View source for NRC-13-0001, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, Using the Consolidated Line Item Improvement Process

{{Adams
| number = ML13014A125
| issue date = 01/11/2013
| title = License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, Technical Specifications End States, NEDC-32988-A, Using the Consolidated Line Item Improvement Process
| author name = Conner J
| author affiliation = DTE Energy
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000341
| license number = NPF-043
| contact person = 
| case reference number = NRC-13-0001
| document type = Letter type:NRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 133
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:J. Todd Conner Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849        Fax: 734.586.5295 Email: connerj@dteenergy.com DTE Energy-10 CFR 50.90 January 11, 2013 NRC-13-0001 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington D C        20555-0001

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

==Subject:==
License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process Regulations (10 In accordance with the provisions of Title 10 of the Code of Federal a request for an CFR) Section 50.90, DTE Electric Company (DTE) is submitting the NRC-amendment to Fermi 2 Technical Specifications (TS) to incorporate approved TSTF-423, Revision 1.
regarding The proposed amendment would modify TS to risk-inform requirements reactor selected Required Action end states by incorporating the boiling water (BWR) owners' group (BWROG) approved Topical Report NEDC-32988-A, to Revision 2, "Technical Justification to Support Risk-Informed Modification Selected Required Action End States for BWR Plants."
Actions with Additionally, the proposed amendment would modify the TS Required 3.0.4.a when a Note prohibiting the use of limiting condition for operation (LCO) entering the preferred end state (Mode 3) on startup.
the
   "   Enclosure 1 provides a description and assessment of the proposed change, requested confirmation of applicability, and plant-specific verifications.
submittal.
   "   Enclosure 2 summarizes the regulatory commitments made in this change.
    "  Enclosure 3 provides markup pages of existing TS to show the proposed

USNRC NRC-13-0001 Page 2
"    Enclosure 4 provides revised (clean) TS pages.
only.
"    Enclosure 5 provides markup pages of existing TS Bases, for information 11, 2013. Once Approval of the proposed license amendment is requested by July approved, the amendment will be implemented within 60 days.
the analysis In accordance with 10 CFR 50.91(a)(1), "Notice for public comment,"
standards about the issue of no significant hazards consideration (NSHC) using the in accordance with   the in 10 CFR 50.92 is being provided to the Commission distribution requirements in 10 CFR 50.4.
this In accordance with 10 CFR 50.91(b)(1), "State consultation," a copy of to the application and the reasoned analysis about NSHC is being provided designated State of Michigan Official.
contact Mr.
Should you have any questions or require additional information, please Zackary W. Rad of my staff at (734) 586-5076.
Sincerely,

==Enclosures:==

of
: 1. Description and Assessment of Proposed Change, Requested Confirmation Applicability, and Plant-Specific Verifications.
: 2. Regulatory Commitments
: 3. Markup Pages of TS
: 4. Revised (Clean) TS pages
: 5. Markup Pages of TS Bases cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0001 Page 3 statements are based on facts I, J. Todd Conner, do hereby affirm that the foregoing to the best of my knowledge and and circumstances which are true and accurate belief.
J. T      Conner Site Vice President, Nuclear Generation I               day of Unaar                 , 2013 before me personally On this and says that he executed the appeared J. Todd Conner, being first duly sworn foregoing as his free act and deed.
Notary Public SHARON 8. MARSHALL NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun14, 2013 ACTING INCOUNTYOF H o

Enclosure 1 to NRC-13-0001 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specifications Specifications End States, Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Process NEDC-32988-A," Using the Consolidated Line Item Improvement Description and Assessment of Proposed Change, Requested Confirmation of Applicability, and Plant-Specific Verifications NRC-13-0001 Page 1

==1.0       DESCRIPTION==

(TS) to risk-inform The proposed amendment would modify technical specifications it would modify the requirements regarding selected Required Action end states. Additionally, condition   for  operation (LCO)
TS Required Actions with a Note prohibiting the use of limiting The changes are consistent 3.0.4.a when entering the preferred end state (Mode 3) on startup.
Specification Task Force with Nuclear Regulatory Commission (NRC)-approved Technical End States, NEDC-32988-A,"
(TSTF) traveler TSTF-423, Revision 1, "Technical Specifications (Reference 1). The dated December 22, 2009 (ADAMS Accession Number ML093570241)
: 34) (Reference 2) announced the FederalRegister notice published on February 18, 2011 (76 FR item improvement process availability of this TS improvement as part of the consolidated line (CLIIP).
2.0      ASSESSMENT 2.1      Applicability of Topical Report NEDC-32988-A, TSTF-423, and Model Safety Evaluation owners' group DTE Electric Company (DTE) has reviewed boiling water reactor (BWR)
Revision 1 (Reference (BWROG) topical report (TR) NEDC-32988-A (Reference 3), TSTF-423,
: 4) as part of the CLIIP. DTE 1), and the NRC staff's model safety evaluation (SE) (Reference and the NRC staff's model has concluded that the information in TR NEDC-32988, TSTF-423, (LAR) for the SE are applicable to Fermi 2 and justify this license amendment request incorporation of the changes to the Fermi 2 TS.
2.2      Optional Changes and Variations TS changes described DTE is proposing variations or deviations from TR NEDC-32988-A, the in the FederalRegister on in the TSTF-423, Revision 1, or the NRC staff's model SE referenced February 18, 2011 (76 FR 34) as part of the CLIIP Notice of Availability. The proposed described in the TSTF-variations/deviations proposed from TR NEDC-32988-A, the TS changes 423, Revision 1, or the NRC staff model SE are discussed in the table below:
NRC-13-0001 Page 2 Comments Variations / Deviations No       Fermi     Title /Description and is not No    TS #
No changes to TS 3.4.3 are      The Standard TS, Conditions A is optional Safety Relief Valves                                                                                      Condition A, 3.4.3 proposed.                       included in the current Fermi TS. Fermi TS, (SRVs)                                                                                                     It requires is for one or more required SRVs inoperable.
36 hours, being in Mode 3 in 12 hours and Mode 4 in C in TSTF-1                                                                     which is similar to the proposed Condition to this TS.
423; therefore, no changes are proposed low pressure Condition D in the Fermi TS is  The Standard TS, Condition A, is for one Emergency Core Cooling                                                                        one  LPCI    pump in 3.5.1 proposed to be revised per      ECCS injection/spray subsystem or Systems (ECCS) -                                        both LPCI subsystems inoperable. Fermi TS has separate TSTF-423; however, it applies                                                      ECCS Operating when Conditions A, B, or C      Conditions: Condition A for one low pressure Condition B for are not met. Conditions in the  injection/spray subsystem inoperable and inoperable.
Fermi TS are numbered           one LPCI pump in both LPCI subsystems Condition C for one Additionally, the Fermi TS includes one LPCI differently from the Standard    Core Spray subsystem inoperable and 2                                      TS Conditions.
subsystem concurrently inoperable.
report and model The justification provided in the topical Condition C of the SE for this change is also applicable to Fermi TS.
for MSIV LCS.
No changes to TS 3.6.1.9 are    Fermi TS does not include a specification 3.6.1.9   Main Steam Isolation proposed.
3             Valve (MSIV) Leakage Control System (LCS)
NRC-13-0001 Page 3 Comments Title /Description       Variations / Deviations Fermi No.       TS#
Condition C in the Fermi TS is The Standard TS, Condition A, is for secondary Secondary Containment                                                                             Condition A for 3.6.4.1 proposed to be revised per     containment inoperable. Fermi TS has to one railroad bay TSTF-423; however, it applies  secondary containment inoperable due B for secondary when Conditions A or B are     access door inoperable; and Condition than Condition not met.                       containment inoperable for reasons other A.
4 report and model The justification provided in the topical to Condition A of the SE for this change is also applicable Fermi TS.
Conditions A No changes to TS 3.7.2 are     The proposed changes in TSTF-423 affect Emergency Equipment                                                                              A is for one pump 3.7.2 proposed.                      and B of the Standard TS. Condition Cooling Water (EECW) /                                 inoperable and Condition B is for one pump in each Emergency Equipment                                                                               does not include subsystem inoperable. The Fermi TS Service Water (EESW)                                                                          It includes Condition Conditions for pump inoperability.           cross-tie line(s);
System and Ultimate                                    A for UHS inoperable due to inoperable 5            Heat Sink (UHS)                                                                                       and Condition C Condition B for one reservoir inoperable; for reasons for one EECW/EESW subsystem inoperable the  proposed other than Conditions A and B. Therefore,                  TS.
to the Fermi changes in TSTF-423 are not applicable 3.7-6, An obsolete footnote is        The footnote on the current Fermi TS, page completion 3.7.3   Control Room                                                                  allowed  extension   of the proposed to be deleted.         describes a onetime Emergency Filtration                                                                                     the footnote time that is no longer applicable; therefore, (CREF) System                                                                                        to be  deleted.
and the associated asterisk are proposed 6
NRC-13-0001 Page 4 Comments Title /Description         Variations / Deviations No.      Fermi TS #
The proposed change is             The Standard TS, Condition A, is for one [control room 3.7.4     Control Center Air                                                                                                     in consistent with TSTF-423;          AC] subsystem inoperable. This Condition is included Conditioning (AC) however, it is applied to          the Fermi TS. The change in TSTF-423 when Required System Condition C which is entered      Action and Completion Time of Condition A are not met when Conditions A or B are        is applied with no variation.
not met. The Fermi TS              Condition D of the Standard TS requires entering LCO incorporates TSTF-477;             3.0.3 immediately for two [control room AC] subsystems therefore, the proposed Fermi      inoperable. The Fermi TS Condition B is for two control 7                                                                           center AC subsystems inoperable. It requires verifying TS change reflects the TSTF-423 change as it applies after     control room area temperature < 90*F once per 4 hours TSTF-477 has been                 and restoring one subsystem to operable within 72 hours.
incorporated.                     The change to the Standard TS in TSTF-423 requires D.
being in Mode 3 within 12 hours of entering Condition This change is applied to the Fermi   TS  when  Required Action and Completion Time of Condition B are not met.
The proposed change is             The Fermi TS contains all the Conditions in the Standard 3.8.1    AC Sources - Operating consistent with TSTF-423;          TS with the exception of the optional Condition F for one inoperable. The Fermi TS also however, the Conditions in the automatic load sequencer Fermi TS are numbered              includes Condition B for both EDGs in one division differently from the Standard      inoperable. The associated Required Actions and TS Conditions.                     Completion Times are consistent with those for Condition 8
B of the Standard TS (One EDG inoperable).
The justification provided in the topical report and model B of the SE for this change is also applicable to Condition Fermi TS.
No changes are proposed.           Fermi TS does not include a specification for Inverters.
9   N/A       Inverters - Operating are    Optional Conditions in the Standard TS are not included 3.8.4 /  DC Sources - Operating / Conditions in the Fermi TS numbered differently from  the     in the Fermi TS.
10    3.8.7    Distribution Systems -
Operating                  Standard TS Conditions.
NRC-13-0001 Page 5

==3.0     REGULATORY ANALYSIS==

3.1     No Significant Hazards Consideration Determination in DTE Electric Company (DTE) has evaluated the proposed changes to the TS using the criteria 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.
Description of Amendment Request: A change is proposed to the TS of Fermi 2, consistent with TSTF-423, Revision 1, to allow, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed consistent with the program in place for complying with the requirements of 10 CFR 50.65(a)(4). Changes proposed in TSTF-423 will be made to the Fermi 2 TS for selected Required Action end states.
Basis for no significant hazards consideration determination: As required by 10 CFR 50.91(a),
DTE analysis of the issue of no significant hazards consideration is presented below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change allows a change to certain required end states when the TS Completion Times for remaining in power operation will be exceeded. Most of the requested technical specification (TS) changes are to permit an end state of hot shutdown (Mode 3) rather than an end state of cold shutdown (Mode 4) contained in the current TS.
The request was limited to: (1) those end states where entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. Risk insights from both the qualitative and quantitative risk assessments were used in specific TS assessments. Such assessments are documented in Section 6 of topical report NEDC-32988-A, Revision 2, "Technical Justification to Support Risk Informed Modification to Selected Required Action End States for BWR Plants." They provide an integrated discussion of deterministic and probabilistic issues, focusing on specific TSs, which are used to support the proposed TS end state and associated restrictions. The NRC staff finds that the risk insights support the conclusions of the specific TS assessments. Therefore, the probability of an accident previously evaluated is not significantly increased, if at all. The consequences of an accident after adopting TSTF-423 are no different than the consequences of an accident prior to adopting TSTF-423. Therefore, the consequences of an accident previously evaluated are not significantly affected by this change. The addition of a requirement to assess and manage the risk introduced by this change will further minimize possible concerns.
NRC-13-0001 Page 6 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 involve a physical alteration of the plant (no new or different type of equipment will be installed). If risk is assessed and managed, allowing a change to certain required end states when the TS Completion Times for remaining in power operation are exceeded (i.e., entry into hot shutdown rather than cold shutdown to repair equipment) will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated. The addition of a requirement to assess and manage the risk introduced by this change and the commitment by the licensee to adhere to the guidance in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 1, 'Technical Specifications End States, NEDC-32988-A," will further minimize possible concerns.
Thus, based on the above, this change does not create the possibility of a new or different kind of accident from an accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change allows, for some systems, entry into hot shutdown rather than cold shutdown to repair equipment, if risk is assessed and managed. The BWROG's risk assessment approach is comprehensive and follows NRC staff guidance as documented in Regulatory Guides (RG) 1.174 and 1.177. In addition, the analyses show that the criteria of the three-tiered approach for allowing TS changes are met. The risk impact of the proposed TS changes was assessed following the three-tiered approach recommended in RG 1.177. A risk assessment was performed to justify the proposed TS changes. The net change to the margin of safety is insignificant.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based upon the reasoning presented above, DTE concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."
NRC-13-0001 Page 7 Needed 3.2       Verifications, Commitments, and Additional Information
: 2. In addition, DTE has proposed TS DTE commits to the regulatory commitments in Enclosure provide guidance and details on how to Bases consistent with TSTF-423, Revision 1, which TSTF-423 requires that risk be managed implement the new requirements. Implementation of program is adequate to satisfy this and assessed, and DTE's configuration risk management but may be a qualitative assessment of requirement. The risk assessment need not be quantified, one or more systems are not able to perform the vulnerability of systems and components when Program consistent with Section 5.5 their associated function. Finally, DTE has a Bases Control of the Standard Technical Specifications (STS).
4.0      ENVIRONMENTAL EVALUATION respect to installation or use of a facility The proposed change would change a requirement with in 10 CFR Part 20, and would change an component located within the restricted area, as defined proposed change does not involve (i) a inspection or surveillance requirement. However, the in the types or significant increase in significant hazards consideration, (ii) a significant change or (iii) a significant increase in the amounts of any effluents that may be released offsite, Accordingly, the proposed change individual or cumulative occupational radiation exposure.
set forth in 10 CFR 51.22(c)(9).
meets the eligibility criterion for categorical exclusion impact statement or environmental Therefore, pursuant to 10 CFR 51.22(b), no environmental change.
assessment need be prepared in connection with the proposed

==5.0     REFERENCES==

NEDC-32988-A," dated
: 1. TSTF-423, Revision 1, "Technical Specifications End States, December 22, 2009 (ADAMS Accession No. ML093570241).
96              of Availability of the Proposed Models
: 2. FederalRegister, Vol. 76, No. 34, p. 14, "Notice Task Force (TSTF) Traveler TSTF-for Plant-Specific Adoption of Technical Specifications NEDC-32988-A,' for Boiling Water 423, Revision 1, 'Technical Specifications End States, Process," dated December Reactor Plants Using the Consolidated Line Item Improvement 22, 2009 (ADAMS Accession No. ML102730585).
to Support Risk-Informed Modification
: 3. NEDC-32988-A, Revision 2, "Technical Justification December 2002 (ADAMS to Selected Required Action End States for BWR Plants,"
Package Accession No. ML030170090).
1, dated February 18, 2011 (ADAMS
: 4. NRC Model Safety Evaluation of TSTF-423, Revision Accession No. ML102730688).

Enclosure 2 to NRC-13-0001 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process Regulatory Commitments NRC-13-0001 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by DTE Electric Company (DTE) 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. Rodney W. Johnson at (734) 586-5076.
REGULATORY COMMITMENTS                                   DUE DATE/EVENT DTE will follow the guidance established in Section 11 of    Ongoing.
NUMARC 93-01,"Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Nuclear Management and Resource Council, Revision 3, July 2000.
DTE will follow the guidance established in TSTF-IG     To be implemented with 02, Revision 2,"Implementation Guidance for TSTF-423,        amendment.
Revision 1, Technical Specifications End States, NEDC-32988-A."

Enclosure 3 to NRC-13-0001 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process Markup Pages of TS 3.3-74                     3.5-2                        3.5-3 3.5-3a                    3.5-12                       3.6-20 3.6-23                    3.6-24                        3.6-25 3.6-33                    3.6-35                        3.6-40 3.6-47                    3.6-48                         3.7-2 3.7-6                     3.7-8                        3.7-11 3.7-14                    3.8-2c                        3.8-16 3.8-27

RPS Electric Power Monitoring 3.3.8.2 3.3 INSTRUMENTATION 3.3.8.2   Reactor Protection System (RPS) Electric Power Monitoring LCO  3.3.8.2      Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.
APPLICABILITY:    MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies, or with both residual heat removal shutdown cooling (RHR-SDC) isolation valves open.
ACTIONS CONDITION                  REQUIRED ACTION             COMPLETION TIME A. One or both inservice      A.1     Remove associated         72 hours power supplies with               inservice power one electric power                supply(s) from monitoring assembly               service.
inoperable.
B. One or both inservice     B.1     Remove associated         1 hour power supplies with              inservice power both electric power              supply(s) from monitoring assemblies            service.
inoperable.
C. Required Action and        C.1     -------- NOTE--------
associated Completion             LCO 3.,0.4.a is not Time of Condition A               a licable when or B not met in                   entering ODE 3.
MODE 1, 2, or 3.                  --------------------
Be in MODE 3.             12 hours AND G2- -- n         9MODE-4-.        36-hours (continued)
FERMI - UNIT 2                       3.3-74                      Amendment No. 134

ECCS-Operating 3.5.1 ACTIONS (continued)
CONDITION             REQUIRED ACTION        COMPLETION TIME D. Required Action and    D.1   -------- NOTE-----
associated Completion       tC 3.0.4.a is not Time of Condition A,        app icable when B, or C not met.            entering MODE 3.
Be in MODE 3.         12 hours D.2   Be in MODE 1.36hop E. HPCI System           E.1   Verify by             Immediately inoperable.                 administrative means RCIC System is OPERABLE.
AND E.2    Restore HPCI System  14 days to OPERABLE status.
F. HPCI System            F.1   Restore HPCI System  72 hours inoperable.                 to OPERABLE status.
AND                  OR Condition A, or       F.2   Restore low pressure  72 hours Condition B, or             ECCS injection/spray Condition C entered.        subsystem(s) to OPERABLE status.
G. One ADS valve          G.1   Restore ADS valve to  14 days inoperable.                 OPERABLE status.
(continued)
FERMI - UNIT 2                  3.5-2                   Amendment No. 4-34

ECCS - Operating 3.5.1 ACTIONS (continued)
CONDITION                REQUIRED ACTION         COMPLETION TIME H. One ADS valve              H.1    Restore ADS valve to   72 hours inoperable.                    OPERABLE status.
AND                     OR Condition A or          H.2    Restore low pressure   72 hours Condition B entered.           ECCS injection/spray subsystem(s) to OPERABLE status.
I. Required Action and        I.1    -------- NOTE--------
associated Completion           LCO 3.0.4.a is not Time of Condition E,            applicable when F, G, or H not met, entering MODE 3.
Be in MODE 3.          12 hours 1.3. Two or more ADS valves   -1.1        Be in MODE 3. 12 hours inoperable.
AND OR 1J.2        Reduce reactor    36 hours Requ red-Action-and       -    steam dome pressure associated-4;ompletion         to s 150 psig.
Time- f-C-ond4tion-E, (continued)
FERMI - UNIT 2                       3.5-3                   Amendment No. 134

ECCS - Operating 3.5.1 ACTIONS (continued)
CONDITION              REQUIRED ACTION        COMPLETION TIME J(. Two or more low         _.1      Enter LCO 3.0.3. Immediately pressure ECCS injection/spray subsystems inoperable for reasons other than Condition B or C.
OR HPCI System and one or more ADS valves inoperable.
OR Condition C and Condition G entered.
FERMI - UNIT 2                  3.5-3a                      Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3    RCIC System LCO 3.5.3          The RCIC System shall be OPERABLE.
APPLICABILITY:     MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.
ACTIONS
 ... ... ... ... - .--------------------- NOTE-----------------------------
LCO 3.0.4.b is not applicable to RCIC.
CONDITION                     REQUIRED ACTION             COMPLETION TIME A. RCIC System                 A.1       Verify by                 Immediately inoperable,                         administrative means High Pressure Coolant Injection System is OPERABLE.
AND A.2       Restore RCIC System        14 days to OPERABLE status.
B. Required Action and        B.1        -------- NOTE--------
associated Completion                LCO 3.0.4.a is not Time not met.                        app licable when entering ODE 3.
Be in MODE 3.             12 hours AND FERMI - UNIT 2                          3.5-12                Amendment No. AM4,   -163

LLS Valves 3.6.1.6 3.6 CONTAINMENT SYSTEMS 3.6.1.6    Low-Low Set (LLS) Valves LCO   3.6.1.6       The LLS function of two safety/relief valves shall be OPERABLE.
APPLICABILITY:      MODES 1, 2, and 3.
ACTIONS CONDITION                     REQUIRED ACTION          COMPLETION TIME A. One LLS valve               A.1       Restore LLS valve to    14 days inoperable.                         OPERABLE status.
B. Required Action and         B.1        -------- NOTE --------
associated Completion               LCO 3.0.4.a is not Time of Condition A                 app licable when not met.                            entering MODE 3.
8R
                                 ~--_Be in MODE 3.                 12 hours Both ((S valves 4neperab e                 AND Be       in MODE 4, 1       i        i3-64eu-rte C. Both LLS valves             C.1       Be in MODE 3.           12 hours inoperabIe.
C.2      Be in MODE 4.           36 hours FERMI - UNIT 2                           3.6-20                    Amendment No. 434

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 ACTIONS (continued)
CONDITION                  REQUIRED ACTION          COMPLETION TIME D. Required Action and        D.1      -       NOTE ------
AssociatedCornpetion            LCO 3.0.4.a is not Time of Condition C             applicable when not met,                        entering MODE 3.
Be in MODE 3.            12 hours DE. Two lines with one or    DE.1          Restore all       1 hour more reactor building-            vacuum breakers in to-suppression chamber            one line to OPERABLE vacuum breakers                  status.
inoperable for opening.
EF. Required Action and       EF.1       Be in MODE 3.        12 hours Associated Completion Time of Condition A,     AND B, or E not met.
EF.2        Be in MODE 4.       36 hours FERMI - UNIT 2                        3.6-23                   Amendment No. 434

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR 3.6.1.7.1     ------------------ NOTES------------------
: 1. Not required to be met for vacuum breakers that are open during Surveillances.
: 2. Not required to be met for vacuum breakers open when performing their intended function.
Verify each vacuum breaker is closed.        14 days SR 3.6.1.7.2    Perform a functional test of each vacuum     31 days breaker.
SR 3.6.1.7.3    Verify the opening setpoint of each          18 months vacuum breaker is 0.5 psid.
NO CHANGES TO TEXT ON THIS PAGE.
INFORMATION MOVED FROM PREVIOUS PAGE.
FERMI - UNIT 2                        3.6-24                   Amendment No. 4-34

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.8 3.6 CONTAINMENT SYSTEMS 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.8        Twelve suppression chamber-to-drywell vacuum breakers shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                   REQUIRED ACTION          COMPLETION TIME A. One suppression             A.1      Restore vacuum          72 hours chamber-to-drywell                breaker to OPERABLE vacuum breaker                    status.
inoperable for opening.
B. Required Action and        B.1       -------- NOTE--------
associated Completion              LCO 3.0.4.a is not Time of Condition A                applicable when not met.                           entering MODE 3.
Be in MODE 3.         12 hours BC. One or more               8C.1          Close the open     2 hours suppression chamber-              vacuum breaker(s).
to-drywell vacuum breaker not closed.
GD. Required Action and       GD.1          Be in MODE 3.      12 hours associated Completion Time of Condition C      AND not met.
GD.2          Be in MODE 4.      36 hours FERMI - UNIT 2                         3.6-25                   Amendment No. 134

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3    Residual Heat Removal (RHR) Suppression Pool Cooling LCO   3.6.2.3      Two RHR suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION            COMPLETION TIME A. One RHR suppression         A.1     Restore RHR              7 days pool cooling subsystem            suppression pool inoperable.                      cooling subsystem to OPERABLE status.
B. Required Action and        B.1      -------- NOTE--------
associated Completion            LCO 3.0.4.a is not Time of Condition A              applicable when entering MODE 3.
Be in MODE 3.           12 hours BC. Two RHR suppression        BC.1         Restore one RHR     8 hours pool cooling                     suppression pool subsystems inoperable.           cooling subsystem to OPERABLE status.
GD. Required Action and       GD.1         Be in MODE 3.        12 hours associated Completion Time of Condition C      AND not met.
GD.2         Be in MODE 4.        36 hours FERMI - UNIT 2                        3.6-33                     Amendment No. 134

RHR Suppression Pool Spray 3.6.2.4 3.6 CONTAINMENT SYSTEMS 3.6.2.4    Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4        Two RHR suppression pool spray subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION             COMPLETION TIME A. One RHR suppression        A.1     Restore RHR                7 days pool spray subsystem             suppression pool inoperable.                      spray subsystem to OPERABLE status.
B. Two RHR suppression        B.1    Restore one RHR            8 hours pool spray subsystems            suppression pool inoperable.                      spray subsystem to OPERABLE status.
C. Required Action and        C.1     -------- NOTE--------
associated Completion            LCO 3.0.4.a is not Time not met.                     applicable when entering MODE 3.
Be in MODE 3.              12 hours AND C.2    Be
                                         -in    MODE            36hours FERMI - UNIT 2                       3.6-35                       Amendment No. 134

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1   Secondary Containment LCO  3.6.4.1      The secondary containment shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                   REQUIRED ACTION             COMPLETION TIME A. Secondary Containment       A.1     Restore railroad bay       7 days inoperable due to one             door to OPERABLE railroad bay access               status.
door inoperable.
B. Secondary containment      B.1      Restore secondary         4 hours inoperable in MODE 1,              containment to 2, or 3 for reasons                OPERABLE status.
other than Condition A.
C. Required Action and        C.1      -------- NOTE-------
associated Completion              LCO 3.0.4.a is not Time of Condition A or             a licable when B not met.                         entering MODE 3.
Be in MODE 3.             12 hours AND C.2-----Be-inM4-4.                -36he4r-s (continued)
FERMI - UNIT 2                         3.6-40                Amendment No. XXX', 444

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO   3.6.4.3      Two SGT subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                     REQUIRED ACTION            COMPLETION TIME A. One SGT subsystem           A.1       Restore SGT subsystem     7 days inoperable.                         to OPERABLE status.
B. Required Action and         B.1       -------- NOTE--------
associated Completion                LCO 3.0.4.a is not Time of Condition A                  app licable when not met in MODE 1, 2,                entering MODE 3.
or 3.                                --------------------
Be in MODE 3.            12 hours
                                 -AND B.2       Bc in MODE 4.            36-houps (continued)
FERMI - UNIT 2                           3.6-47                Amendment No. #$4,  144

SGT System 3.6.4.3 ACTIONS (continued)
CONDITION                 REQUIRED ACTION           COMPLETION TIME C. Required Action and      ------------ NOTE------------
associated Completion  LCO 3.0.3 is not applicable.
Time of Condition A    ----------------------------
not met during movement of recently   C.1        Place OPERABLE SGT      Immediately irradiated fuel                   subsystem in assemblies in the                 operation.
secondary containment or during OPDRVs.      OR C.2.1      Suspend movement of     Immediately recently irradiated fuel assemblies in secondary containment.
AND C.2.2      Initiate action to     Immediately suspend OPDRVs.
D.1      -------- NOTE-    -
D. Two SGT subsystems inoperable in MODE 1,           LC0        awhennot 2,or 3.                       app    aI e
_       en entering MODE .
Enter- LCO-3..3.         4mmed4ate!y Be in MODE 3.             12 hours (continued)
FERMI - UNIT 2                        3.6-48              Amendment No. I4, 444

RHRSW System 3.7.1 ACTIONS (continued)
CONDITION                   REQUIRED ACTION          COMPLETION TIME D. Required Action and        D.1    -------- NOTE -------
associated Completion            LCO 3.0.4.a is not Time of Condition A.             applicable when B, or C not met.                 entering MODE 3.
Be in MODE 3.           12 hours DE. Both RHRSW subsystems     DE.1    -------- NOTE ---------
inoperable for reasons            Enter applicable other than                        Conditions and Condition B.                      Required Actions of LCO 3.4.8 for RHR shutdown cooling made inoperable by RHRSW System.
Restore one RHRSW       8 hours subsystem to OPERABLE status.
EF. Required Action and       EF.1         Be in MODE 3.      12 hours associated Completion Time of Condition E       AND not met.
EF.2         Be in MODE 4.      36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR 3.7.1.1     Verify each RHRSW manual, power operated,       31 days 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.
FERMI - UNIT 2                         3.7-2                    Amendment No. -134

CREF System 3.7.3 3.7   PLANT SYSTEMS 3.7.3    Control Room Emergency Filtration (CREF) System LCO   3.7.3         The CREF System shall be OPERABLE.
--------------     ------------------NOTE---------------         ------------------
The control room boundary may be opened intermittently under administrative control.
APPLICABILITY:      MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION           COMPLETION TIME A. One CREF subsystem           A.1      Restore CREF            7 days inoperable.                        subsystem to OPERABLE status.
B. Two CREF subsystems          B.1     Restore control room    24 hours-inoperable due to                  boundary to OPERABLE inoperable control                 status.
room boundary in MODE 1, 2, or 3.
C. Required Action and          C.1     -------- NOTE--------
associated Completion              LCO 3.0.4.a is not Time of Condition A or             applicable when B not met in MODE 1,               entering MODE 3.
2, or 3.                           --------------------
Be in MODE 3.            12 hours AND G.2     Be inMODE-4              36-hours (continued)
The 24 houros Cmpl-etion-4me-is extended onetime--to-4ho   us-t-eempete F p -c of ? DINiTio n7 2 Return AiroFan i-n Ma149 A                             -1 FERMI   - UNIT 2                         3.7-6     Amendment No. 134, 141, 11942

CREF System 3.7.3 ACTIONS (continued)
CONDITION                   REQUIRED ACTION           COMPLETION TIME E. Two CREF subsystems or    E.1       -------- NOTE--------
a non-redundant                  iC0 3.0.4.a ino t component or portion              applicable when of the CREF System                enteringMODE 3.
inoperable in MODE 1, 2, or 3 for reasons                 -- ~~~--------
other than Condition                Entr LCO 3.0.3 B.                                                         -Iame4ate4 Be in MODE 3.          12 hours F. Two CREF subsystems or  ------------ NOTE------------
a non-redundant         LCO 3.0.3 is not applicable.
component or portion     -----------------------------
of the CREF System inoperable during       F.1       Initiate action to       Immediately movement of recently               suspend OPDRVs.
irradiated fuel assemblies in the      AND secondary containment, or during OPDRVs.       ------------ NOTE-------------
Not required for a CREF System or subsystem inoperable due to failure to provide the required filtration efficiency, or due to replacement of charcoal filtration media.
F.2       Suspend movement of recently irradiated      Immediately fuel assemblies in the secondary containment.
FERMI - UNIT 2                         3.7-8     Amendment No. XZ 4,    4, 19. 4-62

Control Center AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4    Control Center Air Conditioning (AC) System LCO   3.7.4        Two control center AC subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                 REQUIRED ACTION                  COMPLETION TIME A. One control center AC A.1            Restore control           30 days subsystem inoperable.              center AC subsystem to OPERABLE status.
B. Two control center AC    B.1        Verify control            Once per 4 hours subsystems                         room area inoperable.                        temperature <90*F.
AND B.2       Restore one control       72 hours center AC subsystem to OPERABLE status.
C. Required Action and       C.1        -------- NOTE -------
associated Completion              LCO 3.0.4.a is not Time of Condition A                 applicable when or B not met in MODE               entering MODE 3.
1, 2, or 3.                        -------------------
Be in MODE 3.             12 hours AND C.2        Be  in MODE-4 FERMI - UNIT 2                           3.7-11           Amendment No. 1341, 41,~177

Main Condenser Offgas 3.7.5 3.7   PLANT SYSTEMS 3.7.5    Main Condenser Offgas LCO   3.7.5        The gross radioactivity rate of the noble gases measured at the discharge of the 2.2 minute delay piping shall be
                   < 340 mCi/second after decay of 30 minutes.
APPLICABILITY:     MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.
ACTIONS CONDITION                    REQUIRED ACTION            COMPLETION TIME A. Gross radioactivity        A.1        Restore gross             72 hours rate of the noble                   radioactivity rate of gases not within                    the noble gases to limit.                             within limit.
B. Required Action and        B.1       Isolate all main          12 hours associated Completion              steam lines.
Time not met.
OR B.2        Isolate SJAE.            12 hours OR B.3-1          ------  NOTE-----
N-
                                           --- LCO 3.0.4.a is not ap licable when entering   DE 3.
Be in MODE 3.             12 hours FANF B3. .2Be      n   ODE 4,             3"eur4Fs FERMI   - UNIT 2                        3.7-14                      Amendment No. .134

AC Sources -Operating 3.8.1 ACTIONS (continued)
CONDITION               REQUIRED ACTION              COMPLETION TIME F. One offsite circuit     ------------- NOTE------------
inoperable.           Enter applicable Conditions and Required Actions of AND                   LCO 3.8.7, "Distribution Systems - Operating," when One or both EDGs in   Condition F is entered with one Division          no AC power source to one or inoperable.           more 4160 V buses 64B, 64C, 65E or 65F.
F.1      Restore offsite            12 hours circuit to OPERABLE status.
OR F.2      Restore both EDGs in       12 hours the Division to OPERABLE status.
G. Required Action and   G.1      -------- NOTE --------
Associated Completion          LCO 3.0.4.a is not Time of Condition A,           aplicable when B, C, D, E or F not            entering   ODE 3.
met.                           -_-_-_-_-_-_-_-------------
Be in MODE 3.              12 hours AND G.2      Be in MODE-4               36-hours FERMI - UNIT 2                     3.8-2c                        Amendment No.
DC Sources -Operating 3.8.4 3.8  ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources-Operating LCO 3.8.4        The Division I and Division II DC electrical power subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One battery charger        A.1     Restore battery             4 hours inoperable.                      charger to OPERABLE status.
B. One DC electrical         B.1     Restore DC electrical        2 hours power subsystem                   power subsystem to inoperable for reasons           OPERABLE status.
other than Condition A.
C. Required Action and       C.1      -------- NOTE --------
Associated Completion             LCO 3.0.4.a is not Time not met.                     applicable when entering MODE 3.
Be in MODE 3.                12 hours AND C.2     Be inMODE 4.                364iurs FERMI - UNIT 2                            3.8-16                    Amendment No. 134

Distribution Systems -Operating 3.8.7 ACTIONS (continued)
CONDITION                  REQUIRED ACTION            COMPLETION TIME B. One or more required      B.1     Restore DC electrical    2 hours DC electrical power              power distribution distribution                     subsystem(s) to          AND subsystems inoperable.           OPERABLE status.
16 hours from discovery of failure to meet LCO C. Required Action and       C.1     -------- NOTE--------
associated Completion            LCO 3.0.4.a is not Time of Condition A              applicable when or B not met.                    entering MODE 3.
Be in MODE 3.            12 hours AND G.2     Be in- MO9E-4            36-heurs D. Two or more required      D.1     Enter LCO 3.0.3.          Immediately electrical power distribution subsystems inoperable that result in a loss of function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                               FREQUENCY SR   3.8.7.1    Verify correct breaker alignments and           7 days voltage to required AC and DC electrical power distribution subsystems.
FERMI - UNIT 2                       3.8-27                     Amendment No. 434

Enclosure 4 to NRC-13-0001 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process Revised (Clean) TS pages 3.3-74                     3.5-2                        3.5-3 3.5-3a                    3.5-12                       3.6-20 3.6-23                    3.6-24                       3.6-25 3.6-33                    3.6-35                       3.6-40 3.6-47                    3.6-48                        3.7-2 3.7-6                     3.7-8                       3.7-11 3.7-14                    3.8-2c                       3.8-16 3.8-27

RPS Electric Power Monitoring 3.3.8.2 3.3   INSTRUMENTATION 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring LCO 3.3.8.2         Two RPS electric power monitoring assemblies shall be OPERABLE for each inservice RPS motor generator set or alternate power supply.
APPLICABILITY:      MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies, or with both residual heat removal shutdown cooling (RHR-SDC) isolation valves open.
ACTIONS CONDITION                   REQUIRED ACTION             COMPLETION TIME A. One or both inservice       A.1     Remove associated          72 hours power supplies with               inservice power one electric power                 supply(s) from monitoring assembly               service.
inoperable.
B. One or both inservice      B.1      Remove associated         1 hour power supplies with                inservice power both electric power                supply(s) from monitoring assemblies              service.
inoperable.
C. Required Action and         C.1      -------- NOTE--------
associated Completion              LCO 3.0.4.a is not Time of Condition A                applicable when or B not met in                    entering MODE 3.
MODE 1, 2, or 3.                   --------------------
Be in MODE 3.             12 hours (continued)
FERMI - UNIT 2                         3.3-74                      Amendment No. 4-34

ECCS - Operating 3.5.1 ACTIONS (continued)
CONDITION            REQUIRED ACTION        COMPLETION TIME D. Required Action and     D.1  -------- NOTE--------
associated Completion      LCO 3.0.4.a is not Time of Condition A,        applicable when B, or C not met.           entering MODE 3.
Be in MODE 3.         12 hours E. HPCI System           E.1  Verify by             Immediately inoperable.                administrative means RCIC System is OPERABLE.
AND E.2  Restore HPCI System   14 days to OPERABLE status.
F. HPCI System            F.1  Restore HPCI System   72 hours inoperable.                to OPERABLE status.
AND                   OR Condition A, or       F.2   Restore low pressure 72 hours Condition B, or             ECCS injection/spray Condition C entered.        subsystem(s) to OPERABLE status.
G. One ADS valve          G.1   Restore ADS valve to  14 days inoperable.                OPERABLE status.
(continued)
FERMI - UNIT 2                  3.5-2                  Amendment No. --34

ECCS - Operating 3.5.1 ACTIONS (continued)
CONDITION            REQUIRED ACTION        COMPLETION TIME H. One ADS valve           H.1  Restore ADS valve to  72 hours inoperable.                OPERABLE status.
AND                    OR Condition A or        H.2  Restore low pressure  72 hours Condition B entered.       ECCS injection/spray subsystem(s) to OPERABLE status.
I. Required Action and    I.1  -------- NOTE--------
associated Completion      LCO 3.0.4.a is not Time of Condition E,       applicable when F, G, or H not met.
entering MODE 3.
Be in MODE 3.         12 hours J. Two or more ADS valves J.1  Be in MODE 3.         12 hours inoperable.
AND J.2   Reduce reactor steam 36 hours dome pressure to s 150 psig.
(continued)
FERMI - UNIT 2                  3.5-3                  Amendment No. 134

ECCS - Operating 3.5.1 ACTIONS (continued)
CONDITION             REQUIRED ACTION    COMPLETION TIME K. Two or more low          K.1  Enter LCO 3.0.3. Immediately pressure ECCS injection/spray subsystems inoperable for reasons other than Condition B or C.
OR HPCI System and one or more ADS valves inoperable.
OR Condition C and Condition G entered.
FERMI - UNIT 2                  3.5-3a                  Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO    3.5.3        The RCIC System shall be OPERABLE.
APPLICABILITY:      MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.
ACTIONS
     . . . . . . . . . . . . ----------- NOTE-----------------------------
LCO 3.0.4.b is not applicable to RCIC.
CONDITION                   REQUIRED ACTION             COMPLETION TIME A. RCIC System                A.1      Verify by                  Immediately inoperable.                       administrative means High Pressure Coolant Injection System is OPERABLE.
AND A.2      Restore RCIC System        14 days to OPERABLE status.
B. Required Action and        B.1      -------- NOTE --------
associated Completion              LCO 3.0.4.a is not Time not met.                      applicable when entering MODE 3.
Be in MODE 3.              12 hours FERMI - UNIT 2                         3.5-12                Amendment No. /1X4. 163

LLS Valves 3.6.1.6 3.6  CONTAINMENT SYSTEMS 3.6.1.6   Low-Low Set (LLS) Valves LCO   3.6.1.6     The LLS function of two safety/relief valves shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION          COMPLETION TIME A. One LLS valve              A.1     Restore LLS valve to   14 days inoperable.                      OPERABLE status.
B. Required Action and       B.1     -------- NOTE--------
associated Completion            LCO 3.0.4.a is not Time of Condition A              applicable when not met.                         entering MODE 3.
Be in MODE 3.          12 hours C. Both LLS valves           C.1    Be in MODE 3.          12 hours inoperable.
AND C.2    Be in MODE 4.          36 hours FERMI - UNIT 2                       3.6-20                   Amendment No. 134

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 ACTIONS (continued)
CONDITION                  REQUIRED ACTION          COMPLETION TIME D. Required Action and        D.1    -------- NOTE--------
Associated Completion           LCO 3.0.4.a is not Time of Condition C             applicable when not met.                        entering MODE 3.
Be in MODE 3.            12 hours E. Two lines with one or     E.1      Restore all vacuum     1 hour more reactor building-            breakers in one line to-suppression chamber            to OPERABLE status.
vacuum breakers inoperable for opening.
F. Required Action and        F.1   Be in MODE 3.             12 hours Associated Completion Time of Condition A,     AND B, or E not met.
F.2    Be in MODE 4.            36 hours FERMI - UNIT 2                        3.6-23                   Amendment No. 134

Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                             FREQUENCY SR   3.6.1.7.1   ------------------ NOTES------ --------
: 1. Not required to be met for vacuum breakers that are open during Surveill ances.
: 2. Not required to be met for vacuum breakers open when performing their intended function.
Verify each vacuum breaker is closed.      14 days SR 3.6.1.7.2    Perform a functional test of each vacuum   31 days breaker.
SR 3.6.1.7.3    Verify the opening setpoint of each        18 months vacuum breaker is < 0.5 psid.
FERMI - UNIT 2                       3.6-24                  Amendment No. 434

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.8 3.6  CONTAINMENT SYSTEMS 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.8       Twelve suppression chamber-to-drywell vacuum breakers shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION          COMPLETION TIME A. One suppression            A.1       Restore vacuum          72 hours chamber-to-drywell                  breaker to OPERABLE vacuum breaker                      status.
inoperable for opening.
B. Required Action and        B.1       -------- NOTE--------
associated Completion              LCO 3.0.4.a is not Time of Condition A                applicable when not met.                           entering MODE 3.
Be in MODE 3.         12 hours C. One or more                C.1       Close the open vacuum  2 hours suppression chamber-                breaker(s).
to-drywell vacuum breaker not closed.
D. Required Action and       D.1      Be in MODE 3.           12 hours associated Completion Time of Condition C       AND not met.
D.2       Be in MODE 4.          36 hours FERMI - UNIT 2                          3.6-25                   Amendment No. 134

RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO   3.6.2.3      Two RHR suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                   REQUIRED ACTION          COMPLETION TIME A. One RHR suppression        A.1      Restore RHR             7 days pool cooling subsystem            suppression pool inoperable.                       cooling subsystem to OPERABLE status.
B. Required Action and        B.1      -------- NOTE--------
associated Completion             LCO 3.0.4.a is not Time of Condition A               applicable when not met.                          entering MODE 3.
Be in MODE 3.         12 hours C. Two RHR suppression        C.1     Restore one RHR         8 hours pool cooling                      suppression pool subsystems inoperable.            cooling subsystem to OPERABLE status.
D. Required Action and        D.1      Be in MODE 3.           12 hours associated Completion Time of Condition C      AND not met.
D.2      Be in MODE 4.           36 hours FERMI - UNIT 2                        3.6-33                    Amendment No. 134

RHR Suppression Pool Spray 3.6.2.4 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO   3.6.2.4     Two RHR suppression pool spray subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION           COMPLETION TIME A. One RHR suppression       A.1      Restore RHR              7 days pool spray subsystem             suppression pool inoperable.                      spray subsystem to OPERABLE status.
B. Two RHR suppression      B.1      Restore one RHR          8 hours pool spray subsystems            suppression pool inoperable.                      spray subsystem to OPERABLE status.
C. Required Action and      C.1      -------- NOTE--------
associated Completion            LCO 3.0.4.a is not Time not met.                    applicable when entering MODE 3.
Be in MODE 3.            12 hours FERMI - UNIT 2                       3.6-35                    Amendment No. 434

Secondary Containment 3.6.4.1 3.6  CONTAINMENT SYSTEMS 3.6.4.1    Secondary Containment LCO  3.6.4.1       The secondary containment shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION             COMPLETION TIME A. Secondary Containment       A.1       Restore railroad bay       7 days inoperable due to one               door to OPERABLE railroad bay access                 status.
door inoperable.
B. Secondary containment      B.1       Restore secondary          4 hours inoperable in MODE 1,               containment to 2, or 3 for reasons                 OPERABLE status.
other than Condition A.
C. Required Action and        C.1        -------- NOTE--------
associated Completion               LCO 3.0.4.a is not Time of Condition A or              applicable when B not met.                          entering MODE 3.
Be in MODE 3.              12 hours (continued)
FERMI - UNIT 2                          3.6-40                Amendment No. /#, 144

SGT System 3.6.4.3 3.6   CONTAINMENT SYSTEMS 3.6.4.3   Standby Gas Treatment (SGT) System LCO 3.6.4.3       Two SGT subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                     REQUIRED ACTION            COMPLETION TIME A. One SGT subsystem         A.1        Restore SGT subsystem     7 days inoperable.                         to OPERABLE status.
B. Required Action and       B.1        -------- NOTE--------
associated Completion               LCO 3.0.4.a is not Time of Condition A                 applicable when not met in MODE 1, 2,               entering MODE 3.
or 3.                               --------------------
Be in MODE 3.             12 hours (continued)
FERMI - UNIT 2                          3.6-47                Amendment No. P ,  444

SGT System 3.6.4.3 ACTIONS (continued)
CONDITION                  REQUIRED ACTION           COMPLETION TIME C. Required Action and     ------------ NOTE------------
associated Completion  LCO 3.0.3 is not applicable.
Time of Condition A    ----------------------------
not met during movement of recently   C.1       Place OPERABLE SGT       Immediately irradiated fuel                  subsystem in assemblies in the                operation.
secondary containment or during OPDRVs.      OR C.2.1     Suspend movement of      Immediately recently irradiated fuel assemblies in secondary containment.
AND C.2.2      Initiate action to       Immediately suspend OPDRVs.
D. Two SGT subsystems     D.1      -------- NOTE--------
inoperable in MODE 1,          LCO 3.0.4.a is not 2 or 3     i                   applicable when 3entering                          MODE 3.
Be in MODE 3.              12 hours (continued)
FERMI - UNIT 2                      3.6-48                Amendment No. #ld. 144

RHRSW System 3.7.1 ACTIONS (continued)
CONDITION                  REQUIRED ACTION          COMPLETION TIME D. Required Action and       D.1    -------- NOTE -------
associated Completion           LCO 3.0.4.a is not Time of Condition A,            applicable when B, or C not met.                entering MODE 3.
Be in MODE 3.           12 hours E. Both RHRSW subsystems     E.1      -------- NOTE---------
inoperable for reasons           Enter applicable other than                       Conditions and Condition B.                     Required Actions of LCO 3.4.8 for RHR shutdown cooling made inoperable by RHRSW System.
Restore one RHRSW       8 hours subsystem to OPERABLE status.
F. Required Action and       F.1      Be in MODE 3.          12 hours associated Completion Time of Condition E      AND not met.
F.2     Be in MODE 4.          36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                             FREQUENCY SR   3.7.1.1    Verify each RHRSW manual, power operated,     31 days 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.
FERMI - UNIT 2                        3.7-2                   Amendment No. 134

CREF System 3.7.3 3.7 PLANT SYSTEMS 3.7.3     Control Room Emergency Filtration (CREF) System LCO    3.7.3           The CREF System shall be OPERABLE.
 . . .     . .   . . .   . .           . . -T------------
                               . . . -------- NOTE-----------------------------
The control room boundary may be opened intermittently under administrative control.
APPLICABILITY:         MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                      REQUIRED ACTION           COMPLETION TIME A. One CREF subsystem              A.1       Restore CREF             7 days inoperable.                            subsystem to OPERABLE status.
B. Two CREF subsystems             B.1       Restore control room     24 hours inoperable due to                      boundary to OPERABLE inoperable control                     status.
room boundary in MODE 1, 2, or 3.
C. Required Action and             C.1       -------- NOTE--------
associated Completion                   LCO 3.0.4.a is not Time of Condition A or                  applicable when B not met in MODE 1,                   entering MODE 3.
2, or 3.                                --------------------
Be in MODE 3.           12 hours (continued)
FERMI    - UNIT 2                            3.7-6      Amendment No. 134,144-49, -82

CREF System 3.7.3 ACTIONS (continued)
CONDITION                  REQUIRED ACTION            COMPLETION TIME E. Two CREF subsystems or    E.1      -------- NOTE--------
a non-redundant                  LCO 3.0.4.a is not component or portion             applicable when of the CREF System               entering MODE 3.
inoperable in MODE 1, 2, or 3 for reasons              --------------------
other than Condition               Be in MODE 3.
B.                                                         12 hours F. Two CREF subsystems or   ------------ NOTE-------------
a non-redundant         LCO 3.0.3 is not applicable.
component or portion     -----------------------------
of the CREF System inoperable during       F.1      Initiate action to        Immediately movement of recently             suspend OPDRVs.
irradiated fuel assemblies in the       AND secondary containment, or during OPDRVs.-    ------------ NOTE-----------
Not required for a CREF System or subsystem inoperable due to failure to provide the required filtration efficiency, or due to replacement of charcoal filtration media.
F.2     Suspend movement of recently irradiated      Immediately fuel assemblies in the secondary containment.
FERMI - UNIT 2                        3.7-8      Amendment No. ,If4, tA,  X0.   ,62

Control Center AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4    Control Center Air Conditioning (AC) System LCO   3.7.4        Two control center AC subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                 REQUIRED ACTION               COMPLETION TIME A. One control center AC    A.1      Restore control          30 days subsystem inoperable.            center AC subsystem to OPERABLE status.
B. Two control center AC    B.1      Verify control            Once per 4 hours subsystems                       room area inoperable,                      temperature <90&deg;F.
AND B.2      Restore one control       72 hours center AC subsystem to OPERABLE status.
C. Required Action and      C.1       -------- NOTE-------
associated Completion           LCO 3.0.4.a is not Time of Condition A              applicable when or B not met in MODE            entering MODE 3.
1, 2, or 3.                      -------------------
Be in MODE 3.             12 hours FERMI - UNIT 2                        3.7-11           Amendment No. 134, 144, 177

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3.7.5   Main Condenser Offgas LCO 3.7.5         The gross radioactivity rate of the noble gases measured at the discharge of the 2.2 minute delay piping shall be s  340 mCi/second after decay of 30 minutes.
APPLICABILITY:    MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.
ACTIONS CONDITION                   REQUIRED ACTION           COMPLETION TIME A. Gross radioactivity        A.1      Restore gross            72 hours rate of the noble                 radioactivity rate of gases not within                  the noble gases to limit.                            within limit.
B. Required Action and        B.1     Isolate all main         12 hours associated Completion             steam lines.
Time not met.
OR B.2      Isolate SJAE.           12 hours OR B.3-   -------- NOTE-------
LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.            12 hours FERMI - UNIT 2                        3.7-14                     Amendment No. 134

AC Sources -Operating 3.8.1 ACTIONS (continued)
CONDITION                REQUIRED ACTION            COMPLETION TIME F. One offsite circuit    ------------- NOTE------------
inoperable.           Enter applicable Conditions and Required Actions of AND                   LCO 3.8.7, "Distribution Systems - Operating," when One or both EDGs in   Condition F is entered with one Division          no AC power source to one or inoperable.           more 4160 V buses 64B, 64C, 65E or 65F.
F.1      Restore offsite           12 hours circuit to OPERABLE status.
OR F.2      Restore both EDGs in      12 hours the Division to OPERABLE status.
G. Required Action and    G.1      -------- NOTE--------
Associated Completion          LCO 3.0.4.a is not Time of Condition A,           applicable when B, C, D, E or F not            entering MODE 3.
met.                           --------------------
Be in MODE 3.             12 hours FERMI - UNIT 2                     3.8-2c                      Amendment No.1-7-5

DC Sources -Operating 3.8.4 3.8   ELECTRICAL POWER SYSTEMS 3.8.4    DC Sources-Operating LCO   3.8.4        The Division I and Division II DC electrical power subsystems shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION             COMPLETION TIME A. One battery charger        A.1     Restore battery            4 hours inoperable.                      charger to OPERABLE status.
B. One DC electrical          B.1     Restore DC electrical      2 hours power subsystem                  power subsystem to inoperable for reasons           OPERABLE status.
other than Condition A.
C. Required Action and         C.1     -------- NOTE--------
Associated Completion             LCO 3.0.4.a is not Time not met.                    applicable when entering MODE 3.
Be in MODE 3.               12 hours FERMI   - UNIT 2                          3.8-16                  Amendment No. 134

Distribution Systems -Operating 3.8.7 ACTIONS (continued)
CONDITION                   REQUIRED ACTION            COMPLETION TIME B. One or more required      B.1      Restore DC electrical    2 hours DC electrical power                power distribution distribution                       subsystem(s) to          AND subsystems inoperable.            OPERABLE status.
16 hours from discovery of failure to meet LCO C. Required Action and       C.1      -------- NOTE--------
associated Completion             LCO 3.0.4.a is not Time of Condition A               applicable when or B not met.                     entering MODE 3.
Be in MODE 3.            12 hours D. Two or more required      D.1      Enter LCO 3.0.3.          Immediately electrical power distribution subsystems inoperable that result in a loss of function.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR 3.8.7.1      Verify correct breaker alignments and            7 days voltage to required AC and DC electrical power distribution subsystems.
FERMI - UNIT 2                        3.8-27                     Amendment No. 134

Enclosure 5 to NRC-13-0001 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-423, Revision 1, "Technical Specifications End States, NEDC-32988-A," Using the Consolidated Line Item Improvement Process Markup Pages of TS Bases B 3.3.8.2-5                B 3.3.8.2-6                  B 3.3.8.2-7 B 3.3.8.2-8                 B 3.5.1-7                    B 3.5.1-8 B 3.5.1-9                 B 3.5.1-10                   B 3.5.1-11 B 3.5.1-14                 B 3.5.1-16                   B 3.5.1-19 B 3.5.1-20                 B 3.5.3-3a                    B 3.5.3-6 B 3.6.1.6-3                B 3.6.1.6-4                  B 3.6.1.6-5 B 3.6.1.7-5                B 3.6.1.7-6                  B 3.6.1.7-7 B 3.6.1.8-4                B 3.6.1.8-5                  B 3.6.1.8-7 B 3.6.2.3-3                B 3.6.2.3-4                  B 3.6.2.3-5 B 3.6.2.4-3                B 3.6.2.4-4                  B 3.6.2.4-5 B 3.6.4.1-3               B 3.6.4.1-3a                  B 3.6.4.1-7 B 3.6.4.3-4                B 3.6.4.3-6                  B 3.6.4.3-8 B 3.6.4.3-9                 B 3.7.1-5                    B 3.7.1-6 B 3.7.1-7                  B 3.7.3-5                    B 3.7.3-6 B 3.7.3-7                  B 3.7.3-8                   B 3.7.3-11 B 3.7.4-1                  B 3.7.4-4                    B 3.7.4-7 B 3.7.5-2                  B 3.7.5-3                    B 3.7.5-4 B 3.8.1-8                 B 3.8.1-8a                   B 3.8.1-10 B 3.8.1-12                 B 3.8.1-13                   B 3.8.1-14 B 3.8.1-15                 B 3.8.1-16                   B 3.8.1-17 B 3.8.1-18                 B 3.8.1-19                   B 3.8.1-20 B 3.8.4-1                  B 3.8.4-2                    B 3.8.4-4 B 3.8.4-5                  B 3.8.4-7                    B 3.8.4-8 B 3.8.4-9                  B 3.8.7-7                    B 3.8.7-8 B 3.8.7-9

RPS Electric Power Monitoring B 3.3.8.2 BASES ACTIONS (continued) operations personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration or removal from service of the electric power monitoring assemblies.
Alternately, if it is not desired to remove the power supply(s) from service (e.g., as in the case where removing the power supply(s) from service would result in a scram or isolation), Condition C or D, as applicable, must be entered and its Required Actions taken.
C.1 and-C-4 If any Required Action and associated Completion Time of Condition A or B are not met in MODE 1, 2, or 3, the plant must be brought to a Mode in which overall plant risk is minimized.                      ---cpfrm           i p3i t ep ant in a coniti         hre minimal cqument--powered through th'einoperable RPS electric power-menitoring as-senib~y(s), is required-and-ensues- thathe safety functionr  of the-RBS-(e-g., scram ofcn-trol9 rods) is not required. The plant shutdown is accomplished by placing the plant in MODE 3 within 12 hours. and in MODE 4-within 36-houps-Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE         Ref. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b. if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
FERMI - UNIT 2                     B 3.3.8.2-5                        Revision 0

RPS Electric Power Monitoring B 3.3.8.2 BASES ACTIONS (continued)
The allowed Completion Times pa-e-isreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
D.1, D.2.1, and D.2.2 If any Required Action and associated Completion Time of Condition A or B are not met in MODE 4 or 5, or with any control rod withdrawn from a core cell containing one or more fuel assemblies or with both RHR shutdown cooling valves open, the operator must immediately initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies. Required Action D.1 results in the least reactive condition for the reactor core and ensures that the safety function of the RPS (e.g., scram of control rods) is not required.
In addition, action must be immediately initiated to either restore one electric power monitoring assembly to OPERABLE status for the inservice power source supplying the required instrumentation powered from the RPS bus (Required Action D.2.1) or to isolate the RHR Shutdown Cooling System (Required Action D.2.2). Required Action D.2.1 is provided because the RHR Shutdown Cooling System may be needed to provide core cooling. All actions must continue until the applicable Required Actions are completed.
SURVEILLANCE      SR  3.3.8.2.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each overvoltage, undervoltage, and underfrequency channel to ensure that the entire channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.
As noted in the Surveillance, the CHANNEL FUNCTIONAL TEST is only required to be performed while the plant is in a condition in which the loss of the RPS bus will not jeopardize steady state power operation (the design of the system is such that the power source must be removed from service to conduct the Surveillance). The 24 hours is intended to indicate an outage of sufficient duration to allow for scheduling and proper performance of the Surveillance.
The 184 day Frequency and the Note in the Surveillance are FERMI - UNIT 2                    B 3.3.8.2-6                         Revision 0

RPS Electric Power Monitoring B 3.3.8.2 BASES SURVEILLANCE REQUIREMENTS (continued) based on guidance provided in Generic Letter 91-09 (Ref. 23).
SR   3.3.8.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency is based on the assumption of a z 18 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
SR 3.3.8.2.3 Performance of a system functional test demonstrates that, with a required system actuation (simulated or actual) signal, the logic of the system will automatically trip open the associated power monitoring assembly. Only one signal per power monitoring assembly is required to be tested.
This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function. The system functional test of the Class 1E circuit breakers is included as part of this test to provide complete testing of the safety function. If the breakers are incapable of operating, the associated electric power monitoring assembly would be inoperable.
The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.
FERMI - UNIT 2                    B 3.3.8.2-7                        Revision 0

RPS Electric Power Monitoring B 3.3.8.2 BASES REFERENCES      1. UFSAR, Section 7.2.1.1.2.
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
2-3. NRC Generic Letter 91-09, "Modification of Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System."
FERMI - UNIT 2                  B 3.3.8.2-8                       Revision 0

ECCS - Operating B 3.5.1 BASES ACTIONS (continued) of allowed outage times (i.e., Completion Times). With one LPCI pump inoperable in both subsystems, the LPCI loop select design provides essentially equivalent core flooding capability when compared to the inoperability of both LPCI pumps in one subsystem when no additional single failure is assumed.
C.1 and C.2 If one CSS subsystem and one LPCI subsystem is inoperable, one inoperable subsystem must be restored to OPERABLE status within 72 hours. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA.
However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The Completion Time is based on a previously approved amendment (Amendment 80, dated March 9, 1992), which approved a 72 hour Completion Time for one CSS and one LPCI inoperable due to lack of EECW cooling. However, the 72 hour Completion Time now applies to any mechanism of inoperability.
Differing mechanisms for the cause of ECCS inoperabilities does not result in a basis for differing allowed outage times.
D.1 and-D-2 If the inoperable low pressure ECCS subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in whichthe-LGO does-net-app]overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours-and-to-MDE 4-within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 13) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
FERMI - UNIT 2                     B 3.5.1-7                           Revision 0

ECCS - Operating B 3.5.1 BASES ACTIONS (continued)
Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times paeis reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
E.1 and E.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days. In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Verification of RCIC OPERABILITY is therefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or other information to determine if RCIC is out of service for maintenance or other reasons. It does not mean to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System. If the OPERABILITY of the RCIC System cannot be immediately verified, however, Condition I must be immediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.
FERMI - UNIT 2                    B 3.5.1-8                           Revision 0

ECCS-Operating B 3.5.1 BASES ACTIONS (continued)
F.1 and F.2 If any one low pressure ECCS injection/spray subsystem, or one LPCI pump in both LPCI subsystems, or one CSS and one LPCI subsystem is inoperable in addition to an inoperable HPCI System, the inoperable low pressure ECCS injection/spray subsystem(s) or the HPCI System must be restored to OPERABLE status within 72 hours. In this Condition, adequate core cooling is ensured by the OPERABILITY of the ADS and the remaining low pressure ECCS subsystems. However, the overall ECCS reliability is significantly reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function. Since both a high pressure system (HPCI) and a low pressure subsystem(s) are inoperable, a more restrictive Completion Time of 72 hours is required to restore either the HPCI System or the low pressure ECCS injection/spray subsystem(s) to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.
G.1 The LCO requires five ADS valves to be OPERABLE in order to provide the ADS function. The ECCS analyses are performed with the initial condition of one ADS valve out of service (Ref.-314). Per this analysis, operation of only four ADS valves wTTl provide the required depressurization. However, overall reliability of the ADS is reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability. Therefore, operation is only allowed for a limited time. The 14 day Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.
FERMI - UNIT 2                     B 3.5.1-9                         Revision 0

ECCS - Operating B 3.5.1 BASES ACTIONS (continued)
H.1 and H.2 If any one low pressure ECCS injection/spray subsystem, or one LPCI pump in both LPCI subsystems, is inoperable in addition to one inoperable ADS valve, adequate core cooling is ensured by the OPERABILITY of HPCI and the remaining low pressure ECCS injection/spray subsystem. However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available. Since both a high pressure system (ADS) and low pressure subsystem(s) are inoperable, a more restrictive Completion Time of 72 hours is required to restore either the low pressure ECCS subsystem(s) or the ADS valve to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 12 and has been found to be acceptable through operating experience.
I.1 and-I-2 If any Required Action and associated Completion Time of Condition E, F, G, or H is not met, or if two -ormoe ADS valves are- inoperable, the plant must be brought to a cendi-t4on-MODE in which the-LC-dees-net- apply overall    lant risk is minimized. To achieve this status, the p ant must be brought to at least MODE 3 within 12 hours-and reactor-steam dome pressure reduced to    150 psig within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 Ref. 13 an because the time s ent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action 1.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the [CO not met. However there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate.
FERMI - UNIT 2                    B 3.5.1-10                          Revision 0

ECCS - Operating B 3.5.1 BASES ACTIONS (continued)
LCO 3.0.4 is not applicable to, and the Note does not reclude changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are-is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
J.1 and J.2 If two or more ADS valves are inoperable, there is a reduction in the depressurization capability. 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 hours and reactor steam dome pressure reduced to s 150 psiq within 36 hours. The allowed Completion Times isare reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenginq plant systems.
JA4 K.1 When multiple ECCS subsystems are inoperable, as stated in Condition JK, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
FERMI - UNIT 2                    B 3.5.1-11                          Revision 0

ECCS - Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. For the HPCI System, this SR also includes the steam flow path for the turbine and the flow controller position.
The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days. The Frequency of 31 days is further justified because the valves are operated under procedural control and because improper valve position would only affect a single subsystem. This Frequency has been shown to be acceptable through operating experience.
This SR is modified by a Note that allows LPCI subsystems to be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the RHR cut in permissive pressure in MODE 3, and for 4 hours after exceeding the RHR cut-in permissive pressure in MODE 3, if capable of being manually realigned (remote or local) to the LPCI mode and not otherwise inoperable. This allows operation in the RHR shutdown cooling mode during MODE 3, if necessary and sufficient time to restore the system line up to the LPCI mode of operation.
SR   3.5.1.5 Verification every 31 days that ADS primary containment pneumatic supply pressure is !75 psig ensures adequate air or nitrogen pressure for reliable ADS operation. The accumulator on each ADS valve provides pneumatic pressure for valve actuation. The design pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least five valve actuations can occur with the drywell at the long term drywell pressure of the design basis small break LOCA analysis (Ref. -1415). The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS. This minimum required pressure of 75 psig is provided by the primary pneumatic supply system. The 31 day Frequency takes into consideration administrative controls over operation of the pneumatic system and alarms for low pneumatic pressure.
FERMI - UNIT 2                    B 3.5.1-14                          Revision 0

ECCS-Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR   3.5.1.8, SR  3.5.1.9, and SR 3.5.1.10 The performance requirements of the low pressure ECCS pumps are determined through application of the 10 CFR 50, Appendix K criteria (Ref. 8). This periodic Surveillance is performed (in accordance with the ASME Code, Section XI, requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses. The low pressure ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of Reference 10. The pump flow rates (for Core Spray, 2 pumps in parallel operation) are verified against a system head equivalent to the RPV pressure expected during a LOCA. The total system pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during a LOCA. These values may be established during preoperational testing.
Actual testing is performed via the test flow path against test line pressures established in Reference-4718.
The flow tests for the HPCI System are performed at two different pressure ranges such that system capability to provide rated flow is tested at both the higher and lower operating ranges of the system. Additionally, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the HPCI System diverts steam flow. Reactor steam pressure must be > 945 psig to perform SR 3.5.1.9 and 165 psig to perform SR 3.5.1.10. Adequate steam flow is represented by main turbine generator on line or turbine bypass valves open at least 15% in auto-pressure control.
Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform these tests.
Reactor startup is allowed prior to performing the low pressure Surveillance test because the reactor pressure is low and the time allowed to satisfactorily perform the Surveillance test is short. The reactor pressure is allowed to be increased to normal operating pressure since it is assumed that the low pressure test has been satisfactorily completed and there is no indication or reason to believe that HPCI is inoperable.
FERMI - UNIT 2                     B 3.5.1-16                        Revision 50

ECCS - Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) flow are achieved to perform this SR. Adequate pressure at which this SR is to be performed is > 850 psig (the pressure recommended by the valve manufacturer). Adequate steam flow is represented by turbine bypass valves open at least 20%. Reactor startup is allowed prior to performing this SR because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours after reactor steam pressure and flow are adequate to perform the test. The 12 hours allowed for manual actuation after the required pressure and flow are reached is sufficient to achieve stable conditions and provides adequate time to complete the Surveillance.
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.
The Frequency is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
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 516. 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 16.
The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency.
FERMI - UNIT 2                     B 3.5.1-19                         Revision 0

ECCS-Operating B 3.5.1 BASES REFERENCES         1. UFSAR, Section 6.3.2.2.3.
: 2. UFSAR, Section 6.3.2.2.4.
: 3. UFSAR, Section 6.3.2.2.1.
: 4. UFSAR, Section 6.3.2.2.2.
: 5. UFSAR, Section 15.2.7.
: 6. UFSAR, Section 15.6.4.
: 7. UFSAR, Section 15.6.5.
: 8. 10 CFR 50, Appendix K.
: 9. UFSAR, Section 6.3.3.
: 10. 10 CFR 50.46.
: 11. UFSAR, Section 6.3.3.3.
: 12. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
: 13. NEDC-32988-A Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
4314. UFSAR, Table 6.3-6.
4415. UFSAR, Section 5.2.2.2.3.
4516. Technical Requirements Manual.
4617. NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994; and Fermi-2 SER for Amendment 111, dated April 18, 1997.
1718. DC-5079 Vol I, RHR & CSS Technical Specification Surveillance Pump Discharge Pressures.
FERMI - UNIT 2                   B 3.5.1-20                        Revision 50

RCIC System B 3.5.3 BASES ACTIONS (Continued)
B. 1 and-4--2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which overall plant risk is minimized.the-LGO does-not-appy. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.-+nd -reaeter 6s-team-dome    sure-reduced to   150 pse         36  hours-r-hin Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in MODE       Ref. an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times isare reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                     B 3.5.3-3a                       Revision 30

RCIC System B 3.5.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.3.5 The RCIC System is required to actuate automatically in order to verify its design function satisfactorily. This Surveillance verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of the RCIC System will cause the system to operate as designed, including actuation of the system throughout its emergency operating sequence; that is, automatic pump startup and actuation of all automatic valves to their required positions. This test also ensures that the RCIC 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 3.3.5.2 overlaps this Surveillance to provide complete testing of the assumed safety function.
The 18 month Frequency is based on the need to perform the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
REFERENCES        1. 10 CFR 50, Appendix A, GDC 33.
: 2. UFSAR, Section 5.5.6.
: 3. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
: 4. NEDC-32988-A Revision 2, Technical Justification to Support Risk Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                      B 3.5.3-6                        Revision 0

LLS Valves B 3.6.1.6 BASES ACTIONS (continued)
B.1 and-B2 If both LLS valvcs arc inoperable or if the-an inoperable LLS valve cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which_- the-LC de ne-t-appl-yoverall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours-and--      9E-4 wi-thin 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 ef. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. [CO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are-is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
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 hours and MODE 4 within 36 hours. The allowed Completion Times are reasonable,based on operating experience, to reach the FERMI - UNIT 2                     B 3.6.1.6-3                       Revision 0

LLS Valves B 3.6.1.6 BASES ACTIONS (continued) required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR 3.6.1.6.1 REQUIREMENTS A manual actuation of each LLS valve is performed to verify that the valve and solenoids are functioning properly and no blockage exists in the valve discharge line. This can be demonstrated by the response of the turbine control or bypass valve, by a change in the measured steam flow, or by any other method that is suitable to verify steam flow.
Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Adequate pressure at which this test is to be performed is
                  > 850 psig (the pressure recommended by the valve manufacturer). Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the LLS valves divert steam flow upon opening. Adequate steam flow is represented by turbine bypass valves open at least 20%. The 18 month Frequency was based on the SRV tests required by the ASME Boiler and Pressure Vessel Code, Section XI (Ref. 23). Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
Since steam pressure is required to perform the Surveillance, however, and steam may not be available during a unit outage, the Surveillance may be performed during the startup following a unit outage. Unit startup is allowed prior to performing the test because valve OPERABILITY and the setpoints for overpressure protection are verified by Reference 23 prior to valve installation. After adequate reactor steam dome pressure and flow are reached, 12 hours is allowed to prepare for and perform the test.
FERMI - UNIT 2                   B 3.6.1.6-4                         Revision 0

LLS Valves B 3.6.1.6 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.1.6.2 The LLS designated SRVs are required to actuate automatically upon receipt of specific initiation signals.
A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.3.4 overlaps this SR to provide complete testing of the safety function.
The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents a reactor pressure vessel pressure blowdown.
REFERENCES        1. UFSAR, Section 5.2.2.5.
: 2. NEDC-32988-A, Revision 2. Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 23. ASME, Boiler and Pressure Vessel Code, Section XI.
FERMI - UNIT 2                   B 3.6.1.6-5                        Revision 0

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES ACTIONS (continued)
D.1 If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition C, the remaining breakers in the remaining lines can provide the opening function. The plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in MODE 4 Ref. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of [CO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because [CO 3.0.4. requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                    B 3.6.1.7-5                        Revision 0

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES ACTIONS (continued)
DE.1 With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact.
However, in the event of a containment depressurization, the function of the vacuum breakers is lost. Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour. This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, which requires that primary containment be restored to OPERABLE status within 1 hour.
EF.1 and -EF.2 If a--the vacuum breakers in one or more lines cannot be closed or restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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   3.6.1.7.1 REQUIREMENTS Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker position or by verifying a differential pressure of 0.5 psid is maintained between the reactor building and suppression chamber. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.
Two Notes are added to this SR. The first Note allows reactor-to-suppression chamber vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers. The second Note is included to clarify that vacuum breakers open due to an FERMI - UNIT 2                     B 3.6.1.7-6                       Revision 0

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES SURVEILLANCE REQUIREMENTS   (continued) actual differential pressure are not considered as failing this SR.
SR 3.6.1.7.2 Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position. This ensures that the safety analysis assumptions are valid. The 31 day Frequency of this SR was developed based upon Inservice Testing Program requirements to perform valve testing at least once every 92 days. A 31 day Frequency was chosen to provide additional assurance that the vacuum breakers are OPERABLE.
SR 3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of
                  < 0.5 psid is valid. This verification may be performed by measurement of the equivalent force to move the pullet.        The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES        1. UFSAR, Section 6.2.
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                     B 3.6.1.7-7                          Revision 0

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.8 BASES ACTIONS (continued)
B.1 If a required suppression chamber-to-drvwell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time    the lant must be brought to a condition in which overall     ant risk is minimized. To achieve this status, the plant must be rought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the ris in ODE 4 Ref. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components.
consideration of the results. determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to. and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
B-AC. 1 An open vacuum breaker allows communication between the drywell and suppression chamber airspace, and, as a result, there is the potential for suppression chamber overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed (confirmation of the closed status would follow procedures as outlined in the Bases for SR 3.6.1.8.1). The 2 hour completion time is allowed to close the vacuum breaker due FERMI - UNIT 2                    B 3.6.1.8-4                         Revision 0

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.8 BASES ACTIONS (continued) to the low probability of an event that would pressurize primary containment.
GD.1 and_-GD.2 If the inepabe-open suppression chamber-to-drywell vacuum breaker cannot be Tosed er restoed to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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 3.6.1.8.1 REQUIREMENTS Each vacuum breaker is verified closed to ensure that this potential large bypass leakage path is not present. This Surveillance is performed by observing the vacuum breaker position indication or by verifying that a differential pressure of 0.5 psid between the suppression chamber and drywell is maintained for 1 hour without makeup. However, if vacuum breaker position indication is not reliable, either due to: 1) dual or open indication while able to establish a torus-to-drywell differential pressure, or
: 2) closed indication while not able to establish a torus-to-drywell differential pressure, alternate methods of verifying that the vacuum breaker is closed are detailed in Technical Requirements Manual (TRM).
FERMI - UNIT 2                   B 3.6.1.8-5                         Revision 0

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.8 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.1.8.3 Verification of the vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid is valid. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 18 month Frequency has also been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES        1. UFSAR, Section 6.2.
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                   B 3.6.1.8-7                        Revision 0

RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS (continued) overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
B,1 If one RHR suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 Ref. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable.
because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                    B 3.6.2.3-3                        Revision 0

RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS (continued) 8C.1 With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours. In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the RHR suppression pool cooling subsystem to operate.
GD.1 and -GD.2 If the Required Action and associated Completion Time of Condition C cannot be met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. 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 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is FERMI - UNIT 2                    B 3.6.2.3-4                        Revision 0

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 Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR 3.6.2.3.2 Verifying that each RHR pump develops a flow rate
                   > 10,000 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. 23).
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 Inservice Testing Program.
REFERENCES         1. UFSAR, Section 6.2.
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 23. ASME, Boiler and Pressure Vessel Code, Section XI.
FERMI - UNIT 2                    B 3.6.2.3-5                         Revision 0

RHR Suppression Pool Spray B 3.6.2.4 BASES ACTIONS (continued) failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation capability. The 7 day Completion Time was chosen in light of the redundant RHR suppression pool spray capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
B.1 With both RHR suppression pool spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 8 hours. In this Condition, there is a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.
C.1 and-G-2 If the inoperable RHR suppression pool spray subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which_ the-LC9-does -net-applyoverall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and-MODE w4th 36-hour-s.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 Ref. 2 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b if applicable, because LCO 3.0.4.b reguires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability FERMI - UNIT 2                    B 3.6.2.4-3                        Revision 0

RHR Suppression Pool Spray B 3.6.2.4 BASES ACTIONS (continued) that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times-aeis_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 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis. This is acceptable since the RHR suppression pool cooling mode is 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 Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR   3.6.2.4.2 Verifying each RHR pump develops a flow rate > 500 gpm while operating in the suppression pool spray mode with flow through the heat exchanger ensures that pump performance has not degraded during the cycle. Flow is a normal test of centrifugal pump performance required by Section XI of the ASME Code (Ref. 23). This test confirms one point on the pump design curve and is indicative of overall performance.
Such inservice inspections confirm component OPERABILITY, FERMI - UNIT 2                    B 3.6.2.4-4                        Revision 0

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 Inservice Testing Program.
REFERENCES        1. UFSAR, Section 6.2.
: 2. NEDC-32988-A, Revision 2. Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 23. ASME, Boiler and Pressure Vessel Code, Section XI.
FERMI - UNIT 2                   B 3.6.2.4-5                        Revision 0

Secondary Containment B 3.6.4.1 BASES APPLICABILITY (continued) of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, secondary containment is only required to be OPERABLE during fuel handling involving recently irradiated fuel. "Recently irradiated fuel" is fuel that has occupied part of a critical reactor core within the previous 6.3 days.
Handling new (non-irradiated) fuel bundles over the open reactor core or the spent fuel pool is subject to the same requirements of handling recently irradiated fuel, as long as any fuel in the core or fuel pool is recently irradiated.
ACTIONS           A.1 With a Secondary Containment railroad bay access door inoperable there remains a redundant access door in an OPERABLE status. This door is capable of maintaining the Secondary Containment function. Therefore, the 7 day Completion Time gives a reasonable period of time to correct the problem given the availability of the other access door and the low probability of an event occurring that will challenge the Secondary Containment during this time period.
B.1 If secondary containment is inoperable for reasons other than Condition A, it must be restored to OPERABLE status within 4 hours. The 4 hour Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.
C.1 and-C,2 If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which overall plant risk is minimizedteG -dee-t-appy. To achieve this status, the p ant must be brought to at least MODE 3 within 12 hours-and to-MODE - thin 36 he-s.
FERMI - UNIT 2                     B 3.6.4.1-3                      Revision 52

Secondary Containment B 3.6.4.1 BASES ACTIONS (continued)
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in MODE 4 (Ref. 3 because the time spent in ODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are-isreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                   B 3.6.4.1-3a                       Revision 8

Secondary Containment B 3.6.4.1 BASES REFERENCES      1. UFSAR, Section 15.6.5.
: 2. UFSAR, Section 15.7.4.
: 3. NEDC-32988-A. Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2               B 3.6.4.1-7                       Revision 29

SGT System B 3.6.4.3 BASES ACTIONS (continued) availability of the OPERABLE redundant SGT System and the low probability of a DBA occurring during this period.
B.1 and-8B-If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which_ the LCO des not applyoverall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4-within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the ris in ODE 4 Ref. 3 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components.
consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times ape-isreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                    B 3.6.4.3-4                        Revision 8

SGT System B 3.6.4.3 BASES ACTIONS (continued)
Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
D.1 If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactivity release control function. Therefore, actions are -required to-enter LCO 3.0.3 mmediate-y Therefore, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in MODE 4 Ref. 3 an because t e time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0,4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
FERMI - UNIT 2                    B 3.6.4.3-6                        Revision 8

SGT System B 3.6.4.3 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter tests are in accordance with Regulatory Guide 1.52 (Ref.-34). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.6.4.3.3 This SR verifies that each SGT subsystem starts and associated dampers open on receipt of an actual or simulated initiation signal. While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function. Therefore, the Frequency was found to be acceptable from a reliability standpoint.
SR 3.6.4.3.4 This SR verifies that the filter cooler bypass damper can be remote manually opened and the fan remote manually started.
This ensures that the ventilation mode of SGT System operation is available. While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was found to be acceptable from a reliability standpoint.
FERMI - UNIT 2                    B 3.6.4.3-8                       Revision 8

SGT System B 3.6.4.3 BASES REFERENCES       1. 10 CFR 50, Appendix A, GDC 41.
: 2. UFSAR, Section 6.2.3.
: 3. NEDC-32988-A. Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 34. Regulatory Guide 1.52, Rev. 2.
FERMI - UNIT 2                B 3.6.4.3-9                        Revision 8

RHRSW System B 3.7.1 BASES ACTIONS (continued)
Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
D.1 If one RHRSW subsystem is inoperable or one RHRSW pump in one or two subsystems is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 Ref. 6 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach .the required plant conditions from full power conditions in an orderly manner and without challenginq plant systems.
DE.1 With both RHRSW subsystems inoperable for reasons other than Condition B (e.g., both subsystems with inoperable flow paths, or one subsystem with an inoperable pump and one FERMI - UNIT 2                     B 3.7.1-5                        Revision 0

RHRSW System B 3.7.1 BASES ACTIONS (continued) subsystem with an inoperable flow path), the RHRSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours. The 8 hour Completion Time for restoring one RHRSW subsystem to OPERABLE status, is based on the Completion Times provided for the RHR suppression pool cooling function.
The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.8, be entered and Required Actions taken if the inoperable RHRSW subsystem results in inoperable RHR shutdown cooling. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
EF.1 and -EF.2 If the RHRSW subsystems cannot be not restored to OPERABLE status within the associated Completion Times of Condition E, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
FERMI - UNIT 2                     B 3.7.1-6                        Revision 0

RHRSW System B 3.7.1 BASES SURVEILLANCE    SR 3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual, power operated, and automatic valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for RHRSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system.
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 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
REFERENCES      1. UFSAR, Section 9.2.5.
: 2. UFSAR, Chapter 6.
: 3. UFSAR, Chapter 9.
: 4. UFSAR, Chapter 15.
: 5. UFSAR, Section 6.3.2.14.
: 6. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                   B 3.7.1-7                         Revision 0

CREF System B 3.7.3 BASES ACTIONS (Continued)
B.1 If the control room boundary is inoperable in MODE 1, 2, or 3, the CREF system cannot perform its intended function.
Actions must be taken to restore an OPERABLE control room boundary within 24 hours. During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 24-hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of compensatory measures. The 24-hour Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.
C.1 and-C-2 In MODE 1, 2, or 3, if the inoperable CREF subsystem or control room boundary cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status, the unit must e place in at least MODE 3 within 12 hours and in MODE '1within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 Ref. 5 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met, However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components.
consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk FERMI - UNIT 2                     B 3.7.3-5                        Revision 12

CREF System B 3.7.3 BASES ACTIONS (Continued) management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times-ae-jis_reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
D.1, D.2.1 and D.2.2 The Required Actions of Condition D are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.
During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if the inoperable CREF subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CREF subsystem may be placed in the recirculation mode.
This action ensures that this remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.
An alternative to Required Action D.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.
If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of FERMI - UNIT 2                      B 3.7.3-6                       Revision 29

CREF System B 3.7.3 BASES ACTIONS (Continued) a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
A Note is applied to Required Action D.2.2. This Note allows these Required Actions to not be required when the system charcoal filter train filter media cannot provide the required efficiency or is being replaced. Dose calculations have shown that the CREF system is not needed during the activities that would otherwise be suspended by these Required Actions.
E.1 If both CREF subsystems or a non-redundant component or portion of the CREF System are inoperable in MODE 1, 2, or 3 for reasons other than an inoperable control room boundary (i.e., Condition B), the CREF System may not be capable of performing the intended function and the unit is ina condition outside the-accde       nalyses. Therefoe LGO-3-.-3-mast be entered immed4aty.Therefore, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE 4 Ref. 5 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action E.1 is modified by a Note that states that LCO 3.0.4.a is not appl icable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of FERMI - UNIT 2                     B 3.7.3-7                        Revision 29

CREF System B 3.7.3 BASES ACTIONS (continued) a shutdown of the unit.
The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
F.1 and F.2 The Required Actions of Condition F are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.
During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, with two CREF subsystems or a non-redundant component or portion of the CREF System inoperable, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.
If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
A Note is applied to Required Action F.2. This Note allows these Required Actions to not be required when the system charcoal filter train filter media cannot provide the required efficiency or is being replaced. Dose calculations have shown that the CREF system is not needed during the activities that would otherwise be suspended by these Required Actions.
FERMI - UNIT 2                      B 3.7.3-8                       Revision 29

CREF System B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued) outside of the control room to prevent unfiltered inleakage.
The CREF System is designed to maintain this positive pressure with a makeup flow rate of s 1800 cfm to the control room in the recirculation mode. The Frequency of 18 months on a STAGGERED TEST BASIS is consistent with industry practice and other filtration systems SRs.
REFERENCES        1. UFSAR, Chapter 6.
: 2. UFSAR, Chapter 9.
: 3. UFSAR, Chapter 15.
: 4. Regulatory Guide 1.52, Revision 2, March 1978.
: 5. NEDC-32988-A Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                     B 3.7.3-11                       Revision 29

Control Center AC System B 3.7.4 B 3.7   PLANT SYSTEMS B 3.7.4   Control Center Air Conditioning (AC) System BASES BACKGROUND         The Control Center AC System provides temperature control for the control room during normal operation and following isolation of the control room.
The Control Center AC System consists of two independent, redundant subsystems that provide cooling and heating of recirculated control room air. Each subsystem consists of heating coils, cooling coils, fans, chillers, ductwork, dampers, and instrumentation and controls to provide for control center temperature control. Non-redundant ductwork from the Control Room Emergency Filtration System (LCO 3.7.3) is used to supply recirculated air to each subsystem and return air from each subsystem to the control room.
The Control Center AC System is designed to provide a controlled environment under both normal and accident conditions. The design conditions for the control room environment are 750 F and 60% relative humidity. The Control Center AC System operation in maintaining the control room temperature is discussed in the UFSAR, Sections 6.4 (Ref. 1) and 9.4.1 (Ref.-23).
APPLICABLE         The design basis of the Control Center AC System is to SAFETY ANALYSES    maintain the control room temperature for a 30 day continuous occupancy.
The Control Center AC System components are arranged in redundant safety related subsystems. During emergency operation, the Control Center AC System maintains a habitable environment and ensures the OPERABILITY of components in the control room. A single active failure of a component of the Control Center AC System, assuming a loss of offsite power, does not impair the ability of the system to perform its design function. Redundant detectors and controls are provided for control room temperature control.
The Control Center AC System is designed in accordance with Seismic Category I requirements. The Control Center AC System is capable of removing sensible and latent heat loads from the control center, including consideration of FERMI - UNIT 2                      B 3.7.4-1                         Revision 0

Control Center AC System B 3.7.4 BASES ACTIONS (continued) the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours is allowed to restore a Control Center AC subsystem to OPERABLE status. This Completion Time is reasonable considering that the control room temperature is being maintained within the temperature limit and the low probability of an event occurring requiring control room isolation.
C.1 and-C-In MODE 1, 2, or 3, if the inoperable control center AC subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4.within 3 heus.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in ODE        Ref. an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are-isreasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without FERMI - UNIT 2                     B 3.7.4-4                        Revision 44

Control Center AC System B 3.7.4 BASES SURVEILLANCE     SR  3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load.
The SR consists of a verification of the control room temperature. The 12 hour Frequency is appropriate since significant degradation of the Control Center AC System is not expected over this time period.
REFERENCES       1. UFSAR, Section 6.4.
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 23. UFSAR, Section 9.4.1.
FERMI - UNIT 2                   B 3.7.4-7                        Revision 44

Main Condenser Offgas B 3.7.5 BASES LCO             To ensure compliance with the assumptions of the turbine SJAE line failure event (Ref. 1), the fission product release rate should be consistent with a noble gas release to the reactor coolant of 100 pCi/MWt-second after decay of 30 minutes. The LCO is established consistent with this requirement (3430 MWt x 100 pCi/MWt-second =
340 mCi/second).
APPLICABILITY   The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System. This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation. In MODES 4 and 5, steam is not being exhausted to the main condenser and the requirements are not applicable.
ACTIONS         A.1 If the offgas radioactivity rate limit is exceeded, 72 hours are allowed to restore the gross radioactivity rate to within the limit. The 72 hour Completion Time is reasonable, based on engineering judgment, the time required to complete the Required Action, the large margins associated with permissible dose and exposure limits, and the low probability of a Main Condenser Offgas System or SJAE line rupture.
B.1, B.2, and B.3.4-- an4-3---2 If the gross radioactivity rate is not restored to within the limits in the associated Completion Time, all main steam lines or the SJAE must be isolated. This isolates the Main Condenser Offgas System from the source of the radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed, and at least one main steam line drain valve in each drain line is closed. The 12 hour Completion Time is reasonable, based on operating experience, to perform the actions from full power conditions in an orderly manner and without challenging unit systems.
FERMI - UNIT 2                   B 3.7.5-2                         Revision 0

Main Condenser Offgas B 3.7.5 BASES ACTIONS (continued)
An alternative to Required Actions B.1 and B.2 is to place the unit in a MODE in which the LC;O does not-appU! overall plant risk is minimized. To achieve this status, t e unit must be placed in at least MODE 3 within 12 hours.-and-in MODE 4 within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than t e ris in MODE 4 Ref. 3 an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action B.3 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
FERMI - UNIT 2                     B 3.7.5-3                         Revision 0

Main Condenser Offgas B 3.7.5 BASES SURVEILLANCE    SR 3.7.5.1 and SR 3.7.5.2 REQUIREMENTS This SR, on a 31 day Frequency, requires an isotopic analysis of an offgas sample to ensure that the required limits are satisfied. The noble gases to be sampled are Xe-133, Xe-135, Xe-138, Kr-85, Kr-87, and Kr-88. If the measured rate of radioactivity increases significantly (by Q 50% after correcting for expected increases due to changes in THERMAL POWER),  an isotopic analysis is also performed within 4 hours after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas, and is acceptable, based on operating experience.
SR 3.7.5.1 is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.
Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.
REFERENCES      1. UFSAR, Section 15.7.1.
: 2. 10 CFR 100.
: 3. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
FERMI - UNIT 2                   B 3.7.5-4                         Revision 0

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)
According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition F for a period that should not exceed 12 hours. In Condition F, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition E (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.
G. 1 sd-G-2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which overall plant risk is minimizedthc LCOdes not appl.      To ac ieve this status, the unit must be brought to at least MODE 3 within 12 hours         MODE Iwithin 36 hours..andto Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action G.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
FERMI - UNIT 2                      B 3.8.1-8                        Revision 51

AC Sources-Operating B 3.8.1 BASES ACTIONS (continued)
The allowed Completion Times are is reasonable, based on operating experience, to reach thferequired plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      The AC sources are designed to permit inspection and testing REQUIREMENTS      of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, GDC 18 (Ref. 89). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the EDGs are based on the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 910), and Regulatory Guide 1.137 (Ref. 411), as addressed in the UFSAR.
Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3873 V corresponds to the Division I emergency bus degraded voltage minimum limit.
FERMI - UNIT 2                     B 3.8.1-8a                      Revision 51

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)
For the purposes of SR 3.8.1.2 testing, the EDGs are started anywhere from standby to hot conditions by using one of the following signals:
                         -   Manual, Simulated loss-of-offsite power by itself,
                         -   Simulated loss-of-offsite power in conjunction with an ESF actuation test signal, or
                         -   An ESF actuation test signal by itself.
In order to reduce stress and wear on diesel engines, the EDG manufacturer recommends a modified start in which the starting speed of EDGs is limited, warmup is limited to this lower speed, and the EDGs are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2, which is only allowed to satisfy SR 3.8.1.2 but are not applicable when performing SR 3.8.1.7.
SR 3.8.1.7 requires that, at a 184 day Frequency, the EDG starts from standby conditions and achieves required voltage and frequency within 10 seconds. Standby conditions for an EDG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations. The 10 second start requirement supports the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (Ref. 4213). The 10 second start requirement is not applicable to SR 3.8.1.2.
Since SR 3.8.1.7 does require a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2. In addition to the SR requirements, the time for the EDG to reach steady state operation, unless the modified EDG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The normal 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of EDG OPERABILITY, while minimizing degradation resulting from testing.
FERMI - UNIT 2                     B 3.8.1-10                        Revision 0

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour of EDG operation at full load.
The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large uses of fuel oil during this period.
SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling.
In addition, it eliminates the potential for water entrainment in the fuel oil during EDG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 4011). This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.
SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE,  the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the FERMI - UNIT 2                     B 3.8.1-12                          Revision 0

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) controls and control systems for automatic fuel transfer systems are OPERABLE.
The design of fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tank during or following EDG testing. As such, a 31 day Frequency is appropriate, since proper operation of fuel transfer systems is an inherent part of EDG OPERABILITY.
SR 3.8.1.7 See SR 3.8.1.2.
SR   3.8.1.8 Each EDG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the EDG load response characteristics and capability to reject the largest single load while maintaining a specified margin to the overspeed trip. The largest single load for each EDG is a residual heat removal pump (1684 kW). This Surveillance may be accomplished by:
: a. Tripping the EDG output breaker with the EDG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
: b. Tripping its associated single largest post-accident load with the EDG solely supplying the bus.
As required by IEEE-308 (Ref. 1415), the load rejection test is acceptable if the increase indiesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower. This represents 66.75 Hz, equivalent to 75% of the difference between nominal speed and the overspeed trip setpoint.
FERMI - UNIT 2                      B 3.8.1-13                         Revision 0

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)
The frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 18 month Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 910).
SR 3.8.1.9 This Surveillance demonstrates the EDG   capability to reject a full load without overspeed tripping   or exceeding the predetermined voltage limits. The EDG    full load rejection may occur because of a system fault or   inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the EDG experiences following a full load rejection and verifies that the EDG does not trip upon loss of the load. These acceptance criteria provide EDG damage protection. While the EDG is not expected to experience this transient during an event, and continues to be available, this response ensures that the EDG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
The 18 month Frequency is consistent with the recommendation of Regulatory Guide 1.108 (Ref. 910) and is intended to be consistent with expected fuel cycTe lengths.
SR   3.8.1.10 As required by Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(1), this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the EDG, including automatic start of the EDG cooling water pump. It further demonstrates the capability of the EDG to automatically achieve the required voltage and frequency within the specified time.
The EDG auto-start time of 10 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA. The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate FERMI - UNIT 2                     B 3.8.1-14                         Revision 0

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) that all starting transients have decayed and stability has been achieved.
The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the EDG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, or systems are not capable of being operated at full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the EDG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(1), takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing.
SR 3.8.1.11 This Surveillance demonstrates that the EDG (including its associated cooling water pump) automatically starts and achieves the required minimum voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for z 5 minutes. The 5 minute period provides sufficient time to demonstrate stability.
The Frequency of 18 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with the expected fuel cycle lengths. Operating experience has shown that these FERMI - UNIT 2                     B 3.8.1-15                        Revision 0

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.
This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing.
SR 3.8.1.12 This Surveillance demonstrates that EDG non-critical protective functions (e.g., high jacket water temperature) are bypassed on an actual or simulated emergency start (LOCA or loss of offsite power) signal. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The EDG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the EDG.
The 18 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR 3.8.1.13 Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(3),
requires demonstration once per 18 months that the EDGs can start and run continuously at full load capability for an interval of not less than 24 hours-22 hours of which is at a load equivalent to the continuous rating of the EDG, and 2 hours of which is at a load equivalent to 110% of the continuous duty rating of the EDG. Fermi-2 has taken an exception to this requirement and performs the 22 hour run at approximately 90% of the continuous rating (2500 kW-FERMI - UNIT 2                     B 3.8.1-16                        Revision 27

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 2600 kW), and performs the 2 hour run at approximately the continuous rating (2800 kW-2900 kW). The EDG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
Although no power factor requirements are established by this SR, the EDG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is an operational limitation to ensure circulating currents are minimized. A load band is provided to avoid routine overloading of the EDG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY.
The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(3); takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This Surveillance has been modified by a Note. The Note states that momentary transients due to changing bus loads do not invalidate this test.
SR 3.8.1.14 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the minimum required voltage and frequency within 10 seconds and maintain a steady state voltage and frequency range. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. The 18 month Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910), paragraph 2.a.(5).
This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least 2 hours near full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Routine overloads may result in more frequent teardown inspections in accordance with FERMI - UNIT 2                      B 3.8.1-17                        Revision 0

AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) vendor recommendations in order to maintain EDG OPERABILITY.
Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all EDG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
SR 3.8.1.15 As required by Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and load transfer from the EDG to the offsite source can be made and that the EDG can be returned to standby status when offsite power is restored. It also ensures that the auto-start logic is reset to allow the EDG to restart and reload if a subsequent loss of offsite power occurs. The EDG is considered to be in standby status when the EDG is shutdown with the output breaker open, the load sequence timers are reset, and is able to restart and reload on a subsequent bus under voltage.
The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(6), and takes into consideration pTant conditions desired to perform the Surveillance.
SR 3.8.1.16 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the EDGs due to high motor starting currents. The 10% load sequence time interval tolerance ensures that sufficient time exists for the EDG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated. Reference 2 provides a summary of the automatic loading of ESF buses.
The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910),
paragraph 2.a.(2); takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
FERMI - UNIT 2                    B 3.8.1-18                          Revision 0

AC Sources-Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)
SR   3.8.1.17 In the event of a DBA coincident with a loss of offsite power, the EDGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
This Surveillance demonstrates EDG operation, as discussed in the Bases for SR 3.8.1.10, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the EDG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 18 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of 18 months.
This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear and tear on the EDGs during testing.
SR 3.8.1.18 This Surveillance demonstrates that the EDG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the EDGs are started simultaneously.
The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 910).
This SR is modified by a Note allowing EDG starts to be preceded by an engine prelube period. The reason for the Note is to minimize wear on the EDG during testing.
FERMI - UNIT 2                     B 3.8.1-19                        Revision 0

AC Sources-Operating B 3.8.1 BASES REFERENCES          1. 10 CFR 50, Appendix A, GDC 17.
: 2. UFSAR, Sections 8.2 and 8.3.
: 3. Regulatory Guide 1.9.
: 4. UFSAR, Chapter 6.
: 5. UFSAR, Chapter 15.
: 6. Regulatory Guide 1.93.
: 7. Generic Letter 84-15.
: 8. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 89. 10 CFR 50, Appendix A, GDC 18.
910. Regulatory Guide 1.108.
1911. Regulatory Guide 1.137.
1412. Deleted.
1213. UFSAR, Section 6.3.
1314. ASME Boiler and Pressure Vessel Code, Section XI.
4415. IEEE Standard 308.
FERMI - UNIT 2                     B 3.8.1-20                      Revision 45

DC Sources -Operating B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4  DC Sources-Operating BASES BACKGROUND       The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety related equipment. As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.
The DC electrical power system also conforms to the recommendations of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3).
The DC power sources provide both motive and control power to selected safety related equipment, as well as circuit breaker control power for the nonsafety related 480 V loads that are connected to 480 V ESF buses. Two center-tapped 260 VDC batteries are provided for Class 1E loads. They are designated 2PA for Division I and 2PB for Division II. Each 260 VDC battery is divided into two 130 VDC batteries connected in series. Each 130 VDC battery section has a battery charger connected in parallel with their respective battery. Each 260 VDC battery has a spare battery charger that can replace either of the normal 130 VDC connected chargers. Each division's two 130 VDC batteries and their chargers are the source of DC control power for that respective division, including the respective EDG. Each 260 VDC source furnishes power to DC motors necessary for shutdown conditions.
During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system.
In case of loss of normal power to the battery charger, the DC loads are automatically powered from the batteries.
The DC power distribution system is described in more detail in Bases for LCO 3.8.7, "Distribution System-Operating,"
and LCO 3.8.8, "Distribution System-Shutdown."
Each battery has adequate storage capacity to carry the required load continuously for approximately 4 hours (Ref. 1112).
FERMI - UNIT 2                    B 3.8.4-1                         Revision 0

DC Sources -Operating B 3.8.4 BASES BACKGROUND (continued)
Each DC battery subsystem is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems such as batteries, battery chargers, or distribution panels.
The batteries for DC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage limit is 105/210 V.
Each battery charger of DC electrical power subsystem has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged.
Each battery charger has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours while supplying normal steady state loads (Ref. 412).
APPLICABLE        The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES   transient analyses in the UFSAR, Chapter 6 (Ref. 4) and Chapter 15 (Ref. 5), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the EDGs, emergency auxiliaries, and control and switching during all MODES of operation. The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining sufficient DC sources OPERABLE during accident conditions in the event of:
: a. An assumed loss of all offsite AC power or all onsite AC power; and
: b. A worst case single failure.
The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
FERMI - UNIT 2                     B 3.8.4-2                         Revision 0

DC Sources -Operating B 3.8.4 BASES ACTIONS (continued) division. The 4 hour Completion Time (Required Action A.1) for restoration of an inoperable battery charger allows time to replace the inoperable charger with an OPERABLE spare battery charger, if available. The four hour limit is reasonable based on the remaining capability of the battery to carry the loads for this period. The 2 hour limit for Required Action B.1 is consistent with the allowed time for an inoperable DC Distribution System division. The 2 hour Completion Time is based on Regulatory Guide 1.93 (Ref. 6) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.
If the station service DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does net apply overall plant risk is minimized. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours-and-to-   DE-4 within 36 hours.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in ODE 4 Ref.       an because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
Required Action D.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are- isreasonable, based on FERMI - UNIT 2                     B 3.8.4-4                         Revision 0

DC Sources-Operating B 3.8.4 BASES ACTIONS (continued) operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The      mpiction Time to bing t unit to MODE 4 is covnsis tent with the time required in Regulatory Guide 1.93  (Ref. 6)T SURVEILLANCE      SR  3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations. The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 7).
FERMI - UNIT 2                    B 3.8.4-5                           Revision 0

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.8.4.4 and SR 3.8.4.5 Visual inspection and resistance measurements of inter-cell and terminal connections provides an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The anti-corrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection.
The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR, provided visible corrosion is removed during performance of this Surveillance.
The connection resistance limits procedurally established for this SR are no more than 20% above the resistance as measured during installation, and not above the ceiling value established by the manufacturer. This provides conservative measures to assure the Technical Specification limit is not exceeded.
The 18 month Frequency is based on engineering judgement, taking into consideration the desired plant conditions to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency is considered acceptable from a standpoint of maintaining reliability.
SR 3.8.4.6 Battery charger capability requirements are based on the design capacity of the chargers (Ref. 3). According to Regulatory Guide 1.32 (Ref. 89), the battery charger supply is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensures that these requirements can be satisfied.
The Frequency is acceptable, given the unit conditions required to perform the test and the other administrative FERMI - UNIT 2                     B 3.8.4-7                         Revision 0

DC Sources -Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) controls existing to ensure adequate charger performance during these 18 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
SR 3.8.4.7 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 4.
The Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 89) and Regulatory Guide 1.129 (Ref. 910), which state that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 18 months.
This SR is modified by a Note that allows the performance of a performance discharge test in lieu of a service test once per 60 months.
SR 3.8.4.8 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test.
The test is intended to determine overall battery degradation due to age and usage.
The battery performance discharge test is acceptable for satisfying SR 3.8.4.7 as noted in SR 3.8.4.7.
The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 7) and IEEE-485 (Ref. 111). These references recommend that the battery be repTaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.
The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85%
FERMI - UNIT 2                     B 3.8.4-8                          Revision 0

DC Sources -Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) of its expected life, the Surveillance Frequency is reduced to 18 months. Degradation is indicated, according to IEEE-450 (Ref. 7), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is 10% below the manufacturer's rating. The 60 month Frequency is consistent with the recommendations in IEEE-450 (Ref. 7); however, the 18 month Frequency is based on previously accepted industry practice, and the need to perform this test during an outage.
This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance.
REFERENCES         1. 10 CFR 50, Appendix A, GDC 17.
: 2. Regulatory Guide 1.6.
: 3. IEEE Standard 308, 1978.
: 4. UFSAR, Chapter 6.
: 5. UFSAR, Chapter 15.
: 6. Regulatory Guide 1.93.
: 7. IEEE Standard 450.
: 8. NEDC-32988-A Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
: 89. Regulatory Guide 1.32, February 1977.
910. Regulatory Guide 1.129, December 1974.
1911. IEEE Standard 485, 1983.
4412. UFSAR, Section 8.3.2.
FERMI - UNIT 2                      B 3.8.4-9                         Revision 0

Di stribution Systems - Operating B 3.8.7 BASES ACTIONS (continued)
The 2 hour Completion Time for DC distribution subsystems is consistent with Regulatory Guide 1.93 (Ref. 3).
The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours. This situation could lead to a total duration of 10   hours, since initial failure of the LCO, to restore the DC   distribution system. At this time, an AC division could   again become inoperable, and DC distribution could be restored OPERABLE. This could continue indefinitely.
This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."
This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition B was entered. The 16 hour Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.
C.1 and-C-.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does e-app~y overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hourseand to MODE ^swithin36 hou-s.
Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
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Distribution Systems -Operating B 3.8.7 BASES ACTIONS (continued)
Required Action C.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 3. This Note prohibits the use of LCO 3.0.4.a to enter MODE 3 during startup with the LCO not met. However, there is no restriction on the use of [CO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 3, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times ae-is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
D.1 Condition D corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When more than one AC or DC electrical power distribution subsystem is lost, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.
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Distribution Systems- Operating B 3.8.7 BASES SURVEILLANCE   SR  3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC, electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical subsystems are maintained, and the appropriate voltage is available to each required bus, MPU, DC distribution cabinet, or DC MCC. The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these distribution subsystems. The 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.
REFERENCES     1. UFSAR, Chapter 6.
: 2. UFSAR, Chapter 15.
: 3. Regulatory Guide 1.93, December 1974.
: 4. NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected Required End States for BWR Plants, December 2002.
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