NRC-02-0036, Proposed Technical Specification Change (License Amendment) - Response Time Testing

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Proposed Technical Specification Change (License Amendment) - Response Time Testing
ML021560577
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 05/23/2002
From: O'Connor W
Detroit Edison
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-02-0036
Download: ML021560577 (40)
v • d • e


Text

William T. O'Connor, Jr.

Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, Michigan 48166 Tel: 734.586.5201 Fax: 734.586.4172 Detroit Edison SA DTEEinergyCompany, 10CFR50.90 May 23, 2002 NRC-02-0036 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
2) BWR Owners' Group Licensing Topical Report NEDO-32291-A Supplement 1, "System Analyses for Elimination of Selected Response Time Testing Requirements," dated October 1999
3) NRC Letter to BWR Owners' Group, dated June 11, 1999, transmitting Review of Boiling Water Reactor Owners Group (BWROG) Licensing Topical Report NEDO-3229 1, Supplement 1 "System Analyses for Elimination of Selected Response Time Testing Requirements."
4) BWR Owners' Group Licensing Topical Report NEDO-3229 1-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," dated October 1995.
5) NRC Letter to BWR Owners' Group, dated December 28, 1994, transmitting Evaluation of Licensing Topical Report NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements."

Subject:

Proposed Technical Specification Change (License Amendment)

Response Time Testing Pursuant to 10CFR50.90, Detroit Edison hereby proposes to amend the Fermi 2 Plant Operating License NPF-43, Appendix A, Technical Specifications (TS). The

USNRC NRC-02-0036 Page 2 proposed amendment would modify TS to eliminate the response time testing requirements for the Reactor Protection System Instrumentation-reactor high steam dome pressure and reactor level-low, level 3 and for Primary Containment Isolation Instrumentation-main steam line isolation signals reactor vessel water level low low low, level 1 and main steam line high flow. Additional Response Time Testing requirements were eliminated in Amendment 111. provides a description and evaluation of the proposed TS change. provides an analysis of the issue of significant hazards consideration using the standards of 1 OCFR50.92. Enclosure 3 provides the marked up pages of the existing TS to show the proposed change and a typed version of the affected TS pages with the proposed changes incorporated. Enclosure 4 contains the response to the conditions included in the NRC staff's safety evaluation accepting NEDO-3229 1 A Supplement 1. Enclosure 5 provides a list of commitments. Enclosure 6 provides a copy of the marked up TS Bases change pages for information.

Detroit Edison has reviewed the proposed TS changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite.

Additionally, the proposed changes do not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed TS changes meet the criteria provided in 10CFR51.22(c) (9) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

Detroit Edison requests that the NRC approve and issue these changes by January 1, 2003 with an implementation period of within 60 days following NRC approval. The requested approval date is based on the plan to implement this amendment approximately one month before the upcoming ninth refueling outage.

Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.

Sincerely, Enclosures

USNRC NRC-02-0036 Page 3 cc: T. J. Kim M. A. Ring NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-02-0036 Page 4 I, WILLIAM T. O'CONNOR, JR., do hereby affirm that the foregoing statements are based on facts and circums tances which are true and accurate to the best of my knowledge and belief.

Vice President - Nuclear Gen ation On this ____ __day of tLý , 2002 before me personally appeared William T. O'Connor, Jr., being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public KAREN M.REED lotary Public, Monroe County, MI My Commission Expires 09102/2005 to NRC-02-0036 NRC-02-0036 ENCLOSURE 1 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES to NRC-02-0036 Page 2 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE(S)

I. DESCRIPTION This letter is a request to amend Operating License No. NPF-43 for Fermi 2. The proposed amendment would modify Technical Specifications (TS) to eliminate the response time testing (RTT) requirements for TS 3.3.1.1, Reactor Protection System Instrumentation- reactor vessel water level-low, level 3 and reactor vessel steam dome pressure high and for TS 3.6.1.1, Primary Containment Isolation Instrumentation-main steam line flow-high and reactor vessel water level-low low low, level 1. Approval of the proposed License Amendment is requested by January 1, 2003, with the amendment being implemented within 60 days following approval.

This timing will avert removing safety related equipment from service for surveillances associated with these instruments, before and during Refueling Outage RF09.

The Boiling Water Reactor Owners Group (BWROG) with Detroit Edison participation, has developed a Licensing Topical Report (LTR) for eliminating these surveillance requirements (reference 2). The NRC has approved this LTR (reference 3). The change proposed herein to the Fermi 2 TS is consistent with these references.

The LTR (reference 2) shows that other periodic tests required by Technical Specifications, such as channel calibrations, channel checks, channel functional tests, and logic system functional tests, provide adequate assurance that instrument response times are within acceptance limits.

The above stated position is supported by the guidance of IEEE 338-1977, endorsed by Regulatory Guide 1.118, Revision 2, which contains the following statement:

"Response time testing of all safety related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests."

The analysis contained in NEDO-32291-A, Supplement 1 (reference 2), provides the basis for eliminating selected response time testing requirements. The analysis was performed for BWRs, and its applicability to Fermi 2 has been verified with regards to the proposed Technical Specification changes. Fermi participated in the to NRC-02-0036 Page 3 development of NEDO-32291-A Supplement 1 as documented in Appendix A of the NEDO document. NEDO-32291, Supplement 1, was submitted to the NRC for review as a topical report in December, 1997. The NRC approved the Topical Report by a Safety Evaluation Report (SER) issued in June, 1999 (reference 3).

The BWROG analysis includes the identification of potential failure modes of components in the affected instrumentation loops that could potentially impact the instrument loop response time. In addition, plant operating experiences were reviewed to identify response time failures and how they were detected. The failure modes identified were evaluated to determine if the effect on response time would be detected by other testing requirements contained in the Technical Specifications.

The results of the BWROG analysis demonstrate that any credible failure of the instrument loop components would either be bounded by a bounding response time (BRT) or would be detected by other Technical Specifications testing requirements, such as channel calibration, channel check, channel functional test, and logic system functional test. These other testing requirements are sufficient to identify failure modes or degradations in instrument response times and assure operation of the analyzed instrument loops are within acceptance limits. Furthermore, the BWROG has described various defense in depth issues (reference 2) which clearly demonstrate that from a realistic basis, there is no safety significance even if instrumentation loop response times are significantly longer than the loop BRTs. Therefore, potential errors in the conclusions of the analysis and BRTs resulting from unanticipated failure modes of components do not affect the overall conclusion that elimination of the identified response time testing requirements has no substantial detrimental impact on plant safety.

In Summary, NEDO-32291-A, Supplement 1, evaluations and plant specific conditions demonstrate that response time testing can be eliminated for the selected instrument channels.

Elimination of RTT results in safety benefits. These areas include the following:

"* Minimizing the time when safety systems are out of service or otherwise incapable of responding to a degraded plant condition.

"* Reducing the potential for inadvertent safety system actuations.

"* Reducing the complexity of refuel outages.

  • Reducing personnel radiation exposure.

to NRC-02-0036 Page 4 0 Allowing critical personnel to be used for more significant tasks.

In summary, the elimination of RTT for the selected channels has low safety significance and results in an overall safety benefit II. EVALUATION OF THE PROPOSED CHANGES:

TS changes reflect elimination of response time testing for the following channels in accordance with references 2 and 4:

Reactor Protection System Instrumentation (TS 3.3.1.1)

"* reactor vessel water level-low, level 3

"* reactor vessel steam dome pressure high Primary Containment Isolation Instrumentation (TS 3.3.6.1),

Main Steam Line Isolation:

"* reactor vessel water level-low low low, level 1

"* main steam line flow-high The specific changes are as follows:

" Remove reference to Surveillance Requirement (SR) 3.3.1.1.17 from Table 3.3.1.1 -1, Functions 3 and 4. This proposed change eliminates the requirement to perform response time testing for Reactor Protection System (RPS)

Instrumentation- reactor vessel water level-low, level 3 and reactor vessel steam dome pressure high.

"* Delete note 2 from SR 3.3.1.1.17. This change removes instructions that will no longer be applicable with the implementation of the Proposed Change.

" Remove reference to Surveillance Requirement (SR) 3.3.6.1.7 from Table 3.3.6.1-1, Functions l.a and 1.c. This proposed change eliminates the requirement to perform response time testing for Primary Containment Isolation Instrumentation- reactor vessel water level-low low low, level 1 and main steam line flow-high.

to NRC-02-0036 Page 5

  • Delete SR 3.3.6.1.7. This SR will no longer be applicable with the implementation of the Proposed Change.

The TS Bases and Technical Requirements Manual will be revised to eliminate the response times, consistent with this change.

Reference 2 was approved based on the conclusion in reference 4 that there is a bounding time beyond which response time degradation can be detected during the performance of calibrations and other currently required surveillance tests. Reference 4 states that appropriate alternatives to Response Time Testing (RTT) were provided in accordance with Regulatory Guide 1. 118, Revision 2, and IEEE 338-1977. RTT is to be eliminated for selected instrument channels based on the analyses in references 2 and 4, approved by the NRC in references 3 and 5, respectively.

A. Instrument Loop Logic Components Relays of certain manufacturer and model numbers were evaluated in reference 2. A Failure Modes and Effects Analysis (FMEA) was performed for these components to show that the degree to which a component response time can degrade and still not be identified by other surveillance tests is limited. Reference 2 further defines the limit to which response time of a component can degrade without detection by other routine surveillances or calibration as the "bounding response time (BRT)" of that component. According to the analysis in reference 2, response time degradation beyond the BRT will be detected for these components by routine surveillances or calibration. RTT for these components can be eliminated when bounding response times for components in a loop plus the sensor response times are less than the response time required by the accident analysis.

The BRT for each channel is determined by the summation of the individual component responses in the trip system actuation logic. In accordance with Reference 2 Section 8.5.1, the limiting BRT for the sensors is derived from the current RTT acceptance criteria. This value plus the sum of the channel relay BRTs is compared to the current RTT Limit currently listed in the Technical Requirements Manual Tables TR 3.3.1.1 -1 (RPS Instrumentation) and TR 3.3.6.1-1 (Primary Containment Isolation Instrumentation). This analysis also discusses compliance with the provisions of references 2 and 4 for the individual components and evaluation process for design changes.

to NRC-02-0036 Page 6 B. Affected Instrument Channels Fermi 2 evaluated the site-specific loop logic components against those that are covered in reference 2. Those components applicable to the requested changes are:

Agastat EGPI GE HFA Scram Contactor The instrument loops covered by references 2 and 4 are those whose required response times, as set by the safety analysis, are in the 300 to 5000 millisecond range. The loops applicable to Fermi 2 for this TS change are:

Reference 2 Table 6-2 Loop Type Reactor Protection System reactor vessel water level-low, level 3 H reactor vessel steam dome pressure high H Primary Containment Isolation Instrumentation, Main Steam Line Isolation reactor vessel water level-low low low, level 1 E*

main steam line flow-high E**

  • - Fermi design has an additional HFA relay in this loop. Based on the information provided in the NEDO-3229 1-A Supplement 1, Table C.2-1 "Component Sets and Component BRT's" the Loop Logic BRT for this loop will increase to 284 ins. This will decrease the loop sensor BRT to 716 ms.

Fermi 2 tests the sensor to be within 400 ms which is well within the margin.

Based on the above, Fermi 2 design is bounded by the BRT as calculated above using the NEDO-32291-A Supplement 1.

    • - Fermi 2 design has an additional HFA relay in this loop. Based on the information provided in the NEDO-32291-A Supplement 1, Table C.2-1 "Component Sets and Component BRT's" the Loop Logic BRT for this loop will increase to 284 ins. This will decrease the loop sensor BRT to 216 mis.

Fermi 2 tests the sensor to be within 110 ms which is well within the margin.

Based on the above, Fermi 2 design is bounded by the BRT as calculated above using the NEDO-32291-A Supplement 1.

to NRC-02-0036 Page 7 The following tables show Fermi 2 BRT calculation using

Reference:

NEDO-32291 A Supplement 1, Table C.2-1 "Component Sets and Component BRT's".

Loop Type H reactor vessel water level-low, level 3 Sensor Trip Unit TU Output Logic Output Loop Logic Channel (TU) Relay Relay Contactor BRT BRT 429 ms 24 ms 140 ms 40 ms 45 ms 249 ms .678 sec reactor vessel steam dome pressure high Sensor Trip Unit TU Output Logic Output Loop Logic Channel (TU) Relay Relay Contactor BRT BRT 200 ms 24 ms 140 ms 40 ms 45 ms 249 ms .449 sec Loop Type E* (* Additional Auxiliary Relay) reactor vessel water level-low low low, level 1 Sensor Trip Unit TU Logic Auxiliary Output Loop Channel (TU) Output Relay Relay Relay Logic BRT Relay BRT 400 ms 24 ms 140 ms 40 ms 40 ms 40 ms 284 ms .684 sec main steam line flow-high Sensor Trip Unit TU Logic Auxiliary Output Loop Channel (TU) Output Relay Relay Relay Logic BRT Relay BRT 1Orms 24 ms 140 ms 40 ms 40 ms 40 ms 284 ms .394 sec to NRC-02-0036 Page 8 C. Available Margin A BRT has been determined for each trip channel analyzed, and is compared to the current Response Time Testing Limit from the Technical Requirement Manual Tables 3.3.1.1-1 (RPS) and 3.3.6.1-1 (Primary Containment Isolation Instrumentation). The channel BRT is the sum of the sensor and Loop Logic BRTs.

In each case the Technical Requirement Manual Limit exceeds the channel BRT:

Channel TRM Margin Channel BRT Limit (ms ec)

(sec) (sec) reactor vessel water level-low, level 3 .678 < 1.05 +372 reactor vessel steam dome pressure high .449 < 0.55 +101 reactor vessel water level-low low low, level 1 .684 < 1.0 +316 main steam line flow-high .394 < 0.50 +106 D. Defense-in-Depth References 2 and 4 demonstrate that any credible component failure among those analyzed would either be bounded by a limiting response time, or would be detected by other surveillances. The basis for elimination of this response time testing is the demonstration that the bounding response times are valid for the referenced channels.

Detectability of component failures such that component and channel response times are affected is a credible expectation of other surveillance testing. This is a defense-in-depth feature, discussed in detail in references 2, 3, 4, and 5 that provides further assurance of proper operation and reliability of the affected trip channels.

Applicable surveillance procedures contain language requiring technician cognizance and responsibility to observe and report sluggish component behavior.

to NRC-02-0036 Page 9 E. Precedents Two plants have requested similar amendments.

PPL Susquehanna, LLC, Docket No. 50-387, submitted their request on November 16, 2000 and received NRC approval March 12, 2001 (TAC Nos. MB0516 and MB10517). Susquehanna received relaxation of RTT for the same instruments listed in the Fermi 2 submittal. The sensors and types of relays for individual components differed between Fermi and Susquehanna. Susquehanna requested relaxation of sensor RTT for RPS steam dome pressure-high.

Southern Company's Edwin I. Hatch Nuclear Plant, Docket No. 50-366 submitted their request on May 21, 2001. The Hatch request differs from the Fermi 2 request in that it only requested elimination of RPS RTT for reactor vessel water level-low, level 3 and reactor vessel steam dome pressure high. This license amendment request is awaiting approval.

to NRC-02-0036 NRC-02-0036 ENCLOSURE 2 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS 10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION to NRC-02-0036 Page 2 10CFR50.92 SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards consideration. The proposed Technical Specification (TS) changes described above do not involve a significant hazards consideration for the following reasons:

The proposed change eliminates certain response time testing (RTT) surveillance requirements from the Technical Specifications in accordance with the NRC approved methodology delineated in the BWROG Licensing Topical Report (LTR)

NEDO 32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," dated October 1995, and its Supplement 1, dated October, 1999.

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

Response: No.

The proposed amendment to the Technical Specifications does not result in the alteration of the design, material, or construction standards that were applicable prior to the change. The same Reactor Protection System (RPS) and Primary Containment Isolation Instrumentation instrumentation is used, and the response time assumptions in Updated Final Safety Analysis Report (UFSAR) Chapter 15 analysis remain unchanged. Only the methodology of time response verification is changed. The proposed change will not result in the modification of any system interface that would increase the likelihood of an accident since these events are independent of the proposed change. The proposed amendment will not change, degrade, or prevent actions, or alter any assumptions previously made in evaluating the radiological consequences of an accident described in the UFSAR. Therefore, the proposed amendment does not result in 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.

This change does not alter the performance of the Reactor Protection System (RPS) or Primary Containment Isolation Instrumentation to NRC-02-0036 Page 3 systems. All RPS and Primary Containment Isolation Instrumentation channels will still have an initial response time verified by test before initially placing the channel in operational service and after any maintenance that could affect response time. Changing the method of periodically verifying instrument response for certain RPS and Primary Containment Isolation Instrumentation channels (assuring equipment operability) from time response testing to calibration and channel checks will not create any new accident initiators or scenarios. Periodic surveillance of these instruments will detect significant degradation in the channel characteristic. Implementation of the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

Implementation of NEDO 32291-A methodologies for eliminating selected response time testing does not involve a significant reduction in the margin of safety. The current response time limits are based on the maximum values assumed in the plant safety analyses. The analyses conservatively establish the margin of safety. The elimination of the selected response time testing does not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for plant safety analyses. Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore, the margin of safety is not affected. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Detroit Edison has determined that the proposed amendment presents no significant hazards consideration under the standards set forth in 10CFR50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

to NRC-02-0036 NRC-02-0036 ENCLOSURE 3 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS Attached is a mark-up of the existing TS indicating the proposed changes (Part 1) and a typed version incorporating the proposed changes (Part 2) to NRC-92-0036 NRC-02-0036 ENCLOSURE 3 PART 1 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 PROPOSED TS MARKED UP PAGES INCLUDED PAGE(S):

3.3-7 3.3-9 3.3-53 3.3-54 3.3-5 5

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.17 .................. NOTES .................

1. Neutron detectors are excluded.

Pepes time ape not required to

  • -3-For Function 5 "n" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.

Verify the RPS RESPONSE TIME is within 18 months on a limits. STAGGERED TEST BASIS SR 3.3.1.1.18 .................. NOTE ...................

Neutron detectors are excluded.

.o.... .........................-.....-......

Perform CHANNEL CALIBRATION. 24 months SR 3.3.1.1.19 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months SR 3.3.1.1.20 Verify OPRM is not bypassed when APRM 24 months Simulated Thermal Power is Ž 28% and recirculation drive flow is < 60% of rated recirculation drive flow.

FERMI -UNIT 2 3.3-7 Amendment No. OX 139

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

2. Average Power Range Monitors (continued)
c. Neutron 1 3 (c) F SR 3.3.1.1.2 < 120% RTP Flux - Upscale SR 3.3.1.1.3 SR 3.3.1.1.8 SR 3.3.1.1.12 SR 3.3.1.1.18
d. Inop 1.2 (c) G SR 3.3.1.1.12 NA 3
e. 2-out-of-4 Voter 1,2 2 G SR 3.3.1.1.2 NA SR 3.3.1.1.12 SR 3.3.1.1.17 SR 3.3.1.1.19
f. OPRM Upscale > 25% RTP (c) 3 SR 3.3.1.1.2 NA 3

SR 3.3.1.1.8 SR 3.3.1.1.12 SR 3.3.1.1.18 SR 3.3.1.1.20

3. Reactor Vessel Steam 1.2 2 G SR 3.3.1.1.1 _<1113 psig Dome Pressure-High SR 3.3.1.1.9 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15
4. Reactor Vessel Water 1,2 2 G SR 3.3.1.1.1 2 171.9 inches Level - Low, Level 3 SR 3.3.1.1.9 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15
5. Main Steam Isolation 1 8 F SR 3.3.1.1.9 12V closed Valve-Closure SR 3.3.1.1.14 SR 3.3.1.1.15 SR 3.3.1.1.17
6. Main Steam Line 1.2 2 H SR 3.3.1.1.1 _ 3.6 X full Radiation - High SR 3.3.1.1.9 pow.er SR 3.3.1.1.14 ackground SR 3.3.1.1.15
7. Drywell Pressure- High 1,2 2 G SR 3.3.1.1.1 _<1.88 psig SR 3.3.1.1.9 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15 (continued)

(c) Each APRM channel provides inputs to both trip systems.

FERMI -UNIT 2 3.3-9 Amendment No. Mik. 0 ',

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

.....-..-......--.--.. . -...NOTES - - - - - - - - - - - - - - - - -

SRs apply for each Primary

1. Refer to Table 3.3.6.1-1 to determine whiCh Containment Isolation Function.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to:

that

a. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Function 5.a when testing non-redundant circuitry results in loss of isolation capability associated with this Function, provided Functions 5.b, 5.c, and 5.e are OPERABLE:

of

b. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1. 2. 5 (other than non-redundant circuitry isolation 5.a). and 6. provided the associated Function maintains capability: and
c. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for Functions 3 and 4. provided the associated Function maintains isolation capability. . ..--

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Verify the trip unit setpoint. 92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months SR 3.3.6.1.6 Perform CHANNEL FUNCTIONAL TEST. 18 months FERMI - UNIT 2 3.3-53 Amendment No. 134

Primary Containment Isolation Instrumentation URVEILLANCE REQUIREMENTS (continued)____

SSURVEILLANCE FREQUENCY S SR 3.3.6.1.7 ------------------ NOTES ..................

1. Radiation detectors may be excluded.
2. Channel sensor response times are not required to be measured.

Verify the ISOLATION SYSTEM RESPONSE TIME 18 months on a is within limits. STAGGERED TEST j

LT 1LAIJ4 r7-f FERMI -UNIT 2 3.3-54 Amendment No. 134

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 1 of 4)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.1 REQUIREMENTS VALUE

1. Main Steam Line Isolation
a. Reactor Vessel Water 1,2,3 2 D SR 3.3.6.1.1 > 24.8 inches Level - Low Low Low. SR 3.3.6.1.2 Level 1 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
b. Main Steam Line 1 2 E SR 3.3.6.1.1 2 736 psig Pressure- Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
c. Main Steam Line Flow 1.2.3 2 per D SR 3.3.6.1.1 < 118.4 psid High MSL SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
d. Condenser Pressure 1, 2 D SR 3.3.6.1.1 < 7.05 psia High SR 3.3.6.1.2 2 (a), 3 (a) SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
e. Main Steam Tunnel 1,2,3 2 per trip D SR 3.3.6.1.1 < 206*F Temperature-High string SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
f. Main Steam Line 1.2,3 2 D SR 3.3.6.1.1 < 3.6 x full Radiation-High SR 3.3.6.1.2 power background SR 3.3.6.1.4 SR 3.3.6.1.5
g. Turbine Building Area 1,2,3 4 D SR 3.3.6.1.1 < 206*F Temperature- High SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5
h. Manual Initiation 1.2,3 1 per G SR 3.3.6.1.6 NA valve (continued)

(a) Except when bypassed during reactor shutdown or for reactor startup under administrative control.

FERMI UNIT 2 3.3-55 Amendment No. )W'4',

to NRC-02-0036 NRC-02-0036 ENCLOSURE 3 PART 2 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 PROPOSED TS MARKED UP PAGES INCLUDED PAGE(S):

3.3-7 3.3-9 3.3-53 3.3-54 3.3-55

RPS Instrumentation 3.3.1.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.1.17 ------------------NOTES ----------------

1. Neutron detectors are excluded.
2. For Function 5 "n" equals 4 channels for the purpose of determining the STAGGERED TEST BASIS Frequency.

Verify the RPS RESPONSE TIME is within 18 months on a limits. STAGGERED TEST BASIS SR 3.3.1.1.18 ------------------NOTE ------------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. 24 months SR 3.3.1.1.19 Perform LOGIC SYSTEM FUNCTIONAL TEST. 24 months SR 3.3.1.1.20 Verify OPRM is not bypassed when APRM 24 months Simulated Thermal Power is Ž 28% and recirculation drive flow is < 60% of rated recirculation drive flow.

FERMI -UNIT 2 3.3-7 Amendment No. O/X, 0$$,

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.A REQUIREMENTS VALUE

2. Average Power Range Monitors (continued)
c. Neutron 1 3 (c) F SR 3.3.1.1.2 5 120A RTP Flux - Upscale SR 3.3.1.1.3 SR 3.3.1.1.8 SR 3.3.1.1.12 SR 3.3.1.1.18
d. Inop 1.2 3 (c) G SR 3.3.1.1.12
e. 2-out-of-4 Voter 1.2 2 G SR 3.3.1.1.2 SR 3.3.1.1.12 SR 3.3.1.1.17 SR 3.3.1.1.19
f. OPRM Upscale > 25% RTP 3 (c) J SR 3.3.1.1.2 NA SR 3.3.1.1.8 SR 3.3.1.1.12 SR 3.3.1.1.18 SR 3.3.1.1.20
3. Reactor Vessel Steam 1.2 2 G SR 3.3.1.1.1 _ 1113 psig Dome Pressure-High SR 3.3.1.1.9 SR 3.3.1.1.10
4. Reactor Vessel Water 1.2 2 G SR 3.3.1.1.1 z 171.9 inches Level - Low. Level 3 SR 3.3.1.1.9 SR 3.3.1.1.10
5. Main Steam Isolation F R .12% closed 1 8 Valve-Closure SR 3.3.1.1.14 SR 3.3.1.1.15 SR 3.3.1.1.17
6. Main Steam Line 1.2 2 H SR 3.3.1.1.1 < 3.6 X full Radiation - High SR 3.3.1.1.9 power SR 3.3.1.1.14 ackground SR 3.3.1.1.15
7. Drywell Pressure-High 1.2 2 G SR 3.3.1.1.1 5 1.88 psig SR 3.3.1.1.9 SR 3.3.1.1.10 SR 3.3.1.1.14 SR 3.3.1.1.15 (continued) cc) Each APRM channel provides inputs to both trip systems.

FERMI -UNIT 2 3.3-9 Amendment No. 4 139

Primary Containment Isolation Instrumentation 3.3.6.1 SURVEILLANCE REQUIREMENTS

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

1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.
2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to:
a. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Function 5.a when testing non-redundant circuitry that results in loss of isolation capability associated with this Function, provided Functions 5.b, 5.c, and 5.e are OPERABLE;
b. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 1, 2, 5 (other than non-redundant circuitry of 5.a), and 6, provided the associated Function maintains isolation capability; and
c. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for Functions 3 and 4, provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.1.3 Verify the trip unit setpoint. 92 days SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. 18 months SR 3.3.6.1.5 Perform LOGIC SYSTEM FUNCTIONAL TEST. 18 months SR 3.3.6.1.6 Perform CHANNEL FUNCTIONAL TEST. 18 months FERMI -UNIT 2 3.3-53 Amendment No. /',

Primary Containment Isolation Instrumentation 3.3.6.1 THIS PAGE INTENTIONALLY LEFT BLANK FERMI -UNIT 2 3.3-54 Amendment No.o V9',

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 1 of 4)

Primary Containmeent Isolation Instrumentation APPLICABLE CONDITIONS REFERENCED MODES OR REQUIRED CHANNELS FROM PER TRIP REQUIRED SURVEILLANCE ALLOWABLE SPECIFIED REQUIREMENTS VALUE CONDITIONS SYSTEM ACTION C.1 FUNCTION

1. Main Steam Line Isolation 2 D SR 3.3.6.1.1 24.8 inches
a. Reactor Vessel Water 1.2.3 SR 3.3.6.1.2 Level - Low Low Low. SR 3.3.6.1.3 Level 1
b. Main Steam Line 1 2 SR3.3.6.1.2 S3.3.6.1.3 Pressure - Low YSR3.3.6.1.4 SR 3.3.6.1.5 S3.3.6.1.1 s 11874 psid 2MSL per SR 3.3.6.1.2
c. Main Steam Line 1.2.3 SR 3.3.6.1.3 Flow - High SR 3.3.6.1.1 7 psia
1. 2 SR 3.3.6.1.2
d. Condenser Pressure - High SR ,ir"11T1ý1 3.3.6.1.3 206Fý 2(a). 3 (a) SR 3.3.6.1.4 SR 3.3.6.1.5 Main Steam Tunnel 1.2.3 2trip per D SR SR 3.3.6.1.1 3.3.6.1.2 i 206"F e.

Teaperature - High string SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 3.3.6.1.1 5 3.6 x full

f. Main Steam Line 1.2.3 2 D SR SR 3.3.6.1.2 Radiation - High SR 3.3.6.1.4 ackground rower SR 3.3.6.1.5 206°F o SR 3.3.6.1.1 Turbine Building Area 1.2.3 4
g. SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.3 SR 3.3.6.1.4 SR 3.3.6.1.5 NA
h. Manual Initiation 1.2.3 vaee G SR 3.3.6.1.6 varr (continued) reactor startup under administrative control.

(a) Except when bypassed during reactor shutdown or for FERMI -UNIT 2 3.3-55 Amendment No. 134 to NRC-02-0036 NRC-02-0036 ENCLOSURE 4 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS RESPONSE TO THE CONDITIONS INCLUDED IN THE NRC STAFF'S SAFETY EVALUATION ACCEPTING NEDO-32291-A SUPPLEMENT 1 to NRC-02-0036 Page 2 RESPONSE TO THE CONDITIONS INCLUDED IN THE NRC STAFF'S SAFETY EVALUATION ACCEPTING NEDO-32291-A SUPPLEMENT 1

1. Confirm the applicability of the generic analysis of Supplement 1 to NEDO-32291-A to their plant; NEDO-32291-A Supplement 1 is applicable to Fermi 2. Fermi participated in the development of NEDO-32291-A Supplement 1 as documented in Appendix A of the NEDO document.
2. For Agastat Relays if the following requirements are met, no credible failure will increase response time to more than 140 ms without being detected by tests other than RTT:
a. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 70 ms or less after power is removed from the coil.

The calibration procedures will be revised to include a step requiring response time test to be performed, prior to return of the relay to service when repairing or replacing the relay. The normally open contacts of the relays will be confirmed to open in 70 ms or less after power is removed from the coil. The test is required "prior to return to service" rather than "prior to installation" since it is acceptable to perform response time testing on the bench or installed.

b. The relays are within their qualified life.

Relays have been verified to be within their qualified life.

c. The relays are procured by the utility as "nuclear safety related", or are dedicated for nuclear-safety-related application under a utility dedication program.

The relays are procured as "nuclear-safety-related".

3. For GE HFA Relays if the following requirements are met, no credible failure will increase response time to more than 40 ms without being detected by tests other than RTT.
a. These relays must be used as normally open energized in the untripped state, with power removed and contacts closed to trip.

to NRC-02-0036 Page 3 These relays are used as normally open energized in the untripped state, with power removed and contacts closed to trip.

b. The HFA manufacturer's instructions are followed for setup and adjustment of the relay before initial operation and after any repair or maintenance.

The manufacturer's instructions for setup and adjustment of the relay will be proceduralized in the calibration procedures. These procedure will be performed for relays before intial operation and after any repair or maintenance.

c. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 20 ms or less after power is removed from the coil.

The normally open contacts of the relays will be confirmed to open in 20 ms or less after power is removed from the coil. The calibration procedure will be revised to include this verification, before installation or after maintenance or repair of the relays.

d. The relays are procured by the utility as "nuclear safety related", or are dedicated for nuclear-safety-related application under a utility dedication program.

The relays are procured as "nuclear-safety-related".

4. For Scram Contactors if the following requirements are met, no credible failure will increase response time to more than 45 ms without being detected by tests other than RTT
a. One GE CR105, GE CR205, or GE CR305 magnetic contactor directly operates a set of Scram Pilot Solenoid Valves.

These contactors have been confirmed to directly operate a set of Scram Pilot Solenoids Valves.

A combined response is used for b and c

b. Verify that the RPS scram contactor components are tested as a part of the APRM upscale trip RTT.

to NRC-02-0036 Page 4 c Determine that one of the two postulated test methods are used.

Each Fermi 2 scram contactor and one interposing relay, not shared by other loops, are response time tested with an acceptance criteria of less than or equal to 50 ms for RPS function Average Power Range Monitor (APRM) Two-Out-Of-Four Voter. Hence, 45 ms is used as the scram contactor BRT in the analysis as identified by NEDO-3229-1, Supplement 1, Section B.7.2.2.

d. Use the appropriate BRT for the test method used.

A BRT of 45 ms is to be used.

to NRC-02-0036 NRC-02-0036 ENCLOSURE 5 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS LIST OF REGULATORY COMMITMENTS to NRC-02-0036 Page 2 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Detroit Edison in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Norman K. Peterson at extension (734) 586-4258.

These commitments apply only to the trip units and relays covered by these proposed Technical Specification changes.

1. For Agastat relays:
a. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 70 ms or less after power is removed from the coil.

The calibration procedures will be revised to include a step requiring response time test to be performed, prior to return of the relay to service when repairing or replacing the relay. The normally open contacts of the relays will be confirmed to open in 70 ms or less after power is removed from the coil. The test is required "prior to return to service" rather than "prior to installation" since it is acceptable to perform response time testing on the bench or installed.

2. For GE HFA relays:
a. The HFA manufacturer's instructions are followed for setup and adjustment of the relay before initial operation and after any repair or maintenance.

The manufacturer's instructions for setup and adjustment of the relay will be proceduralized in the calibration procedures. These procedure will be performed for relays before intial operation and after any repair or maintenance.

b. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 20 ms or less after power is removed from the coil.

The normally open contacts of the relays will be confirmed to open in 20 ms or less after power is removed from the coil, proceduralized in the calibration procedures, before installation or after maintenance or repair of the relay.

to NRC-02-0036 NRC-02-0036 ENCLOSURE 6 FERMI 2 NRC DOCKET NO. 50-341 OPERATING LICENSE NO. NPF-43 REQUEST TO RELAX RESPONSE TIME TESTING FOR REACTOR PROTECTIONS SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION TECHNICAL SPECIFICATIONS (FOR INFORMATION ONLY)

PROPOSED TS BASES MARKED UP PAGES INCLUDED PAGE(S):

B 3.3.1.1-33 B 3.3.1.1-35 B 3.3.6.1-31 B 3.3.6.1-32

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification that all components are tested. The RPS RESPONSE TIME acceptance criteria are included in Reference 10. RPS RESPONSE TIME for the APRM 2-out-of-4 Voter Function includes the output relays of the voter and the associated RPS relays and contactors. (The digital portion of the APRN and 2-out-of-4 voter channels are excluded from the RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.)

Confirmation of the time base is adequate to assure required response times are met.

As noted, neutron detectors are excluded from RPS RESPONSE TIME testing because th i virtually ens .tantaneous response Itune t.e.s.ng. Ther sensorsor these Function Teh eassumed to operate at thelogcaointdesign response time. Thios i adtoN allowance te***d by Reference512on an-nch18 determined is supported monnth" that significant degradation of the on Wtenso channel response chanespr rip Frqunc t b dtrmindase Technical forys can time be detected nteiong ie and 4e during 8 canels spcfrom of other performance inS Table r

Specification SRshno that the sensor respens f tio small part- of the overall Ri'S RESPONSE TMtE t~ig STAGGERED TEST BASIS. Not equires STAGGERED TEST BASIS Frequency to be determined ased on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function. This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal. The 18 month Frequency is consistent with the typical industry refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

FERMI- UNIT 2 B 3.3.1.1 -33 Revision 0

1 RPS Instrumentation B 3.3.1.1 BASES REFERENCES (continued)

14. NEDO-31960-A. "BWR Owners' Group Long-Term Stability Solutions Licensing Methodology," November 1995.
15. NEDO-31960-A, Supplement 1. "BWR Owners' Group Long Term Stability Solutions Licensing Methodology,"

November 1995.

16. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications," August 1996.
17. NEDC-32410P-A, Supplement 1, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," November 1997.
18. Letter, L. A. England (BWROG) to M. J. Virgilio, "BWR Owners' Group Guidelines for Stability Interim Corrective Action," June 6, 1994.
19. NRC Generic Letter 94-02, "Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal Hydraulic Instabilities in Boiling Water Reactors," July 1994.
20. BWROG Letter 96113, Kevin P. Donovan (BWROG) to L. E.

Phillips (NRC). "Guidelines for Stability Option III

'Enable Region' (TAC M92882)," dated September 17, 1996.

L9 1 . ~C

- t) ~P e- oevA 1,e Wk1~n A ~o t~Lýt E71A1A41Dý L*-7-7T

-r)AA)O Revision 4 B 3.3.1,1-35 FERMI - UNIT 22

- B 3.3.1.1-35 Revision 4

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.6.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel. The system functional testing performed on PCIVs in LCO 3.6.1.3 overlaps this Surveillance to provide complete testing of the assumed 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.

is SR ensures that the individual channel response times are less than or equal to the maximum values assumed in t acci t analysis. The instrument response times must added t the PCIV closure times to obtain the ISOLATIO SYSTEM R ONSE TIME.

ISOLATION SYS M RESPONSE TIME acceptance criter, for the instrumentation ortion are included in Refere ce 7, while the acceptance cr eria for the PCIV closur imes are included in Referen 8. This test may b erformed in one measurement, or in ov lapping segments ith verification that all components are ested.

A Note to the Surveillance s tes hat the radiation detectors may be excluded from OLATION SYSTEM RESPONSE TIME testing. This Note is n e ary because of the difficulty of generating an pprop .ate detector input signal and because the pr ciples of etector operation virtually ensure an ins ntaneous resp se time. Response times for radiation ector channels sh 1 be measured from detector output or e input of the first ectronic component in the annel.

In addition, ote 2 states the response time of tsensors are exclud from the ISOLATION SYSTEM RESPONSE TI testing. he sensors for the tested Functions are as med to ope te at the sensor's design response time. This allo nce is supported by Reference 10 which determined t t "i ificant degradation of the sensor channel response time n be detected during performance of other Technical FERMI - UNIT 2 B 3.3.6.1 -31 Revision 0

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANC SSpec-T~ ~ion SRs and that the sensor response tiqs-f L t smallpart~ rll resonse t *

/ISOLATION SYSTEM RESP TIME t r~re Aconducted on an

/ 18 mnhSAGRD ETB h 18 month Frequency is Sconsitn ihtet ia n~sr rfueling cycle and is

\ baseduonpan rtngepeine tt_shows that random "falresun occturrenes.o copoetscas-WT,,riu REFERENCES 1. UFSAR, Section 6.3.

2. UFSAR, Chapter 15.
3. NEDO-31466, "Technical Specification Screening Criteria Application and Risk Assessment,"

November 1987.

4. UFSAR, Section 4.5.2.4.
5. NEDC-31677P-A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation,"

July 1990.

6. NEDC-30851P-A Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation,' March 1989.
7. UFSAR, Section 7.3.
8. UFSAR, Section 6.2.
9. NEDO-31400, "Safety Evaluation for Eliminating the BWR MSIV Closure Function and Scram Function of the MSL Radiation Monitor," Licensing Topical Plant Report for BWROG.

/ s Selcted " *t," iuary FERMI - UNIT 2 8 3.3.6.1 -32 Revision 0

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