View source for NRC-08-0001, Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process

{{Adams
| number = ML080230716
| issue date = 01/15/2008
| title = Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process
| author name = Plona J
| author affiliation = DTE Energy
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-08-0001
| document type = Letter type:NRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 28
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Joseph H. Plona Site Vice President 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy-10 CFR 50.90 January 15, 2008 NRC-08-0001 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

==Reference:==
Fermi 2 Docket No. 50-341 License No. NPF-43

==Subject:==
Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency and a Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Detroit Edison is submitting a request for an amendment to the Technical Specifications (TS) for Fermi 2.
The proposed amendment would: (1) Revise the TS Surveillance Requirement (SR) frequency in TS 3.1.3, "Control Rod OPERABILITY" and (2) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides a summary of the regulatory commitments made in this submittal. Enclosure 5 provides marked up TS Bases pages to show the associated changes.
Due to a position indication problem with control rod 50-31, power reduction is currently required every 7 days to perform the surveillance. Therefore, Detroit IJCR

USNRC NRC-08-0001 Page 2 Edison requests approval of the proposed License Amendment by April 30, 2008 with the amendment being implemented within 60 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Michigan State Official.
If you should have any questions regarding this submittal, please contact Mr. Ronald W. Gaston, Manager, Nuclear Licensing at (734) 586-5197.
Sincerely,

==Enclosures:==
: 1. Description and Assessment
: 2. Proposed Technical Specification Change
: 3. Revised Technical Specification Pages
: 4. Regulatory Commitments
: 5. Proposed Technical Specification Bases Changes cc:  NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-08-0001 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
JOSEPH H. PLONA Site Vice President - Nuclear Generation On this      15          day of 3*-nL o-fr       ,2008 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.
Notary Public                       "
SHA' .~R!L KtoTM PliSvJG, sumT OF ",T OG7OF O

1 TO ENCLOSURE NRC-08-0001 AND ASSESSMENT DESCRIPTION to NRC-08-0001 Page 1

==1.0    DESCRIPTION==

The proposed amendment would: (1) Revise the Technical Specifications (TS) Surveillance Requirement (SR) 3.1.3.2 frequency in TS 3.1.3, "Control Rod OPERABILITY," and (2) revise Example 1.4-3 in Section 1.4 "Frequency" to clarify the applicability of the 1.25 surveillance test interval extension.
The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard TS (STS) change TSTF-475, Revision 1. The Federal Register notice published on November 13, 2007, announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP).
2.0    ASSESSMENT 2.1    Applicability of Published Safety Evaluation Detroit Edison has reviewed the safety evaluation dated November 13, 2007, as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-475, Revision 1. Detroit Edison has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Fermi 2 and justify this amendment for the incorporation of the changes to the Fermi 2 TS.
Fermi 2 is a BWR/4 plant; therefore, the other change in TSTF-475, Revision 1, to clarify the SRM TS action for inserting control rods is not applicable. This clarification is already included in the Fermi 2 TS.
2.2   Optional Changes and Variations Detroit Edison is not proposing any variations or deviations from the TS changes described in the modified TSTF-475, Revision 1, or the NRC staff s model safety evaluation dated November 13, 2007.
The surveillance number changes shown in TSTF-475, Revision 1, TS Bases marked-up pages for re-numbered Section B 3.1.3.3 are not appropriate and will not be adopted.

==3.0   REGULATORY ANALYSIS==

3.1   No Significant Hazards Consideration Determination Detroit Edison has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. Detroit Edison has concluded to NRC-08-0001 Page 2 that the proposed NSHCD presented in the Federal Register notice is applicable to Fermi 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2   Verification and Commitments As discussed in the notice of availability published in the Federal Register on November 13, 2007 for this TS improvement, Detroit Edison verifies the applicability of TSTF-475 to Fermi 2, and commits to establishing Bases for TS as proposed in TSTF-475, Revision 1.
These changes are based on TSTF change traveler TSTF-475, Revision 1, that proposes revisions to the Standard TS (STS) by: (1) Revising the frequency of SR 3.1.3.2, notch testing of fully withdrawn control rods, from "7 days after the control rod is withdrawn and THERMAL POWER is greater than the Low Power Set Point (LPSP) of the Rod Worth Minimizer (RWM)"
to "31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM," and (2) revising Example 1.4-3 in Section 1.4 "Frequency" to clarify that the 1.25 surveillance test interval extension in SR 3.0.2 is applicable to time periods discussed in NOTES in the "SURVEILLANCE" column in addition to the time periods in the "FREQUENCY" column.
4.0    ENVIRONMENTAL EVALUATION Detroit Edison has reviewed the environmental evaluation included in the model safety evaluation dated November 13, 2007, as part of the CLIIP. Detroit Edison has concluded that the staffs findings presented in that evaluation are applicable to Fermi 2 and the evaluation is hereby incorporated by reference for this application.

ENCLOSURE 2 TO NRC-08-0001 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Pages 1.4-4, 1.4-5, 3.1-8, 3.1-10, 3.1-11 and 3.1-14

Frequency 1.4 1.4  Frequency EXAMPLES        EXAMPLE 1,4-2            (continued)
                 "Thereafter" indicates future performances must be established per SR 3.0.2. but only after a specified condition is first met (i.e., the "once" performance in this example).           If reactor power decreases to < 25% RTP. the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.
EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                      FREQUENCY
                  ..................          NOTE ..................
Not required to be performed until 12 hours after - 25% RTP.
Perform channel adjustment.                          7 days The interval continues whether or not the unit operation is
                < 25% RTP between performances.
As the Note modifies the required performance of the Surveillance. it is construed to be part of the "specified Frequency."            Should the 7 day interval be exceeded while operation is < 254 RTP. this Note allows 12 hours after power reaches - 25", RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency." Therefore. if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2). but operation was < 25t RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES. even with the'7 day Frequency not met. provided operation does not exceed 12 hours with power -t25% RTP.
(continued)
FERMI   UNIT 2                               1.4-4                    Amendment No. 134

Frequency 1.4 1.4  Frequency EXAMPLES        EXAMPLE 1.4-3   (continued)
Once the unit reaches 25% RTP. 12 hours would be allowed for completing the Surveillance. If the Surveillance wer performed within this 12 hour interval,! there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
EXAMLE*-
EXAMPLE 1.4-4     "       -
(P*     -    e....                     )
SURVEILLANCE REQUIREMENTS-SURVEILLANCE                       FREQUENCY
                  ------------------ NOTE ------------------
Only required-to be met in MODE 1.
Verify leakage rates are within limits.      24 hours Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.
Therefore, if the Surveillance were not performed within the 24 hour interval (plus the extension allowed by SR 3.0.2).
but the unit was not in MODE 1. there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour Frequency were not met). SR 3.0.4 would require satisfying the SR.
FERMI - UNIT 2                       1.4-5                    Amendment No. 134

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION               REQUIRED ACTION               COMPLETION TIME A.   (continued)           A.3        Perform SR .1.3.2          24 hours from
                                  -O..or                            discovery of each withdrai              Condition A OPERABLE control rod.      concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND A.4         Perform SR 3.1.1.1.      -72 hours B. Two or more withdrawn  B.1        Be in MODE 3.               12 hours control rods stuck.
C. One or more control-  ----------- NOTE .............
rods inoperable for   RWM may be bypassed as reasons other than    allowed by LCO 3.3.2.1. if Condition A or B. required, to allow insertion of inoperable control rod and continued operation.
C.1        Fully insert               3 hours inoperable control rod.
AND C.2        Disarm the associated      4 hours CRD.
kcontinued)
FERMI   -UNIT   2                    3.1-                         Amenament No. 134

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR  3.1.3.1     Determine the position of each control rod.            24 hours SR 3.1.3.2       ...........--.......-. NOTE -------- --------
                   "Not re      red to be performed ntil 7 days afte the control rod is
* hdrawn and MAL POWER is great       than the LPSP of
                     ......................... W...........          .
                                                                          -7 A  -
Insert eact SR 3.1.3                                 NOTE ...................
SR  3.o1t3.required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.
Insert each                withdrawn control rod     31 days at least one notch,.
SR 3.1.3.       Verify each control rod scram time from               In accordance fully withdrawn to notch position 06 is               with
                    - 7 seconds.                                         SR 3.1.4.1.
SR 3.1.4.2.
SR 3.1.4.3. and SR 3.1.4.4 (continued) 1177RMI - UNIT 2                            3.1-10                      Amenoment No. 134

i Control-Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS   (continued)
SURVEILLANCE                        I     FREQUENCY SR 3.1.3e      Verify each control rod does not go to the     Each time the withdrawn overtravel position.                 control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling HERMI - UNIT 2                       3.1-11                  Amendment No. 134

Control Rod Scram Times 3.1.4 Table 3.1.4-1 (page 2 of 1)
Control Rod Scram Times
  ------------------------------------- NOTES ------------------------------------
: 1. OPERABLE control rods with scram times not within the limits of this Table are considered "slow."
: 2. Enter applicable Conditions and Required Actions of LCO 3.1.3. "Control Rod OPERABILITY," for control rods with scram times > 7 seconds to notch positio 06. These control rods are inoperable, in accordance with SR 3.1.3.* aand are not considered "slow.
S     -----------            -----------------------------------------
SCRAM TIMES when REACTOR STIEAma*
PRESSURE z 800 psig (seconds NOTCH POSITION 46 0.457 36                                     1.084 26                                     1.841 06                                     3.361 (a)   Maximum scram time from fully withdrawn position, based on de-energization of scram pilot valve solenoids at time zero.
(b)   When reactor steam dome pressure is < 800 psig established scram time limits apply.
FERMI   - UNIT 2                      3 .1-14                     Amendment No. 134

ENCLOSURE 3 TO NRC-08-0001 REVISED TECHNICAL SPECIFICATIONS PAGES Pages 1.4-4, 1.4-5, 3.1-8, 3.1-10, 3.1-11 and 3.1-14

Frequency 1.4 1.4  Frequency EXAMPLES       EXAMPLE 1.4-2   (continued)
               "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to < 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.
EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                    FREQUENCY
                                -- NOTE--------------
Not required to be performed until 12 hours after &#x17d; 25% RTP.
Perform.channel. adjustment...7...days..
Perform channel adjustment.                7 days The interval continues whether or not the unit operation is
               < 25% RTP between performances.
As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is < 25% RTP, this Note allows 12 hours after power reaches ; 25% RTP to perform the Surveillance. The Surveillance is still considered to be within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by SR 3.0.2), but operation was < 25% RTP, it would not constitute a failure of the SR or failure to meet the LCO. Also, no violation of SR 3.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours (plus the extension allowed by SR 3.0.2) with power ; 25% RTP.
(continued)
FERMI - UNIT 2                     1.4-4                   Amendment No. 134

Frequency 1.4 1.4  Frequency EXAMPLES       EXAMPLE 1.4-3     (continued)
Once the unit reaches 25% RTP, 12 hours would be allowed for completing the Surveillance. If the Surveillance were not performed within this 12 hour interval (plus the extension allowed by SR 3.0.2), there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.
EXAMPLE 1.4-4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                   FREQUENCY
                ---                  NOTE ------------------
Only required to be met in MODE 1.
Verify-eakage-ates-ae-withi- limit..24.ho Verify l~eakage rates are within limits. 24 hours Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.
Therefore, if the Surveillance were not performed within the 24 hour interval (plus the extension allowed by SR 3.0.2),
but the unit was not in MODE 1, there would be no failure of the SR nor failure to meet the LCO. Therefore, no violation of SR 3.0.4 occurs when changing MODES, even with the 24 hour Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour Frequency were not met), SR 3.0.4 would require satisfying the SR.
FERMI - UNIT 2                       1.4-5                   Amendment No. 134

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION                REQUIRED ACTION            COMPLETION TIME A.  (continued)           A.3      Perform SR 3.1.3.2       24 hours from for each withdrawn       discovery of OPERABLE control rod. Condition A concurrent with THERMAL POWER greater than the low power setpoint (LPSP) of the RWM AND A.4      Perform SR 3.1.1.1.      72 hours B. Two or more withdrawn  B.1      Be in MODE 3.            12 hours control rods stuck.
C. One or more control  ------------ NOTE -------------
rods inoperable for   RWM may be bypassed as reasons other than    allowed by LCO 3.3.2.1, if Condition A or B. required, to allow insertion of inoperable control rod and continued operation.
C.1      Fully insert             3 hours inoperable control rod.
AND C.2      Disarm the associated    4 hours CRD.
(continued)
FERMI - UNIT 2                     3.1-8                     Amendment No. 134

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVE I LLANCE                            FREQUENCY SR  3.1.3.1    Determine the position of each control rod. 24 hours SR  3.1.3.2   -------------------NOTE --------------------
Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.
Insert each withdrawn control rod at least     31 days one notch.
SR  3.1.3.3    Verify each control rod scram time from        In accordance fully withdrawn to notch position 06 is        with
* 7 seconds.                                   SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR  3.1.3.4    Verify each control rod does not go to the     Each time the withdrawn overtravel position.                 control rod is withdrawn to "full out" position AND Prior to decl ari ng control rod OPERABLE after work on control rod or CRD System that could affect coupling FERMI - UNIT 2                          3.1-10                Amendment No. 134

Control Rod OPERABILITY 3.1.3 THIS PAGE INTENTIONALLY LEFT BLANK FERMI - UNIT 2               3.1-11                   Amendment No. 134

Control Rod Scram Times 3.1.4 Table 3.1.4-1 (page 1 of 1)
Control Rod Scram Times
------------------------------------- NOTES ------------------------------
: 1. OPERABLE control rods with scram times not within the limits of this Table are considered "slow."
: 2.                Enter applicable Conditions and Required Actions of LCO 3.1.3, "Control Rod OPERABILITY," for control rods with scram times > 7 seconds to notch position 06. These control rods are inoperable, in accordance with SR 3.1.3.3, and are not considered "slow."
SCRAM TIMES when REACTOR STEAM DOME PRESSURE &#x17d; 800 psig (seconds)(a)(b)
NOTCH POSITION 46                               0.457 36                               1.084 26                               1.841 06                               3.361 (a)                         Maximum scram time from fully withdrawn position, based on de-energization of scram pilot valve solenoids at time zero.
(b)                         When reactor steam dome pressure is < 800 psig established scram time limits apply.
FERMI                                 UNIT 2                                        3.1-14                    Amendment No.
0 ENCLOSURE 4 TO NRC-08-0001 REGULATORY COMMITMENTS to NRC-08-0001 Page 1 REGULATORY COMMITMENTS:
The following table identifies those actions committed to by Detroit Edison in this document.
Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Ronald W. Gaston, Manager, Nuclear Licensing at (734) 586-5197.
REGULATORY COMMITMENTS                               DUE DATE / EVENT Detroit Edison will establish the Technical  To be implemented concurrently with Specification Bases for TS B 3.1.3, TS B     imnplementation of the associated license 3.1.4, and TS B 3.3.1.2 consistent with      amendment.
those shown in TSTF-475, Revision 1, "Control Rod Notch-Testing Frequency and SRM Insert Control Rod Action."

a ENCLOSURE 5 TO NRC-08-0001 PROPOSED TECHNICAL SPECIFICATION BASES PAGES Pages B 3.1.3-4, B 3.1.3-8, B 3.1.3-9, B 3.1.4-3, and B 3.3.1.2-5

Control Rod OPERABILITY B 3.1.3 BASES ACTIONS (continued)
RWM is bypassed to ensure compliance with the CRDA analysis.
With one withdrawn control rod stuck, the local scram reactivity rate and CRDA control rod worth assumptions may not be met if the stuck control rod separation criteria are not met. Therefore, a verification that the separation criteria are met must be performed immediately.         The separation criteria are not met if: a) the stuck control rod occupies a location adjacent to two "slow" control rods; b) the stuck control rod occupies a location adjacent to. one "slow" control rod, and the one "slow" control rod is also adjacent to another "slow" control rod; or c) if the stuck control rod occupies a location adjacent to one "slow" control rod when there is another pair of "slow" control rods-adjacent to-one another.         The description of "slow" control rods is provided in LCO 3.1.4, "Control Rod Scram Times."     In addition, the associated control rod drive must be disarmed in 2 hours. The allowed Completion Time of 2 hours is acceptable, considering the reactor can still be shut down, assuming no additional control rods fail to insert, and provides a reasonable time to perform the Required Action in an orderly manner.         Isolating the control rod from scram prevents damage to the CRDM. The control rod can be isolated from scram and normal insert and withdraw pressure, yet still maintain cooling water to the CRD.
Monitoring of the insertion capability of each withdrawn control rod must also be performed within 24 hours from discovery of Condition A concurrent with THERMAL POWER greater than the-low power setpoint (LPSP) of the RWM.
SR 3 .1. 3.2(,a!l*d3*-,       3)perform periodic tests of the control rod insertion capability of withdrawn control rods.
Testing each withdrawn control rod ensures that a generic problem does not exist. This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." The Required Action A.3 Completion Time only begins upon discovery of Condition A concurrent with THERMAL POWER greater than the actual LPSP of the-RWM, since the notch insertions may not be compatible with the requirements of rod pattern control (LCO 3.1.6) and the RWM (LCO 3.3.2.1).        The allowed Completion Time of 24 hours from discovery of Condition A concurrent with THERMAL POWER greater than the IDID ^f +6              provids a reasonable time to test the control rods, considering the potential for a need to reduce power to perform the tests.
FERMI - UNIT 2                           B 3.1.3-4                           Revision 0

Control Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR3...
Control rod insertion capability is demonstrated by inserting each partially or fully withdrawn control rod at least one notch and observing that the control rod moves.
The control rod may then be returned to its original position. This ensures the control rod is not stuck and is free to insert on a scram signal.              These Surveillances are not required when THERMAL POWER is less than or equal to the actual LPSP of the RWM, since the notch insertions may not be compatible with the requirements of the prescribed withdrawal seauence (LCO 3.1.61 and the RWM (LCO 3.3.2.1).
7 d yThereque          of SR      .3.2 is     sed on otrating -n exp      ence r        ed    o e Chan          in CRD       ormance        the se of       ormi          otch t      ng for       IV wit      n&#xfd;contro rods.      artially withdrawn control rods are tested at a 1  day  Frequency, re~quired to allow based        on the rod the control     potential   power reduction movementaH*-4R     {*~~-**
* arg*-@*-tIng~ *    "6f.*.Furthermore,                    the 31 day Frequency takes into account operating experience related to changes in CRD performance.                At any time, if a withdrawn control rod is immovable, a determination of that control rod~s ability to insert on a scram (OPERABILITY) must be made and appropriate action taken.
SR L.1.3 Verifying that the scram time for each control rod to notch position 06 is
* 7 seconds provides reasonable assurance that the control rod will insert when required during a DBA or transient, thereby completing its shutdown function.
This SR is performed in conjunction with the control rod scram time testing of SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4.         The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.1.1, "Reactor Protection System (RPS)
Instrumentation," that overlaps this Surveillance and the functional testing of SDV vent and drain valves in LCO 3.1.8, "Scram Discharge Volume (SDV) Vent and Drain Valves," provide complete testing of the assumed safety function. The associated Frequencies are acceptable, considering the more frequent testing performed to demonstrate other aspects of control rod OPERABILITY and operating experience, which shows scram times do not significantly change over an operating cycle.
FERMI  - UNIT 2                          B 3.1.3-8                                 Revision 0

Control Rod OPERABILITY B 3.1.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.1*3.)    '
Coupling verification is performed to ensure the control rod is connected to-the CRDM and will perform its intended function when necessary. The Surveillance requires verifying a control rod does not go to the withdrawn overtravel position. The overtravel position feature provides a positive check on the coupling integrity since only an uncoupled CRD can reach the overtravel position.
The verification is required to be performed any time a control rod is withdrawn to the "full out" position (notch position 48) or prior to declaring the control rod OPERABLE after work on the control rod or CRD System that could affect coupling. This includes- control rods inserted one notch and then returned to the "full out" position during the performance of SR 3.1.3.2. This Frequency is acceptable, considering the low probability that a control rod will become uncoupled when it is not being moved and operating experience related to uncoupling events.
REFERENCES         1. 10 CFR 50, Appendix A, GDC 26,  GDC 27, GDC 28, and GDC 29.
: 2. UFSAR, Section 4.5.2.1.3.
: 3. UFSAR, Chapter 15.
: 4. NEDO-21231, "Banked Position Withdrawal Sequence,"
Section 7.2, January 1977.
FERMI - UNIT 2                      B .3.1.3 - 9                         Revision 0

Control Rod Scram Times B 3.1.4 BASES LCO (continued) is accomplished through measurement of the "dropout" times.
To ensure that local scram reactivity rates are maintained within acceptable limits, no more than two of the allowed "slow" control rods may occupy adjacent (i.e., face adjacent or diagonally adjacent) locations.
Table 3.1.4-1 is modified by two Notes which state that control rods with scram times not within the limits of the table are considered "slow" and that control rods with scram times > 7 seconds are considered inoperable as required by SR 3.1.3.An This LCO applies only to OPERABLE control rods since inoperable-control rods will be-inserted and disarmed-(LCO 3.1.3). Slow scramming control rods may be conservatively declared inoperable and not accounted for as "slow" control rods.
APPLICABILITY   In MODES I and 2, a scram is assumed to function during transients and accidents analyzed for these plant conditions. These events are assumed to occur during startup and power operation; therefore, the scram function of the control rods is required during these MODES.      In MODES 3 and 4, the control rods are not able to be withdrawn since the reactor mode switch is in shutdown and a control rod block is applied. This provides adequate requirements for control rod scram capability during these conditions.
Scram requirements in MODE 5 are contained in LCO 3.9.5, "Control Rod OPERABILITY-Refueling."
ACTIONS         A.I When the requirements of this LCO are not met, the rate of negative reactivity insertion during a scram may not be within the assumptions of the safety analyses. Therefore, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brouaht tn M*nF I within 12 hmrc      Thk  allowed rComplet Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                    B 3.1.4- 3                         Revision 0

SRM Instrumentation B 3.3.1.2 BASES ACTIONS (continued) position prevents subsequent control rod withdrawal by maintaining a control rod block. The allowed Completion Time of 1 hour is sufficient to accomplish the Required Action, and takes into account the low probability of an event requiring the SRM occurring during this interval.
E.1 and E.2 With one or more required SRMs inoperable in MODE 5, the ability to detect local reactivity changes in the core during refueling is degraded. CORE ALTERATIONS must be immediatel ysuspended and action must be immediately
                   'in iia e to insert all insertable control rods in core cells containing one or more fuel assemblies. Suspending CORE ALTERATIONS prevents the two most probable causes of reactivity-changes, fuel loading and control rod withdrawal, from occurring. Inserting all insertable control rods ensures that the reactor will be at its minimum reactivity given that fuel is present in the core. Suspension of CORE ALTERATIONS shall not preclude completion of the movement of a component to a safe, conservative position.
Action (once required to be initiated) to insert control rods must continue until all insertable rods in core cells containing one or more fuel assemblies are inserted.
SURVEILLANCE       The SRs for each SRM Applicable MODE or other specified REQUIREMENTS       conditions are found in the SRs column of Table 3.3.1.2-1.
SR   3.3.1.2.1 and SR   3.3.1.2.3 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on another channel.       It is based on the assumption that instrument channels monitoring-the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious.
A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to oper4te properly between each CHANNEL CALIBRATION.
FERMI - UNIT 2                      B 3.3.1.2- 5                         Revision 0}}