.3.3 NA subsystem (a), (c)
3. RHR System Isolation
a. Reactor Vessel (b) 2 in one trip B SR 3.3.5.3.1 > 171.9 inches Water Level -

system SR 3.3.5.3.2 Low, Level 3

4. Reactor Water Cleanup (RWCU)

System Isolation

a. Reactor Vessel (b) 2 in one trip B SR 3.3.5.3.1 > 103.8 inches Water Level -

system SR 3.3.5.3.2 Low Low, Level 2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel Water Inventory Control.

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Individual component controls.

FERMI - UNIT 2 3.3-49c Amendment No

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and z 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. containment boundary is capable of being Add Per established in less NRC-18-0019 than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

FERMI - UNIT 2 3.5-9 Amendment No. 134, 241

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.1 -------- NOTE--------

Required ECCS Add Per injection/spray NRC-18-0019 subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for

> 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to Immediately establish secondary containment boundary.

AND D.3 Initiate action to Immediately isolate secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to Immediately verify one standby gas treatment subsystem is capable of being placed in operation.

FERMI - UNIT 2 3.5-9a Amendment No. 134, 241

RPV WaterInventory Control

-ECCS-Shttdowi 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME l

Required Action J.1 Initiate action to Immediately and associated restore Completion Ti not DRAIN TIME to >_

met. PERAEstats. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

lof Condition C or Dl D.2 Initiate action to Imm ately restore one standby gas treatment subsystem to OPERAB DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> status.

AND D.3 Initiat action to Immediately rest isolation Add Per ca ility in each NRC-18-0019 quired secondary containment penetration flow path not isolated.

INSERT New SR 3.5.2.1 (see next Page)

SURV ILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2. Verify, for Sat required low pressure In accordance coolant injection (LPCI) subsystem, the with the suppression pool water level is Surveillance a -66 inches. Frequency Control Program (continued)

FERMI - UNIT 2 3.5-9b Amendment No. -134, 201

Enclosure 4 to NRC-18-0019 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to NRC Request for Additional Information for License Amendment Request to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control Revised Technical Specification Changes Revised Pages 1.1-3 (1.1 Definitions) 3.3-49a (3.3.5.3 RPV Water Inventory Control Instrumentation) 3.3-49c (Table 3.3.5.3-1 RPV Water Inventory Control Instrumentation) 3.5-9 (3.3.5.3 RPV Water Inventory Control Instrumentation Actions) 3.5-9a (3.3.5.3 RPV Water Inventory Control Instrumentation Actions) 3.5-9b (3.3.5.3 RPV Water Inventory Control Instrumentation Actions)

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."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths; (continued)

FERMI - UNIT 2 1.1-3 Amendment No. 34

RPV Water Inventory Control Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.3 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.3-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.3-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.3-1 for the channel.

B. As required by B.1 Declare associated Immediately Required Action A.1 penetration flow and referenced in path(s) incapable of Table 3.3.5.3-1. automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by C.1 Place channel in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Required Action A.1 trip.

and referenced in Table 3.3.5.3-1.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.3-1.

(continued)

FERMI - UNIT 2 3.3-49a Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.3 Table 3.3.5.3-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System
a. Reactor Steam Dome 4,5 4 (a) C SR 3.3.5.3.1 z 441 psig Pressure- Low SR 3.3.5.3.2 (Injection Permissive)
b. Manual Initiation 4,5 1 per D SR 3.3.5.3.3 NA subsystem (a), (c)
2. Low Pressure Coolant Injection (LPCI) System
a. Reactor Steam Dome 4,5 4 (a) C SR 3.3.5.3.1 z 441 psig Pressure-Low SR 3.3.5.3.2 (Injection Permissive)
b. Manual Initiation 4,5 1 per D SR 3.3.5.3.3 NA subsystem (a), (c)
3. RHR System Isolation
a. Reactor Vessel Water (b) 2 in one B SR 3.3.5.3.1 z 171.9 inches Level- Low, Level 3 trip SR 3.3.5.3.2 system
4. Reactor Water Cleanup (RWCU) System Isolation
a. Reactor Vessel Water (b) 2 in one B SR 3.3.5.3.1 z 103.8 inches Level- Low Low, Level trip SR 3.3.5.3.2 2 system (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "Reactor Pressure Vessel Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) Individual component controls.

FERMI - UNIT 2 3.3-49c Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and z 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

FERMI - UNIT 2 3.5-9 Amendment No. 134, 241

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.1 -------- NOTE--------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for

> 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to Immediately establish secondary containment boundary.

AND D.3 Initiate action to Immediately isolate secondary containment penetration flow path or verify it can be manually isolated from the control room.

AND D.4 Initiate action to Immediately verify one standby gas treatment subsystem is capable of being placed in operation.

FERMI - UNIT 2 3.5-9a Amendment No. 134, 291

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to Immediately associated Completion restore DRAIN TIME to Time of Condition C or > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant In accordance injection (LPCI) subsystem, the suppression with the pool water level is -66 inches. Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) In accordance subsystem, the: with the Surveillance

a. Suppression pool water level is Frequency

> -66 inches; or Control Program

b. Condensate storage tank water level is 19 ft.

(continued)

FERMI - UNIT 2 3.5-9b Amendment No. 134, 201, 294

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