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Proposed Rev 5 to Improved TS Pages
	ML20206H552
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Site:	Fermi
Issue date:	04/30/1999
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ML20206H545	List: ML20206H552; NRC-99-0044, Forwards Rev 5 to ITS to Provide Responses to RAI Re ITS Section 3.6 (Except ITS Section 3.6.1.3) Contained in & Update in ITS Submittal to Reflect Responses;
References
	NUDOCS 9905110247
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Primary Containment 3.6.1.1 i i

3.6 CONTAINMENT SYSTEMS l

3.6.1.1 Primary Containment

)

j LC0 3.6.1.1 Primary containment shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3.

l l

ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME l l

A. Primary containment A.1 Restore primary 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. containment to ,

OPERABLE status. '

l 1

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I associated Completion ;

Time not met. AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months l I

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.1.1 Perform required visual examinations and In accordance g leakage rate testing except for primary with the ii containment air lock. in accordance with Primary the Primary Containment Leakage Rate Containment Testing Program. Leakage Rate Testing Program l

l (continued)

I l FERMI UNIT 2 3.6 1 Revision 5. 04/30/99 9905110247 990430 1 PDR ADOCK O p -.

Primary Containment B 3.6.1.1 BASES APPLICABLE SAFETY ANALYSES The safety design basis for the primary containment is that it must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate.

The DBA that postulates the maximum release of radioactive material within primary containment is a LOCA. In the analysis of this accident, it is assumed that primary containment is OPERABLE such that release of fission products to the environment is controlled by the rate of primary containment leakage.

Analytical methods and assumptions involving the primary containment are presented in References 1 and 2.

analyses assume a nonmechanistic fission product releaseThe safety following a DBA, which forms the basis for determination of offsite doses. The fission product release is, in turn, based on an assumed leakage rate from the primary containment. OPERABILITY of the primary containment ensures that the leakage rate assumed in the safety analyses is not exceeded.

b The maximum allowable leakage rate for the primary containment (L d

$l per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months al)the design basis LOCA maximum peakis 0.5%

containment pressure (P ) of 56.5 psig (Ref.1).

Primary containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LC0 Primary leakage containment to 5 1.0 L OPERABILITY is maintained by limiting performing a requi,. except prior to the first startup after red Primary Containment Leakage Rate Testing Program leakage test. At this time, the applicable leakage limits must be met. Compliance with this LC0 will ensure a primary containment configuration, including equipment hatches, that is structurally sound and that will limit leakage to those leakage rates assumed in the safety analyses.

Individual leakage rates specified for the primary containment air lock are addressed in LCO 3.6.1.2.

i l FERMI - UNIT 2 83.6.1.1-2 Revision 5 04/30/99

Primary Containment B 3.6.1.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Failure to meet air lock leakage testing (SR 3.6.1.2.1),

%wl secondary containment bypass leakage (SR 3.6.1.3.11).

resilient seal primary containment purge valve leakage

% testing (SR 3.6.1.3.6), main steam isolation valve leakage (SR 3.6.1.3.12), or hydrostatically tested lines valve leakage (SR 3.6.1.3.13) does not necessarily result in a failure of this SR. The impact of the failure to meet these SRs must be evaluated against the Type A. B. and C acceptance criteria of the Primary Containment Leakage Rate Testing Program. As left leakage prior to the first startup after performing a required Primary Containment Leakage Rate Testing Program leakage test is required to be s 0.6 L for b combined Type B and C leakage and s 0.75 L, for overalf 1 Type A leakage. At all other times between required leakage

{ rate tests, the acceptance criteria is based on an overall Type A leakage limit At s 1.0 L, the offsite dose consequences areofbounded s 1.0 L'y. b the assumptions of the safety analysis. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.1.2 Maintaining the pressure suppression function of primary containment requires liciting the leakage from the drywell to the suppression chambar. Thus, if an event were to occur that pressurized the drywell, the steam would be directed through the downcomers into the suppression pool. This SR measures drywell to suppression chamber differential pressure during a 10 minute period to ensure that the leakage paths that would bypass the suppression pool are within allowable limits.

Satisfactory performance of this SR can be achieved by establishing a known differential pressure between the drywell and the su)pression chamber and verifying that the pressure between t1e suppression chamber and the drywell does not change by more than 0.2 inch of water per minute over a 10 minute period. This leakage is equivalent to that through a 1 inch diameter orifice at a differential pressure of approximately 1 asid. The leakage test is performed every 18 months. T1e 18 month Frequency was developed considering it is prudent that this Surveillance be performed during a unit outage and also in view of the fact that component failures that might have affected this test l FERMI UNIT 2 B 3.6.1.1 - 4 Revision 5. 04/30/99

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 PRIMARY CONTAINMENT A.5 CTS SRs 4.6.1.1.c and 4.6.1.1.d provide direction to comply with other Specifications. ITS format does not include such " cross references." Compliance with other Specifications is required without it being stated here. The removal of these " cross references" is a presentation preference of the ITS consistent with NUREG-1433. Therefore, this change is an administrative change with no impact en safety.

TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.6.1.2 and 3.6.2.1 Actions for primary containment and drywell-to suppression chamber leakage above established limits only restrict rear. tor coolant heatup beyond 200*F (which would allow a startup_and control rod withdrawal from cold conditions, i.e.. < 200*F). Furthermore, if primary containment leakage or ,

drywell to suppression chamber above establisned limits were discovered while operating, the CTS Actions are non specific as to ,

the appropriate required actions. One interpretation would be to consider Primary Containment Integrity not met and enter the 1-hour Action of CTS 3.6.1.1. Under the same conditions. ITS LC0 3.0.4 will not allow a reactor startup to commence with containment leakage outside limits: just as CTS requires.

However, a restriction is added by ITS 3.6.1.1 Action B to require 3 a plant shutdown to Mode 4. if leakage rates are discovered outside established limits and cannot be corrected within the g

times provided in ITS Action A.

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provided in ITS Action A presents a restriction beyond CTS requirements (or consistent with the above mentioned interpretation). While ITS 3.6.1.1 is potentially more restrictive, it provides appropriate Actions, commensurate with the type of leakage failure experienced, to ensure the plant is placed in a configuration consistent with the design basis.

Therefore. this change will result in an improvement in plant safety and has no negative impact on safety. ,

FERMI UNIT 2 2 REVISION 5 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.1 PRIMARY CONTAINMENT H.2 CTS 3.6.1.5, Action, allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore structural integrity to within limits. ITS 3.6.1.1 presents the primary containment structural integrity requirements in the Primary Containment LCO, which provides an allowed Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when structural conditions are not in compliance with requirements. This conservatively brings the allowed times for restoration for a loss of containment structural integrity into agreement with a loss of containment Operability. Furthermore, the potential confusion in applying the appropriate restoration time is eliminated. This is a more restrictive change with no negative impact on safety.

TECHNICAL CHANGES LESS RESTRICTIVE

" Generic" LA.1 CTS 4.6.2.1.e requires a visual inspection of the suppression chamber every 18 months. Visual examinations are a 10 CFR 50.

Appendix J. requirement prior to Type A leak rate testing (and as such, are required by ITS SR 3.6.1.1.1). This adequately prescribes the frequency for these visual examinations without the need for a Technical Specification requirement for more frequent examinations. Therefore, this more frequent inspection is relocated from Technical Specifications to the Technical Requirements Manual. These details car be adequately defined and controlled by the provisions of 10 CFR 50.59. This detail is not required to be in the ITS to provide adequate protection of the public health and safety acceptable because it does not impact the requirement to maintain the primary containment Operable.

LA.2 CTS 3.6.2.1.b details the requirement for drywell bypass leakage testing by stating the acceptance criteria as "the equivalent leakage through a 1. inch diameter orifice." ITS SR 3.6.1.1.2 provides the detailed acceptance criteria that this corresponds to. The " equivalency" is relocated to the Bases. These details can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bases Control Program. These details are not required to be in the ITS to provide adequate protection of the public health and safety acceptable because these details do not impact the requirement to maintain the bypass leakage within limit.

FERMI UNIT 2 3 REVISION 5.

04/30/99lh

Primary Centainment 3.6.1.1 SURVEILLANCE REQUIREMENTS (crf) '

l RAi 'l l SURVEILLANCE FREQUENCY l

SR 3.6.1.1.1 Perform required v'sual examinations and J--- OTE-- T leakage rate tasting except for primary S .0.2 not containment a'ar lock testing, in plicab

_accordance wi.thflo (;F 50, Appendt d, T k .

fJ g,f , g,y' <

ea py app ed exemptio . I Q,4g,4 (

fasmoa In accordance '

Th sakage ra acceptance er terion is with 1 FR 5 ,

1.0 L H ever, during t first unit I pe tx J s startup*.fo owing testing rformed in fied accordan with 10 CFR 5 Appendix J, ! , prove modifi by approved ex tions, the 'ereen ons leak e rate acceptan criteria ar

<0 L for the T

< 0,.75 L, for and Type C ests Type A tes

+ktfriw/1 LcAkay Role T<s6ng Mi{tM f<09 m o.~2.

SR 3.6.1.1.2 Verify drywell to suppression chamber differential ressure does not decrease (18monthsg (%2l.h I at a rate > inch water gauge per 8lfD minute tested over a g ol minute period at an initial differdntfal pressure of -----NOTE -

(1)psid. Only required after two consecutive tests fail and continues until two consecutive tests pass Q monthsg 4WR/LSIL- 3.6-2 RE N T-0+f07f95-kY

Primary Containment B 3.6.1.1 j- BASES

. ,0pties p, l

BACKGROUND conformance with 10 CFR 50, Appendix J Re . , as modified j (continued) by approved exemptions.

APPLICABLE The safety design basis for the primary containment is that SAFETY ANALYSES it must withstand the pressures and temperatures of the '

limiting DBA without exceeding the design leakage rate.

The DBA that postulates the maximum release of radioactive material within primary containment is a LOCA. In the analysis of this accident, it is assumed that primary :

containment is OPERABLE such that release of fission products to the environment is controlled by the rate of l primary containment leakage.

Analytical methods and assumptions involving the primary containment are presenteo in References 1 and 2. The safety analyses assume a nonsechanistic fission product release following a DBA, which forms the basis for detemination of ,

offsite doses. The fission product release is, in turn, i based on an assumed leakage rate from the primary l containment. OPERABILITY of the primary containment ensures !

that the leakage rate assumed in the safety analyses is not !

- C'd'd

hsignbash o,y l i LM The maximum allowable oakage rate for the primary RAl-5' l

% by weight of the containment air containment U. i per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months al)Lis theYmaximum peak containment pressure (P ) i g

Sf, ofd4h4-}-

as. n kan , psig,er [0.!'.].% by Wi;ht ef th e^= tat, z-t S._

.+ +_k._ 2._____2_ .,..._.._...s. e. , i r _o_n . e , ._.u.,, i u _ ,

Primary containment satisfies Criterion 3 of 'h: M"C a:1 icy (O(.?

Otet;;.;c.t. -

QC WR60.3(o L Primary containment OPERABILITY is maintained by limiting l re cad leakage to s 1.0 L., except prior to the first startup after !

L

Ma l^ *f't erforming a requirea WCF*. 50, 'aaaadix J, leakage test. !

l.ee kog (Ra f t At this time, th e--^1--d Typ 9 !ad C 'eth;-^"-"St be- .

g,j8 0 4 L , 2-d +ha a = =11 Type 8 '"--- -"L. I Complia,nce with this LCO will ensure a primary containmen,t l

'q O' 'A

configuration, including equipment hatches, that is s cyp % bti te keye Sit, Q l be m tP. - -

(continued)

B'JR/4 ST 8 3.6-2 Ru 1, Ot/07/05 l

r REV T l

Pr10ary Containment B 3.6.1.1 g i f h dM SM b' cal k64ed I

,, BASES (continued) Ob{" ,

Imts VMyt leaIqc(u, 36.1113) % l i

SURVEILLANCE SR 3.6.1.1.1 IN f,Q REQUIREMENTS

' O 3

b'I*I~ b Maintaining the' primary containment OPERABLE requires "

compliance with the visual examinations and leakage rate test requirements of In ern u , 377 3g!- y (n-5. 3), g i a,r1 ::dif t:d by ;;r:;;d :rgt!:::. . Failure to meet air loc n

'44 'n m t'i leakage testing (SR 3.6.1.2.1), isecondary containment 13 0 g.L

, 4co kaOe, fafe bypass leakage (SR 3.6.1.3 ~ .MresilienT. semi primar 6 containment purge valve lea testing (SR 3.6.1.3 ,

M m.y=- Frgra* .@ main steam isolation valve leakage (SR 3.6.1.3.38)raocs not necessarily result in a failure of this SR. The impact of the failure to meet these SRs must be evaluated ag t the Type A, B, and C acceptance criteria of 10 CFP. L 1"t

.;;-div -J. es -^dified by 1;;re :d e r ; tica: (R:f. :).

left leakage prior to the first startup after performing a reautre M 0 CF" 50,.";;: dfr 3.-leakage test is r red to be)(BO.6 L for combined Type B and C leakage, anc .75 L, b fcVoverali Type A leakage. At all other times b en i required leakage rate tests, the acceptance criteria is E based on an overall Type A leakage limit of $ 1.0 L At E

$ 1.0 L the offsite dose consequences are bounded $y. the assumptions of the safety analysis. The Frequency is required byj 0 CFR 50, ^4 R., dix ; e i. ;), n wiiiwu i,y

.;gsJ:d 1.ations. 'hus, 59. 3.0.' 'd!:S til e: 4:;u:::y 3/

ev+=e!!ea!) da=! -et apply. t 4 (eg,,,jQg,,q f,a p g i 2are Tesfr4 nogram SR 3.6.1.1.2 --

Maintaining the pressure suppression fusiction of primary containment requires limiting the leakage from the drywell to the suppression chamber. Thus, if an event were to occur

.that pressurized the drywell, the steam would be directed through the downcomers into the suppression pool. This SR measures drywell tp suppression chamber differential pressureduringa3107minuteperiodtoensurethatthe leakage paths that would bypass the suppression pool are within allowable limits.

Satisfactory perfomance of this SR can be achieved by establishing a known differential pressure between the -

drywell and the suppression chamber and verifyin the h. d (g-h ee rt 7pressureJ&oHhar the suppression chamber @ e drywe does not change by more than [0.2 m inch of water per minute over a 10 minute period The lea e test is perfonned

=- 8 monthsi. e418 month $ requency was developed 7 '

TA ,', lea k S e o ep *AleM += n . O' N mp lid c(/amefer orific t p,2 (continued) af a NFHre , tic, I rire ss u r e &

cypo rrima telf .] h s id.

BWR/4-STS- B 3.6-4 Rs 1, O'/0495-REV T

i Pri:ary Centainment B 3.6.1.1 ,

i l

BASES l

SURVEILLANCE SR 3.6.1.1.2 (continued)

REQUIREMENTS considering it is prudent that this Surveillance be performed during a unit outage and also in view of the fact that component failures that might have affected this test are identified by other primary containment SRs. Two consecutive test failures, however, would indicate J

f. 5' unexpected +r mers ;;;t :::t degradation; in this event, 1 as the Note indicates, increasing the Frequency to once g every49 monthspis required until the situation is remedied W as evidanced by passing two consecutive tests.

4 REFERENCES 1. MFSAR, Sectionj6.2$. j

2. ItFSAR, Section [-154,39) /f. 8.5~,

3. 10 CFR 50, Appendix y Dp g 6, 1

l l

C ;/4 STS- B 3.6-5 RevJ ; ^1/^USS l

i l

l l

1 L .

l JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.6.1.1 PRIMARY CONTAINMENT l

NON BRACKETED PLANT SPECIFIC CHANGES P.1 Not used.

P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses.

P.3 Not used.

P.4 The ITS details of leakage rate tests are relocated to the Primary Containment Leak Rate Testing Program, which is being added to Section 5, Administrative Controls. This presentation is generally consistent with CTS presentation (which already includes an Administrative Controls Program for primary containment leak rate testing). Additionally. this change is in accordance with (unapproved) Generic Change TSTF 52, application of 10 CFR 50.

Appendix J. Option B.

P.5 The suppression pool bypass test tests a boundary" that is internal to the primary containment - literally not a part of the primary containment boundary. This change therefore, represents an editorial correction.

P.6 ISTS SR 3.6.1.1.1 Bases provides clarification that certain leakage tests (secondary containment bypass, purge valve, and MSIV) do not impact the SR 3.6.1.1.1 requirement for 10 CFR 50, Appendix J. Option B, leakage testing. An additional leakage test 5 is included in this Bases list - hydrostatically tested lines. J.

This provides necessary clarification and completeness, listing (

all additional leakage tests required by ITS Specification 3.6.1.3 that are not intended to be covered by ITS SR 3.6.1.1.1.

P.7 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technic'al Specification

" split" criteria found in 10 CFR 50.36(c)(2)(ii).

FERMI UNIT 2 1 REVISION 5, 04/30/99l

Prizary Containment Air Lock 3.6.1.2 3.6 CONTAINHENT SYSTEMS l 3.6.1.2 Primary Containment Air Lock l LC0 3.6.1.2 The primary containment air lock shall be OPERABLE. l APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

y l 1. Entry and exit is permissible to perform repairs of the air lock

- components.

@ Enter applicable Conditions and Required Actions of LC0 3.6.1.1. " Primary 2.

Containment," when air lock leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. One primary -

NOTES - - ----

. containment air lock 1. Required Actions A.1, door inoperable. A.2 and A.3 are not applicable if both doors in the air lock are inoperable and Condition C is entered.

2. Entry and exit is permissible for 7 days under administrative controls.

A.1 Verify the OPERABLE 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months door is closed.

AN_Q (continued) l FERMI UNIT 2 3.6-3 Revision 5. 04/30/99

Primary Containment Air Lock 3.6.1.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 12. hours associated Completion Time not met. AND D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY h SR 3.6.1.2.1 --- --

-- - NOTES -- - - -

g 1. An ino erable air lock door does not i invali ate the previous successful

- performance of the overall air lock leakage test.

Q

( 2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air In accordance lock leakage rate testing in accordance with the with the Primary Containment Leakage Rate Primary

Testing Program. Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary 24 months containment air lock can be opened at a time.

l FERMI - UNIT 2 3.6-6 Revision 5, 04/30/99

i Primary Containment Air Lock B 3.6.1.2 ;

l BASES APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 :

and 5, the probability and consequences of these events are j reduced due to the pressure and temperature limitations of i these MODES. Therefore, the primary containment air lock is not required to be OPERABLE in MODES 4 and 5 to prevent leakage of radioactive material from primary containment. j i

ACTIONS The ACTIONS are modified by Note 1, which allows entry and exit to perform repairs of the affected air lock component.

If the outer door is inoperable, then it may be easily l accessed to repair. If the inner door is the one that is ;

inoperable, however, then a short time exists when the l containment boundary is not intact (during access through t the outer door). The ability to open the OPERABLE door, l even if it means the primary containment boundary is j tem)orarily not intact, is acceptable due to the low '

pro) ability of an event that could pressurize the primary containment during the short time in which the OPERABLE door

b. is expected to be open. The OPERABLE door must be Ql immediately closed after each entry and exit.

The ACTIONS are modified by a second Note. which ensures l appropriate remedial measures are taken when necessary.

Pursuant to LC0 3.0.6, actions are not required, even if primary containment is exceeding its leakage limit.

Therefore, the Note is added to require ACTIONS for LC0 3.6.1.1, " Primary Containment," to be taken in this event.

A.1. A.2. and A.3 With one primary containment air lock door inoperable, the OPERABLE door must be verified closed (Required Action A.1) in the air lock. This ensures that a leak tight primary containment barrier is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Com31etion Time is consistent with the ACTIONS of LC0 3.6.1.1, w11ch requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

l l FERMI - UNIT 2 B 3.6.1.2 - 3 Revision 5, 04/30/99

Primary Containment Air Lock B 3.6.1.2 ;

BASES ACTIONS (continued)

In addition, the air lock penetration must be isolated by locking closed the OPERABLE air lock door within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is considered reasonable for locking the OPERABLE air lock door, considering that the OPERABLE door is being maintained closed.

Required Action A.3 ensures that the air lock with an inoperable door has been isolated by the use of a locked closed OPERABLE air lock door. This ensures that an acceptable primary containment leakage boundary is maintained. The Completion Time of once per 31 days is based on engineering judgment and is considered adequate in view of the low likelihood of a locked door being mispositioned and other administrative controls. Required Action A.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and allows these doors to be verified locked closed by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small.

The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and _ associated Completion Times of Condition C are required if both doors in the air lock are inoperable. With both doors in the air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception of Note 1 does not affect tracking the Completion Time from the initial entry into Condition A: only the requirement to comply with the Required Actions. Note 2 allows use of the air lock for entry and exit for 7 days under administrative controls.

Primary containment entry may be required to perform Technical Specifications (TS) Surveillances and Required Actions, as well as other activities on equipment inside primary containment that are required by TS, activities on equipment that support TS required equipment. This Note is

> not intended to preclude performing other activities (i.e.,

1 non TS related activities) if the primary containment was g entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize l FERMI UNIT 2 B 3.6.1.2 - 4 Revision 5 04/30/99

l Primary Containment Air Lock l B 3.6.1.2 BASES ACTIONS (continued) the primary containment during the short time that the OPERABLE door is expected to be open.

B.1. B.2. and B.3 With an air lock interlock mechanism inoperable, the Required Actions and associated Completion Times are I consistent with those specified ir. Condition A.

l The Required Actions have been modified by two Notes.

Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the air lock are inoperable. With both doors in the air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from the primary containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the function of the interlock). The dedicated individual must ensure the OPERABLE door is locked prior to leaving the air lock.

Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and that allows these doors to be verified locked closed by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the arobability of misalignment of the door, once it has )een verified to be in the proper position, is small.

C.1. C.2. and C.]

If the air lock is inoperable for reasons other than those described in Condition A or B. Recuired Action C.1 requires action to be immediately initiatec to evaluate containment overall leakage rates using current air lock leakage test results. An evaluation is acceptable since it is overly conservative to immediately declare the 3rimary containment inoperable if both doors in an air lock lave failed a seal test or if the overall air lock leakage is not within UNIT 2 B 3.'6.1.2 - 5 Revision 5 04/30/99 f l - FERMI

Primary Containment Air Lock B 3.6.1.2 BASES SURVEILLANCE REQUIREMENTS (continued) l primary containment leakage rate. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

nl The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous d successful performance of the overall air lock leakage test.

g This is considered reasonable since either air lock door is capable of )roviding a fission product barrier in the event (b

of a DBA. hte 2 has been added to this SR. requiring the results to be evaluated against the acceptance criteria which is applicable to SR 3.6.1.1.1. This ensures that air lock leakage is properly accounted for in determining the

. combined Type B and C primary containment leakage rate. l SR 3.6.1.2.2 The' air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident primary containment pressure, closure of either door will su) port primary containment OPERABILITY. Thus, the interloc(

feature supports primary containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that' simultaneous inner and outer door opening will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when primary containment is used for entry and exit (procedures require strict adherence to >

single door opening) this test is only required to be performed every 24 months. The 24 month Frequency is based on the desire to perform this SR under the conditions that apply during a plant outage, and the potential for loss of

( i primary containment OPERABILITY if the Surveillance were performed with the reactor at power. The 24 month Frequency is justified based on generic operating experience. The 24 month Frecuency is based on engineering judgment and is considerec adequate given that the interlock is not normally j challenged during use of the air lock. l l

l i

I l FERMI UNIT 2 B 3.6.1.2 - 7 Revision 5 04/30/99 j i

i I

IL i

)

Prinary Containment Air Lock B 3.6.1.2 BASES REFERENCES 1. -UFSAR, Section 3.8.2.1.3.4.

! 2. 10 CFR 50. Appendix J. Option B.

3. UFSAR, Section 6.2.

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l FERMI UNIT 2 83.6.1.2-8 Revision 5. 04/30/99

SrEC I F=tc ATro Al 3 . 6 o f. 7-.

(/fis o s e e.fS ec tYr'c a flaa, C,5)

CONTAINHENT SYSTEMS T f SURVEILLANCE RE0VIREMENTS hg,,p A n o sg .a.s. I. s ot itt oT-eS I 41.% - / ;

543.I,l Al 4d+3- Eac(h primary containment air lock shall 6e demonstrated zAw Peak ces tm1 Leak OPERABLE:

par, kt Po-

a. Within 7 days following each closing, except when the air lock is ;

being used for multiple entries, then at least once per 30 days, by verifying seal leakage rate less than or equal to 5 scf per i A hour when the gap between the door seals is pressurized to Pa . !

56.5 psig. .

Prior to establishing PRIMARY CONTAINMENT INTEGRITY when the air l' b.

lock has been opened during periods when containment integrity was not required. The demonstration shall verify a seal leakage rate !

less than or equal to 5 scf per hour when the gap between the door seals is pressurized to P , 56.5 psig, unless the air lock is fee tested pursuant to Specif$ cation 4.6.1.3.c.2. j SgecMicefiori c. By conducting an overall air lock leakage test at Pa, 56.5 psig, gp and by verifying that the overall air lock leakage rate is within its limit:

1. Prior to initial fuel loading and at 30 months

intervals j thereafter,

2. Prior to establishing PRIMARY CONTAINMENT INTEGRITY when the air lock has been opened during periods when containment ;

integrity was not required, if maintenance which could affect the leak tight integrity of the doors has been performed since the last successful test ursuant to Specification 4.6.1.3 _ ,

j

d. At least once per by verifying that only one door in each j SR 3,5 'l' 2 ' 1 air lock can be opened at a time.** {

I L,

'3 e e f g,,7 f e,t [,y *The provisions of Specification 4.0.2 are not applicable.

'I that inner do need not opened to ver y interlock ERABILI* wher) the mary cont nment is inert , provided- t the i door i riock is t ed withi hours after t primary co ainme been einerted.

l 3/4 6-9 Amendment No.108 FERMI - UNIT 2 Corrected Aucust 19. 19 %

PAGE d 0F 02 Rev r

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.2 - PRIMARY CONTAINMENT AIRLOCK f

l ADMINISTRATIVE 1 l l

A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS). certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications' l

NUREG 1433. Rev. 1.

A.2 CTS 3.6.1.3 footnote "*" to the Applicability references CTS Special Test Exception 3.10.1. ITS 3.0.7 adequately prescribes the use of the Special Operations LCOs and eliminates the need for this " cross reference." Elimination of this reference is an administrative change with no impact on safety.

A.3 ITS 3.6.1.2. Actions Note 2 and Required Action C.1. and ITS SR 3.6.1.2.1. Notes 1 and 2. are added. This additional information lg facilitates the use and understanding of the intent of the k$.

i requirements. The additional information is outlined as follows: I

. Actions Note 2 considers the primary containment inoperable in the event air lock leakage results total in-leakage exceeding the Appendix J acceptance criteria for overall containment leakage.

Required Action C.1 ensures that the primary containment overall leakage is evaluated against the Appendix J acceptance criteria if an air lock is inoperable. d

. 1 SR 3.6.1.2.1. Note 1. provides that an inoperable does not invalidate the previous successful performance of the air lock do overall air lock leakage test. Since the inoperability affects i only one door, the barrel and the other Operable door provide a sufficient containment barrier. Even though the overall test ;

could not be satisfied (SR 3.0.1 would normally require ;

declaring the LC0 not met possibly requiring ITS 3.6.1.2 !

Condition C (CTS Action b) to be entered). the Note clarifies !

the intent that the previous test not be considered "not met." g Note 2 includes clarification that the results are to be a evaluated against the overall and combined Type B and C limits of SR 3.6.1.1.1. {

These clarifications are consistent with the CTS intent and

( interpretation. and are therefore administrative changes.

FERMI UNIT 2 1 REVISION 5. 04/30/99l l

1 I

Primary Centainment Air Lcck l 3.6.1.2 l l

3.6 CONTAINMENT SYSTEMS 3.6.1.2 Primary Containment Air Lock LCO 3.6.1.2 The primary containment air lock shall be OPERABLE. 3.G.I.3 APPLICA8ILITY: MODES 1, 2, and 3.

l ACTIONS

- - - - - - - - - - - - - - - - - - - - NOTES------------------ - l 1

1. Entry and exit is pemissible to perform repairs of the air lock-----(-Doc. L.l)

P, components. g g., g

2. Enter applicable Conditions and Required Actions of LCO 3.6.1.1. " Primary Containment," when air lock leakage results in exceeding overall (pg g, !

containment leakage rate acceptance criteria. i CONDITION REQUIRED ACTION COMPLETION TIME A. Ore primary -

---NOT ES----- - f3.G l.3 Aenm et) ,

containment air lock 1. Required Actions A.1, door inoperable. A.2, and A.3 are not /pg g-applicable if both doors N in the air lo'ck are inoperable and 3 Condition C is entered. ;

2. Entry and exit is permissible for 7 days (Doc L,q} ,

under administrative !

controls. l A.1 Verify the OPERABLE 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (3.C.,1,3 Ocum o.1 door is closed, i

i (continued)

I l

t WRf+-STS- 3.6-3 Re N i

k6V h :

4 Pricary Centainment Air Lock 3.6.1.2 l SURVEILLANCE REQUIREMENTS fCIb) 1 I

SURVEILLANCE FREQUENCY ,

SR 3.6.1.2. ---------------NOT - - - - - -

()g A,3 An inoperable air lock door does not ll oc g, geg43 shbe, invalidate the previous successful performance of-the overall air lock g yduad 8$";"'.p y leakage test.

gww n&n,ae .. _ _ - - .___ ..

l N g g,4,g,t wws ,g Perfons required primary containment air ---

> g> i f,U 5 lock leakare rate testina in accordance ' , '.NOT 3 0. is no with)fD CFF,/50, Appendix J as modified ppli le

~

1 by appro exemptions. -- -

t j The ceptance crit a for air loc In accordance te ing are: with IG FR 5^ l I d J, l

. Overall ai lock leakage r e is di ed A

$ [0.05 ,] when tested 2 P, . app ve

<ex ti r.s ch door, leaka rate is

b. For r06D**" b^g!"gl s .01 L when t gap betwee the oor seal ]is pr surized to eok,agt A

[2 10 psig for t least 15 T*En3 utes].) pmpe ks SR 3.6.1.2.2 (-------- --------nus --- -- ' ' 'b ' ' 'd Only u ired to be erformed upo entry int primary cont neent air 1 when primary con inment is d norted.

g.-----.... . --..

Verify only one door in the primary 1EW- ,

containment air lock can be opened at a [Ay mon 4hs]

time. l

-GWR/4 STS- 3.6-7 Rev -1, Ot/07/92

{6\l

Prizary Containment Air Lock !

B 3.6.1.2 i

BASES f LCO OPERABLE. Closure of a single door in air lock is (continued) sufficient to provide a leak tight barrier following r postulated events. Nevertheless, both doors are kept closed '

when the air lock is not being used for normal entry exit from primary containment. o l

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of j these MODES. Therefore, the primary containment air lock is j not required to be OPERABLE in MODES 4 and 5 to prevent leakage of radioactive material from primary containment.

l ACTIONS The ACTIONS are modified by Note 1, which allows entry and !

exit to perform repairs of the affected air lock component. 1 If the outer door is inoperable, then it may be easily accessed to repair. If the inner door is the one that is inoperable, however, then a short time exists when the containment boundary is not intact (during access through oqd the outer door). The ability to open the OPERABLE door, F even if it means the primary containment boundary is !

temporarily not intact, is acceptable due to the low probability of an event that could pressurize the primary containment during the short time in which the OPERABLE door i is expected to be open. The OPERABLE door must be i immediately closed after each entry and exit. l 1

.The ACTIONS are modified by a second Note, which ensures !

appropriate remedial measures are taken when necessary. !

Pursuant to LCO 3.0.6, actions are not required, even if i primary containment is exceeding its leakage limit.

Therefore, the Note is added to require ACTIONS for LCO 3.6.1.1, " Primary Containment," to be taken in this event. !

1 I

A.1. A.2. and A.3 l With one primary containment air lock door inoperable, the OPERABLE door must be verified closed (Required Action A.1) in the air lock. This ensures that a leak tight primary (continued)

" /' STS- B 3.6-8 Rev 1, O'/07/05 j

i

Pri::ary Containment Air Lock l B 3.6.1.2 l BASES l ACTIONS A.1. A.2. and A.3 (continued) j Actions, as well as other activities on equipment inside Apk i primary containment that are required by TS or activities on 1" equipment that support TS-required equipment. This Note is not intended to preclude performing other activities (i.e., 4 non-TS-related activities) if the primary containment was '

entered, using the inoperable air lock, to perform an l allowed activity listed above. This allowance is acceptable '

due to the low probability of an event that could pressurize the primary containment during the short time that the l OPERABLE door is expected to be open.

B.1. B.2. and B.3 With an air lock interlock mechanism inoperable, the Required Actions and associated Completion Times are consistent with those specified in Condition A.

l The Required Actions have bee. :,dified by two Notes.

Note 1 ensures that only the A quired Actions and associated Completion Times of Condition C are required if both doors l in the air lock are inoperable. With both doors in the air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. Note 2 allows entry into and exit from the primary containment under the control'of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e., the individual performs the functionoftheinterlock).g

) Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and that allows these doors to be verified locked closed by use of administrative controls. Allowing verification by administrative controls L cledicofed is considered acceptable, since access to these areas is

,rd/ idu ./ ,St oj t I typically restricted. Therefore, the probability of e ruu re f A e, j misalignment of the door, once it has been verified to be in ppm gg 4 j, the proper position, is small.

, locked pro % to ,

i lCavoQ lhe air 1 Io c. It .

(continued) 41WR/4-STS B 3.6-10 R n 1, 04/07/95 KEV

rrinary cun6.u m.. ni. m B 3.6.1.2 BASES ACTIONS C.1. C.2. and C.3 (continued)

If the air lock is inoperable for reasons other than those described in Condition A or B, Required Action C.1 requires action to be immediately initiated to evaluate containment overall leakage rates using current air lock leakage test results. An evaluation is acceptable since it is overly conservative to immediately declare the primary containment inoperable if both doors in an air lock have failed a seal test or if the overall air lock leakage is not within limits. In many instances (e.g., only one seal per door has failed), primary containment remains OPERABLE, yest only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (according to LCO 3.6.1.1) would be provided to restore the air lock door to OPERABLE status prior to requiring a plant shutdown. In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits.

Required Action C.2 requires that one door in the primary containment air lock must be verified closed. This action must be completed within the I hour Completion Time. This specified time period is consistent with the ACTIONS of LCO 3.6.1.1, which require that primary containment be restored to OPERABLE status within I hour.

Additionally, the air lock must be restored to OPERABLE i status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completten Time is l reasonable for restoring an inoperable air lock to OPERABLE I status considering that at least one door is maintained closed in the air lock.

C\%l locktk f,3 D.1 and D.2 % 9 g If the inoperable primary containment air lock cannot'be 841 4 restored to OPERABLE status within the associated 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

I (continued) 1 aim /t CTS B 3.6-11 Rev 1, 04/04 9'r l

l SEV $

Prit:ary Containment Air Leck B 3.6.1.2

,, BASES (continued)

SURVEILLANCE SR 3.6.1.2.1

, REQUIREMENTS Maintaining primary containment air locks OPERABLE requires l

cong]agewiththe1,sakageratetestregrenensof

.m.,., ,,, . .. . r... .,, .. ...... .,, .,,.....

--t i re . This SR reflects the leakage rate testing

'**M j#m M4i'1* d requirements with respect to air lock leakage (Type B 4 , n ,,,. , q Leo ko e. Of f. leakage tests). The acceptance criteria were establishe p ,,,,,n.

> - l 6 & ; ir.i U J .;. L .L er.4 ,,.i e. , n r.t n rt C ^v^e Riii sf/g g,opo M _t.;;i'lk.

- - air lo The periodic leakage doestesting requirements not exceed the allowedverify that fraction of the the overall primary containment leakage rate. The Frequency is f,(s required byja- "CFo app - ' ~~ - - - M, .*ppedi.x 3 (P.-f. 2),a" n --dif t:d by

-' '"^^"--~

c._ d;;i!.H_ , 7_ _;; '.;i. ._~T"

- ,' 7 ' ' '- '- "" ~"... " '^ "

The SR has been modified by I Note *that states that an inoperable air lock door does not invalidate the previous h

successful performance of the overall air lock leakage test. gai_1 This is considered reasonable since either air lock door is y capable of providing a fission product barrier in the event i 1

id5ER.T of a DBApr

\ g g,g,, yg- l v$ eel for edty a est W (, roc edu ret te uire SR 3.6.1.2.2 Tricf adh era << t'a )

pMyteeher operup The air lock interlock mechanism is e igned to prevent

t simultaneous opening of both doors in the air lock. Since both the inner and outer doors of an air lock are designed '

to withstand the maximum expected post accident primary containment pressure, closure of either door will support primary containment OPERABILITY. Thus, the interlock g*[ feature supports primary containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. periodic testing of this interlock demonstrates that the interlock will function as desi ned and that simultaneous inner and outer door opening wi.1 not inadvertently occur. Due to the purely mechanical nature of

~

this interlock, and given that the interlock mechanism is

*b'""*M ,

challenged when primary containment is entwed$0this test is only required to be performed ; = et-- M p i= ~y N M t:t ..- T,2 bet'ts-not=requtred more frevently than pgg # 1"=i-t y: eten primary w.teir.nr.t-4s-de-inr6d/ The

.H d e Frequency is based on engineering judgment and is considered adequate '- 2: :f other id-tri:tretive :strsh G u e.*, the f the in fo r loc k. h no G_oer.,ah cha liened dueohy tue of the

~V b (continued) 1:v 1. ad!07/;5---

\ ' '"" " Q M 12 -

h ked on tAe elegire n, D'l m > tin . h 21 mc YA &*f u' < y

'fo p o r a, this srg under tk co,de% 1AJ aply du & c) e p h #

f~

\

ou tacje o c! M e. po te n io. I (ic in s of Prind 6PftM b/ CITY lf the $vini Homer wea pm%y udwilk co kinruenQ A reacfW x M po w r. & Nwm nyuw.f ;, Jvs neeJ twj sn ewrie

~

l q

1 opwa kny ~

eype,-;m . -

~

j Rev T

I

! Prirary Containment Air Lock B 3.6.1.2 l

INSERT B 3.6.1.2 1 1 aI l

I Note 2 has been added to this SR. requiring the results to be Q l evaluated against the acceptance criteria which is applicable %

l to SR 3.6.1.1.1. This ensures that air lock leakage is

! properly accounted for in determining the combined Type B and ,

j C primary containment leakage rate.

l j i

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1 l

l

)

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I FERMI UNIT 2 Page B 3.6 12 (INSERT) Revision 5. 04/30/99l l

r JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.6.1.2 - PRIMARY CONTAINENT AIR LOCK 1

NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current licensing basis: including design features, existing license requirements and commitments. Refer to CTS Discussion Of Changes to the related requirement for a detailed justification of changes made to the current licensing basis which are also reflected in the ITS as presented. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with i Writer's Guide conventions.

P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses. Specifically, some of the changes are related to the Fermi 2 airlock design, which does not incorporate inflatable seals (as reflected in NUREG 1433): nor does the design include control room indication of airlock door positioning.

P.3 Not used. l l

P.4 Not used.

l3 i P.5 Not used. ld P.6 The ITS details of leakage rate tests are relocated to the Primary Containment Leak Rate Testing Program, which is being added to Section 5 Administrative Controls. This presentation is l generally consistent with CTS presentation (which already includes an Administrative Controls Program for primary containment leak rate testing). Additionally, several Bases changes are made for editorial clarity. These changes are in general accordance with l (unapproved) Generic Change TSTF 52, application of 10 CFR 50.

Appendix J. Option B. :

P.7 The reference to the NRC Policy Statement has been replaced with a !

more appropriate reference to the Improved Technical Specification

" split" criteria found in 10 CFR 50.36(c)(2)(ii).

P.8 The Bases for Required Actions D.1 and D.2 is corrected to reflect the Fermi 2 ITS. The ITS Required Actions D.1 and D.2 provide o alternates to completing the restoration to OPERABLE ' status, d before imposing a required shutdown. These alternates are <

included.in the proposed ITS Bases. T FERMI UNIT 2 1 REVISION 5. 04/30/99l

JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.1.2 PRIMARY CONTAINMENT AIR LOCK GENERIC CHANGES C.1 TSTF 17: NRC approved change to NVREG 1433: with the following I changes:

a. ~normally" added to the inserted Bases for SR 3.6.1.2.2 to l properly indicate that for Fermi 2 the air lock interlock )

is not "normally" challenged during use of the air lock. ,

The interlock is challenged during performance of the SR.

and may be inadvertently challenged at other times. .

I

b. The inserted Bases for SR 3.6.1.2.2 revises "need" to )

~ desire" in describing when the SR is performed. Fermi 2 has no specific "need" to perform the SR during an outage, although it certainly is a desire.

1 1

FERMI - UNIT 2 2 REVISION 5. 04/30/99l

1 Pri2ary Containment Pressure B 3.6.1.4 BASES APPLICABLE SAFETY ANALYSES (continued) i l

The bounding accident events involve actuation of the drywell spray following a steam leak in the drywell (small break accident) and following a DBA. All i intermediate line break events are enveloped by these cases. '

The limiting plant transient case is the inadvertent drywell spray actuation during plant operation, which assumes an initial condition of 0.10 psig (Ref.1).

l Primary containment pressure satisfies Criterion 2 of 10 CFR l l

50.36(c)(2)(ii).

l LC0 In the event of a DBA, with an initial 3rimary containment l

pressure s +2.0 psig, the resultant pea ( primary containment accident pressure will be maintained below the primary containment design pressure. In the event of an inadvertent t

~ drywell spray actuation, with an initial primary containment 1 1 pressure a 0.10 psig, the resultant negative primary l

Ql containment pressure will be above the external primary containment design pressure.

APPLICABILITY In MODES 1, 2. and 3. a DBA could cause a release of ,

radioactive material to primary containment. In MODES 4 )

and 5, the probability and consequences of these events are !

reduced due to the pressure and temperature limitations of !

these MODES. Therefore, maintaining primary containment pressure within limits is not required in MODE 4 or 5. .

I t

i ACTIONS dul l, i

With primary containment pressure not within the limit of the LCO. 3rimary containment pressure must be restored i within 1 lour. The Required Action is necessary to return j

! operation to within the bounds of the primary containment !

analysis. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is consistent with the ACTIONS of LC0 3.6.1.1, " Primary Containment." which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , i

! i l

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l FERMI UNIT 2 B 3.6.1.4 - 2 Revision 5. 04/30/99 l l l

l PriGary Containment Pressure l

B 3.6.1.4 Insert B 3.6.1.4 1 ;

l l The most severe negative pressures in cor.tainment result )

from events that challenge the vacuum relief system. The l

events are associated with operation of the containment spray mode of the RHR system under accident and transient j conditions. which result in high depressurization rates. '

The bounding accident events involve actuation of the drywell spray following a steam leak in the drywell (small-break accident) and following a DBA. All intermediate-line i break events are enveloped by these cases. The limiting plant transient case is the inadvertent drywell spray actuation during plant operation, which assumes an initial condition of 0.10 psig (Ref.1).

l Insert B 3.6.1.4 2 l

A sensitivity study (Ref. 3) was performed to evaluate the maximum containment pressure with an initial pressure of 2 psig. It was found that post LOCA containment pressure remains below the maximum allowable pressure of 62 psig.

Therefore. the LC0 limitation of 2 psig ...

Insert B 3.6.1.4 3 The Technical Specification limits are based upon analyses performed at initial licensing that result in a peak post-LOCA drywell pressure of 56.5 psig (Ref.1). This value bounds the more recent licensing basis analysis for the l power uprate" license amendment, which results in Insert B 3.6.1.4 4 In the event of an inadvertent drywell spray actuation. with 7

l an initial primary containment pressure t -0.10 psig. the l(

l resultant negative primary containment pressure will be j above the external primary containment design pressure.

FERMI UNIT - 2 Page B 3.6 33 (INSERT) Revision 5 04/30/99 l

l

~5pecificaf to tt 3.4. l.5 faNTAINMENT SYSTEMS DRYWELL AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION L CO 3. 4.1. C -3.6.1. 7 Drywell average air temperature shall not exceed 145*F. l APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the drywell average air temperature greater than 145'F, reduce the jC7M4 average air temperature to within the limit within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least l

HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the l

g./,,g 3 following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l l

l SURVEILLANCE RE001REMENTS

$ 2 3'/,'I* f*I he vo.lenfetric wefage7 $.l l l 4.0.1.7 The drvwell averaoe air temperat 11 (pea *6neraterfs at thedollowintr loc ns an 4 hall be determined to be within the limit at least once per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

levation Azinidh (At le st one at each elevation) l

a. '0" 90', 135V *70or 316' N

. 597'0" , 75', 93', 135', 175* 00*, 246',

272*, 306' or 345' / g ,j

c. 8" , 0', 90*, 180* 270*

d 648'6" 45', 135' 25* or 315'

e. 662'0" O' ,180* or 2

f. J '6" /0* or 180*

( __ -

FERMI - UNIT 2 3/4 6-13 Amendment No. 20 l

PAGE OF 01

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.5 DRYWELL AIR TEMPERATURE ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS), certain wording preferences or conventions

( are adopted which do not result in technical changes (either I actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Tecnnical Specifications NUREG 1433. Rev. 1.

l

- TECHNICAL CHANGES MORE RESTRICTIVE i

' None i l

TECHNICAL CHANGES LESS RESTRICTIVE l " Generic" ,

1 LA.1 CTS 4.6.1.7 requires the drywell average air temperature to be I determined and details how the SR is to be performed. ITS lE SR 3.6.1.5.1 requires that the drywell average air temperature be determined, but does not specify how the SR is to be performed.

This is acceptable because these details do not impact the ITS requirement to determine the drywell average air temperature.

Furthermore, the methods of performing a surveillance are not directly required to support the Operability of the ITS components.

The " volumetric average" computational method is relocated to the l ITS Bases, where changes are controlled by the Bases Control __

program. The specific temperature monitoring locations are l relocated to the UFSAR where changes are controlled by 10 CFR 4 l 50.59. I l

s TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" I

None j I

RELOCATED SPECIFICATIONS I i

None FERMI UNIT 2 1 REVISION 5. 04/30/99

I LLS Valves B 3.6.1.6 BASES ACTIONS (continued)

B.1 and BJ l

l If both LLS valves are inoperable or if the ino)erable LLS valve cannot be restored to OPERABLE status wit 11n the required Com)letion Time, the plant must be brought to a MODE in whic1 the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within i 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed i l

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.

l SURVEILLANCE SR 3.6.1.6.1 '

l REQUIREMENTS >

A manual actuation of each LLS valve is performed to verify ti,at 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. r Adequate reactor steam dome pressure must be available to y perform this test to avoid damaging the valve. Adequate l _ pressure at which this test is to be performed is a 850 psig g (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 1 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. 2). Operating experience has shown that these com)onents usually pass the Surveillance when performed at t1e 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 l FERMI UNIT 2 B 3.6.1.6 - 3 Revision 5. 04/30/99 l

l L

LLS Valves B 3.6.1.6 BASES SURVEILLANCE REQUIREMENTS (continued) prior to performing the test because valve OPERABILITY and the setpoints for overpressure protection are verified by Reference 2 prior to valve installation. After adequate reactor steam dome pressure anci flow are reached,12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to prepare for and perform the test.

l SP 3.6.1.6.2 1

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 un)lanned transient if the

Surveillance were performed with t1e reactor at power.

0)erating experience has shown these components usually pass tie Surveillance when performed at the 18 month Frequency.

Therefore, the Frecuency was concluded to be acceptable from a reliability stancpoint. l l t4 i

4 This SR is modiried by a Note that excludes valve actuation.

g This prevents a reactor pressure vessel pressure blowdown.

l REFERENCES 1. UFSAR, Section 5.2.2.5.

l l 2. ASdE, Boiler and Pressure Vessel Code.Section XI.

l l

l 1

1 l FERMI - UNIT 2 B 3.6.1.6 - 4 Revision 5 04/30/99 f

o

LLS Valves B 3.6.1.6 l

BASES

}

ACTIONS B.1 and B.2 (continued) allowed Completion Times are reasonable, based on operating experienca, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.1.6.1 REQUIREMENTS A manual actuation of each LLS valve is performed to verify that the valve and solenoids are functioning properly and no l 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 l perform this test to avoid damaging the valve. Adequate @ '

pressure at which this test is to be performed is 8 cro -

hMkHtpsig (the pressure recommended by the valve manufacturer). Also, adequate steam flow must be passing

'E 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

= - o represented by ^ t 1 t 1.28 turbine pass valves open,-4e-of IWd 10 f 4*' "--- E J;- 15/M. The ;tl month Frequency was 4 based on the SJRV tests required by th E Boiler and Pressure Vessel Code,Section XI (Ref. 2). The 9:; :::y of 18 - ne_aa e _ . . .. . .ow ,w,.~w........

n}s!:::idfn..n 0

.... . ::d'

^/;".' u ;it.. :.:t:!; ::t:f. Operating experience 'as shown that these components usually pass the Surveillance when performed at the (18) month Frequency.

Therefore, the Frequency was conc W.ed 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 2 prior to valve installation. After adequate reactor steam dome pressure and flow are reached, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to prepare for and perform the test.

(continued)

M42 B 3.6-40 Rev-Ir-04/07/M-

$W

LLS Valves B 3.6.1.6 BASES SURVEILLANCE SR 3.6.1.6.2 REQUIRENENTS (continued) The LLS designated SfRVs 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.Y 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 i Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass ]

g the Surveillance when performed at the 18 month Frequency. j Therefore, the Frequency was concluded to be acceptable from )

a reliability standpoint. !

This SR is modified by a Note that excludes valve actuation 3 l g This prevents a reactor pressure vessel pressure blowdown.

REFERENCES 1. q'FSAR, Section (5.5.!?}

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

I I

l I

I BWRf4-STS- B 3.6-41 kV 1, 04/07/95-Rev 5'

JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433 ITS: SECTION 3.6.1.6 - LLS Valves NON BRACKETED PLANT SPECIFIC CHANGES P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current ,

licensing basis: including design features, existing license l requirements and commitments. Additional rewording, reformatting.

I and revised numbering is made to incorporate these changes consistent lh with Writer's Guide conventions. Since Fermi 2 SRVs are designed l - with only one solenoid, the " Staggered Test Basis" is not applicable.

l P.2 Bases changes are made to reflect plant specific design details. ;

equipment terminology, and analyses. l l

l P.3 Bases changes are made to reflect changes made to the Specification.

Refer to the Specification change JFD for additional detail. el j 1

P.4 Not used. lk P.5 Not used. l l"T P.6 The reference to the RC Policy Statement has been replaced with a j more appropriate reference to the Improved Technical Specification

" split" criteria found in 10 CFR 50.36(c)(2)(ii).

1 i

l l

l 4

FERMI - UNIT 2 1 REVISION 5 04/30/99l j

l Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7 3.6 CONTAINMENT SYSTEMS .

j 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers flLC03.6.1.7 Each reactor building to suppression chamber vacuum breaker g shall be OPERABLE. i APPLICABILITY: MODES 1, 2. and 3.

ACTIONS Y ..................................... NOTE - - - -- -- - - ----- -- -

k $$$$f!.OS SS.!S2..I.! .f$.!!!."$.............................

CONDITION REQUIRED ACTION COMPLETION TIME i

i A. One or more lines with A.1 Close the open vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months one reactor building- breaker, k' to suppression chamber <

vacuum breaker not

. closed.

" B. One or more lines with B.1 Close one open vacuum 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months two reactor building- breaker.

to suppression chamber j O vacuum breakers not j l8 closed. j

\

% i k C. One line with one or B.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months more reactor building- breaker (s) to to suppression chamber OPERABLE status.

'l vacuum breakers inoperable for !

opening.

l 1

, (continued) l l FERMI - UNIT 2 3.6 18 Revision 5. 04/30/99 {

l l

I Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 3 D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Wl Associated Completion g Time not met. MQ l D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l

l 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 l 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.

1 SR 3.6.1.7.3 Verify the opening setpoint of each 18 m nths vacuts breaker is s 0.5 psid.

L j FERMI - UNIT 2 3.6-19 Revision 5. 04/30/99 l

1 e

Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7 I l B 3.6 CONTAINMENT SYSTEMS B 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers I

BASES BACKGROUE The function of the reactor building-to suppression chamber vacuum breakers is to relieve vacuum when primary l l containment depressurizes below reactor building pressure.

If the drywell depressurizes below reactor building pressure, the negative differential pressure is mitigated by l flow through the reactor building to-suppression chamber

' vacuum breakers and through the suppression chamber-to-drywell vacuum breakers. The design of the external .

(reactor building to suppression chamber) vacuum relief l provisions consists of two vacuum breakers (a vacuum breaker p and an air operated butterfly isolation valve), located in I series in each of two lines from the reactor building to the l

I

'f suppression chamber airspace. The butterfly valve is actuated by differential pressure sensors which result in l air operated actuators opening the isolation valve. The l

vacuum breaker is self actuating and can be remotely 9l operated for testing purposes. The two vacuum breakers in series must be closed to maintain a leak tight primary containment boundary.

l A negative differential pressure across the drywell wall is

! caused by ra)id depressurization of the drywell. Events that cause t11s rapid depressurization are cooling cycles.

l inadvertent primary containment spray actuation, and steam i condensation in the event of a primary system rupture.

l Reactor building to-suppression chamber vacuum breakers prevent an excessive negative differential pressure across the primary containment boundary. Cooling cycles result in minor pressure transients in the drywell, which occur slowly and are normally controlled by heating and ventilation equipment. Steam condensation results in a more significant pressure transient and becomes important in sizing the external (reactor building to-suppression chamber) vacuum breakers, i

l l FERMI - LUIT 2 B 3.6.1.7 - 1 Revision 5, 04/30/99 l

1 Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES APPLICABLE SAFETY ANALYSES (continued)

The results of these two cases show that the external vacuum breakers, with an opening setpoint of 0.5 psid. are capable of maintaining the differential pressure within design limits. I The reactor building to suppression chamber vacuum breakers satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LC0 All reactor building to suppression chamber vacuum breakers, l 4 two on each line, are required to be OPERABLE to satisfy the q assumptions used in the safety analyses. The requirement ensures that the two vacuum breakers (vacuum breaker and air i operated butterfly isolation valve) in each of the two lines from the reactor building to the suppression chamber q- airspace are closed (except during testing or when performing their intended function). Also, the requirement

( ensures both vacuum breakers in each line will o)en to relieve a negative pressure in the suppression clamber.

1 APPLICABILITY In MODES 1. 2. and 3. a DBA could cause pressurization of primary containment. In MODES 1. 2. and 3. the Primary Containment is required to be OPERABLE to mitigate the effects of a DBA. Excessive negative pressure inside primary containment could occur due to inadvertent initiation of the Suppression Pool Saray System. Therefore, the vacuum breakers are required to 3e OPERABLE in MODES 1

2. and 3. When the Primary Containment is required to be OPERABLE to mitigate the effects of inadvertent actuation of the Suppression Pool Spray System.

Also, in MODES 1, 2. and 3. a DBA could result in excessive negative differential pressure across the drywell wall caused by the rapid depressurization of the drywell. The event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in MODES 1. 2. and 3.

l FERMI UNIT 2 B 3.6.1.7 - 3 Revision 5. 04/30/99 l

r Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7 4

BASES APPLICABILITY (continued)

In MODES 4 and 5, the probability and consequences of these ;

events are reduced due to the pressure and temperature 1 limitations in these MODES. Therefore, maintaining reactor building to suppression chamber vacuum breakers OPERABLE is not required in MODE 4 or 5.

b A Note has been added to provide clarification that, for the J. ACTIONS

pur)ose of this LCO, separate Condition entry is allowed for T eac1 penetration flow path.

l l hu.1 t

l 4 With one or more vacuum breakers not closed, the leak tight l

5 primary containment boundary may be threatened. Therefore.

E the inoperable vacuum breakers must be restored to OPERABLE

% status (i.e., closed) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is consistent with requirements for '

inoperable suppression chamber to drywell vacuum breakers in LC0 3.6.1.8, " Suppression Chamber to Drywell Vacuum Breakers." The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundancy capability afforded by the remaining breakers, the fact that the OPERABLE breaker in each of the lines is closed, and the low probability of an event occurring that would require the vacuum breakers to be OPERABLE during this period.

J B

With one or more lines with two vacuum breakers not closed, primary containment integrity is not maintained. Therefore, 3 one open vacuum breaker must be closed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This 3 Completion Time is reasonable based on engineering

\n judgement.

I

~

L.1 kll With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary is intact. The ability to mitigate an event that causes a y containment depressurization is threatened, however, if both vacuum breakers in at least one vacuum breaker penetration are not OPERABLE. Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and l FERMI - UNIT 2 B 3.6.1.7 - 4 Revision 5. 04/30/99

Reactor Building to Suppression Chamber Vacuum Breakers >

B 3.6.1.7 BASES ACTIONS (continued) <

i the fact that the leak tight primary containment boundary is being maintained.

J Ql D.1 and D.2 a ,

If all the vacuum breakers in one line cannot be closed or !

E' l restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 l '

does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the )

recuired plant conditions from full power conditions in an orcerly manner and without challenging plant systems.

I SURVEILLANCE SR 3.6.1.7.1 REQUIREMENTS ,

Each vacuum breaker is verified to be closed to ensure that j a potential breach in the primary containment boundary is j not present. This Surveillance is performed by observing .

local or control room indications of vacuum breaker position or by verifying a differential maintained between the reactor bressure ofsuppression uilding and 0.5 psid is h chamber. The 14 day Frequency is based on engineering l judgment. is considered adequate in view of other j indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.

i 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 actual differential pressure are not considered as failing this SR.

i l FERMI UNIT 2 B 3.6.1.7 - 5 Revision 5. 04/30/99 i

Speca: uvon 3.c.t.7 M*I CONTAINMENT SYSTEMS REACTOR BUILDING - SUPPRESSION CHAMBER VACUUM BREAKERS llMITING CONDITION FOR OPERATION O

3 fo I 7 -4drdd All Reactor Building - suppression chamber vacuum breakers shall be g ,y OPERABLE [ano closedj APPLICABillTY: OPERATIONAL CON 0lTIONS 1, 2, and 3.

ACTION:

4. With one Reactor Building - suppression chamber vacuum breaker tn NCn0 PJ C inoperable for opening @ut known to be closedJ~festore the ' 1 inoperable vacuum breaker to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be el D D4 g in at least HOT SHUTOOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTOOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . l With one Reactor Building - suppression chamber vacuum breaker open, (4- J ncma ABb. J isolate the associated vacuum breaker line by closing the isolation '

valve within 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s: restore the open vacuum breaker to the closed position within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT SHUTDOWN within the

(

next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

c. Wit the position cicator of any eactor Building suppre ion aker inoperable restore the inoperabl position g,j c mber vacuum ndicator to RABLE status wi in 14 days or verify e vacuum breaker t e closed at least nce per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by vi al inspect n. Otherwise, dec re the vacuum breaker operable or b '

in a east HOT SHUTDOWN hin the next 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months nd in COLD Q WN within the foi ing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .f SURVEILLANCE RE0VIREMENTS g 4.6.4.2 Each Reactor Building - suppression chamber vacuum breaker shall be: 1 SR3,G,t.~7.l -er Verified closed at least once per 7 days D L ,7.

'k

b. Demonstrated OPERABLE: NC I' 2-g_ ___

l. At least once per 31 days by: ~

.l 5A34IS'L a) Cycling vacuum breaker through at least one complete test cycle of full travel.

.)

(b)- Veri ngthepositionindiratorUVLKAt3LLDy/Dserving) tex cted valve movement & fring the cycling Aestg

2. At least once per 18 months by: i P

a) Demonstrating that the force required to open each

a R 3 hd O. 3 vacuum breaker does not exceed (the/equivplent A_D '3 lk 0.5 psid.

@ "t:=? '.::::ti O -

Vertyying Ine posniop inaicator OPERABLE b/performan of f CHANNEL CALIBR4r10N. j FERMI UNIT 2 3/4 6 50 PAGE / OF 01

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.7 - REACTOR BUILDING TO SUPPRESSION CHAM ER VACUUM BREAKERS ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications (CTS) to the proposed plant specific Improved Technical Specifications (ITS). certain wording preferences or conventions are adopted which do not result in technical changes (either actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the l Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1. l A.2 CTS 3.6.4.2 details that reactor building to suppression chamber vacuum breakers are to be Operable and closed." ITS LC0 3.6.1.7 simply requires Operability. Since Operability addresses the entire safety related function, and is adequately detailed in the Bases, elimination of the explicit statement to be closed (as a subset of Operable) is administrative, with no impact on safety. 3 A el A.3 Not used. lg g ,

e 1 A.4 Not used. lW to !

A.5 Not used.

A.6 ITS LC0 3.6.1.7 Actions are modified by a Note, which provides clarification that, for the purpose of the associated LC0.

" Separate Condition entry is allowed for each line." This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each vacuum breaker line with an inoperable vacuum breaker. Complying with the Required Actions ]

will allow for continued operation: subsequent inoperable vacuum breaker (s) in another line are governed by subsequent Condition g

entry and application of associated Required Actions. This is an administrative change with no impact on safety because the clarifications provided by the Note are consistent with the existing interpretation of the CTS.

FERMI UNIT 2 1 REVISION 5. 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.7 REACTOR BUILDING TO SUPPRESSION CHAM ER VACUUM BREAKERS TECHNICAL CHANGES MORE RESTRICTIVE

- M.1 CTS 3.6.4.2. Action a. reflects a condition where the vacuum j breaker is inoperable for opening, allowing 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore it to operable status. However, the CTS Action also includes an explicit "but is known to be closed" condition, which results in deferring the beginning of the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowance if the vacuum breaker is not full closed when it is discovered that it will not b open. This deferral could be up to 2 additional hours (CTS d Action b requires any open vacuum breaker to be closed within t 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ). ITS 3.6.1.7 Action C does not explicitly include a check of whether the vacuum breaker is known to be closed: and therefore, its Required Action to restore the vacuum breaker within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is not delayed pending closure of the vacuum breaker. This results in the ITS being more restrictive by up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . .The added conservatism presents no negative impact on safety.

TECHNICAL CHANGES LESS RESTRICTIVE

" Generic" LA.1 CTS 3.6.4.2 Actions and associated surveillance requirements for the vacuum breaker position indicators are being relocated to the Technical Requirements Manual. The vacuum breaker position l indication instrumentation does not support the Operability (i.e.,

safety function) of the vacuum breaker and therefore, does not directly support the safe operation of the facility. The ,

instrumentation only provides a monitoring capability of the ~

i vacuum breaker position. Therefore, the requirements associated c with the instrumentation can be removed from ITS consistent with T the BWR STS. NUREG 1433. Revision 1. and relocated in the Technical Requirements Manual (TRM). These details can be lw adequately defined and controlled by the provisions of 10 CFR

.50.59. This detail is not required to be in the ITS to provide lN adequate protection of the public health and safety acceptable because it does not impact the requirement to maintain the vacuum breakers Operable.

FERMI UNIT 2 2 REVISION 5 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.7 REACTOR BUILDING TO SUPPRESSION CHAM ER VACUUM BREAKERS LA.2 CTS 4.6.4.2.b.2.b) requires a visual inspection of the reactor building to suppression chamber vacuum breakers. This inspection requirement is relocated from Technical Specifications to the TRM.

l These details can be adequately defined and controlled by the i provisions of 10 CFR 50.59. This detail is not required to be in i

the ITS to provide adequate protection of the public health and l safety acceptable because it does not impact the requirement to maintain the vacuum breakers Operable. l l

1 LA.3 CTS 4.6.4.2 requires the demonstration that the force required to l open each vacuum breaker does no exceed "the equivalent of" !

0.5 psid. ITS SR 3.6.1.7.3 requires this same demonstration, but tr> j relocates the wording "the equivalent of" to the ITS SR Bases. L where changes are controlled by the Bases Control Program. This Q l detail is implied and is not necessary to be explicitly included in the ITS.

TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" L.1 CTS 4.6.4.2 requires each vacuum breaker be verified closed every 7 days. ITS SR 3.6.1.7.1 requires this verification every 14 days. Vacuum breakers are also verified closed on a 31 day frequency in conjunction with the functional test requirement (ITS I SR 3.6.1.7.2). Surveillance frequencies for other component i position verification are typically set at 31 days. When one or more vacuum breaker position indications are inoperable. the CTS l required verifications of vacuum breaker positions is required at l 14 day intervals (note this is relocated from the ITS based on other discussions). Based on extended intervals for similar requirements on component position surveillances, and the fact that CTS Actions for inoperable vacuum breaker position indication allow 14 days, this extension is considered appropriate.

l FERMI - UNIT 2 3 REVISION 5. 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.7 - REACTOR BUILDING T0 SUPPRESSION CHA M ER VACUUM BREAXERS L.2 CTS 4.6.4.2.a requires that the vacuum breakers be closed at all l

I times: with no explicit allowance to be open when performing their i intended function (i.e., when relieving vacuum), and no allowance l for opening during performance of required Surveillances. ITS SR 3.6.1.7.1 has two Notes: Note 1 stating that the vacuum breakers can be opened when performing required Surveillances. and Y Note 2 stating that vacuum breakers can be open when performing l

their intended function. These additions provide specific ITS k direction, which is consistent with the intent of maintaining l

" operable" vacuum breakers. These allowances will not affect the vacuum breaker ability to perform its intended functions of relieving vacuum or of providing an isolated containment barrier in the event of positive containment pressure. Therefore. these l changes introduce no negative impact on safety.

RELOCATED SPECIFICATIONS None l

TECHNICAL SPECIFICATION BASES )

l The CTS Bases for this Specification have been replaced by Bases that reflect I the format and applicable content of ITS 3.6.1.7 cunsistent with the BWR STS.

NUREG 1433. Rev. 1.

I 1

l FERMI - UNIT 2 4 REVISION 5 04/30/99l l l

I l

Reactor Building-to-Suppression Cf.:,ber Vacuum Broakers i 3.6.1.7 3.6 CONTAINMENT SYSTEMS I6 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.42)l

, I LCO 3.6.1.7 Each reactor building-to-suppression chamber vacuum breaker o shall be OPERABLE. 4 k

APPLICABILITY: MODES 1. 2. and 3. g L

ACTIONS 4 ,

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

Separate Condition entry is allowed for each line.

\gg4/

/ \

l

\

l I CONDITION REQUIRED ACTION COMPLETION TIME l l A. One or more lines with A.1 Close the open vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Acnog b) one reactor building- breaker. 4 l to-suppression chamber l vacuum breaker not 9 closed. 9 l ~

k 0,I B. One or more lines with B.1 Close one open vacuum houh two reactor building- breaker.

to-suppression chamber vacuum breakers not (/}c7104 b) l closed.

l -

C. One line with one or 'C.1 Restore the vacuum 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months more reactor building- breaker (s) to CTiedof to-suppression chamber OPERABLE status. j vacuum breakers l

inoperable for opening.

J.

4 (continued) l l

swayesTS 3.6-23 h + 04/07/95 t

C

R3acter Building-to-Suppressicn Chamber Vacuum Breakers I 3.6.1.7 l

I ACTIONS (continued) )

CONDITION REQUIRED ACTION CONPLETION TINE i D. Two [or more] 1 s D. Rest all vac 1h fl one or reactor e

ding-to-b ers in ne to OPE LE ok suppre on ch status, vac breakers i rable fo pening.

/

p[.RequiredActionand .1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months l hW*rJ h Associated Completion Time not met. Ngl /X AM b\/

$.2 Be in MODE 4.

36hoursf' -$

Y- O $

?

'E M

SURVEILLANCE REQUIRENENTS SURVEILLANCE FREQUENCY SR 3.6.1.7.1 - - - - - - - - - --- NO T ES --------------

1. Not required to be met for vacuum breakers that are open during /N l Surveillances. \ 00 b h' .

2. Not required to be met for vacuum breakers open when perfoming their intended function.

Verify each vacuum breaker is closed. 14 days (L4,(,,4.2.. Ah SR 3.6.1.7.2 Perform a functional test of each vacuum days y,(,,y,2, b ,l breaker.

(continued)

~C/? ST3 3.6-24 Rowt G4/Gifsi KEY

I Reactor Building-to-Suppression Chamber Va uum Breakers B 3.6.1.7 8 3.6 CONTAINHEKT SYSTEMS B 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers 8ASES 8ACKGROUND The function of the reactor building-to-suppression chamber vacuum breakers is to relieve vacuum when primary containment depressurizes below reactor building pressure.

If the drywell depressurizes below reactor building pressure, the negative differential pressure is mitigated by flow throgh the reactor building-to-suppresjion chamber vacuum breakers and through the suppression 9 chamber-to-drywell vacuum breakers. The design of the external (reactor butiding-to-suppression chamber) vacuum relief l

__ provisions consists of two. vacuum breakers (a vacuum breaker

/. M'TT and_ an air operated butterfly 4 valve), located in series in ID llSo --ahl each of two lines from the reactor building to the o p,1 suppression chamber airspace. The butterfly valve is 1 actuated by differential pressuret The vacuum breaker is 4.

Tengorc uAch result self actuating and can be remotely operated for testing t g a;" 4gg purposes. The two vacuum breakers in series must be closed N i

L i to maintain a leak tight primary containment boundary. j

.I Ort;uators ofeNn3 i l geisoGtgloftva(4.)l A negative causeddifferential pressure across by rapid depressurization of thethe drywell drywell. wall is Events D- ~

that cause this rapid depressurization are cooling cycles, inadvertent primary containment spray actuation, and steam condensation in the event of a primary system rupture.

Reactor building-to-suppression chamber vacuum breakers

! prevent an excessive negative differential pressure across I the primary containment boundary. Coolin ;

minor pressure transients in the drywell,g cycles which result occur in slowly and are normally controlled by heating and ventilation O- ent -5 eetent eray actuttieeresults in a more :

S tew M,e$gnui,73c ;Thre@ssure transient and becomes important in i a ndena h,m sizing the external (reactor building-to-suppression 1 chamber) vacuum braakers.

l The external vacuum breakers are sized on the basis of the air flow from the secondary containment that is required to j mitigate the depressurization transient and limit the maximum negative containment (drywell and suppression chamber) pressure to within design limits. The maximum depressurization rate is a function of the pt4macy- l 2 temperature and the assumed initial conditions of the primary containment atmosphere.

(continued) l 7.";/' :T: B 3.6-42 4ev 4 44/O U95~ ,

I l

Rev5' i

i 1

Reactor Building-to-Suppression Chamber Vacuum Breakers 8 3.6.1.7 8ASES APPLICABLE capable of maintaining the differential pressure within SAFETY ANALYSES design limits.

(continued)

The reactor butiding-to-suppression chamber vacuum breakers

' satisfy Criterion 3 o

MCFR = Tel["

S0 St;t---"Ct)(Q&

1bfo oA eack LC0 All reactor building-to-suppression chamber vacuum brea er i A C-4 are required to be OPERA 8LE to satisfy the assumptions use s&km" in the safety analyses. The requirement ensures that the two vacuum breakers (vacuum breaker and sir operated butterflyfvalve) in each of the two lines from the reactor

[3 -

building to the suppression chamber airspace are closed except durin testing or when performing their intended y

[

unction). A so, the rsquirement ensures both vacuum breakers in each line wl11 open to relieve a negative pressure in the suppression chamber.

A - ,

(frjina_ry(enfaina,e<q APPLICA81LITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. In MODES 1, 2, and 3, the Appi n .; n j Peel 3 p .i 3i.;;e is required to be OPERABLE to mitigate the OPAt effects of a DBA. Excessive negative pressure inside ppmu primary containment could occur due to inadvertent initiation of thtsp'ystem. Therefore. the vacuum breakers ,p,,gggf,9 are required to be UPERABLE in MODES 1, 2, and 3, when the E ppi.;;te;. Tobi ^,..., ;j;;;; is required to be OPERABLE, to wori

. f,k Y mitigate the effects of inadvertent actuation of the Suppression Pool Spray System.

co#. n Also, in MODES 1, 2, and 3, a DBA could result in excessive i

l negative differential pressure across the drywell wall caused by the rapid depressurization of the drywell. The l event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pre'ssure and temperature of the primary system prior to a DBA occur in MODES 1, 2, and 3. l q

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintair.ing reactor (continued) 4WR/4-STS - 8 3.6-44 Re 1, 04/07f95 Rev 5' I

l l

l Reactor Sullding-to-Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES APPLICABILITY building-to-suppression chamber vacuum breakers OPERABLE is (centinued) not required in MODE 4 or 5.

I 6

ACTIONS A Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allow each penetration flow path.

l u

With one or more vacuum breakers not closed, the leak tight primary contair.iaent boundary may be threatened. Therefore, l the inoperable vacuum breakers must be restored to OPERABLE Igd i f,h tu -er the ;= ;== k=he closed)within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . 8 W,

I

. The hour Completion Time is consistent with requirements '

I (l.C.y for inoperable suppresstort5 chamber- drywell vacuum l breakers in LCO 3.6.1.8, "Suppressio haaber-to-Drywell l Vacuum Breakers.' The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into l account the redundancy capability afforded by the remaining breakers, the fact that the OPERABLE breaker in each of the l

lines is closed, and the low probability of an event '

l occurring that would require the vacuum breakers to be i !

OPERARLE during this period. V l l

M I l With one or more lines with two vacuum breakers not closed, I I primary containment integrity is not maintained. Therefore, l one open vacuum breaker must be closed within I hour. This Completion Time is =: ht rt d th ths ;CTE3 u~

0 3.5.1 1, "P dry C = t: b. s t," W a h requires Ina l pr-imary cantainment be restored to OPFRARtr etztne witkip O l TLUMbit bastd m awptcohg tS u

With one line with one or more vacuum breakers inoperable Lj for opening, the leak tight primary containment boundary is b intact. The ability to mitigate an event that causes a l

containment depressurization is threatened, however, if both y l

vacuum breakers in at least one vacuum breaker penetration '

l are not OPERABLE. Therefore, the inoperable vacuum breaker (continued)

BWR/4 STS B 3.6-45 Rev 1, 04/07/95

$5v' V

Reactor Building-to-Suppression Chamber Vacuum Breakers l B 3.6.1.7 8ASES '

ACTIONS I.d (continued) l@

must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and k 1

)

the fact that the leak tight primary containment boundary is being maintained.

With two ' . u.e) lines th one er vacuum reake inoper e for opent , he primar ontal boundar is int . However the event a conta nt ressurizat , the funct of the uum bre s is ost. Ther ore, all va breake intone ne sus restored o OPERABLE s us with I hour, is C ion Time consistent yt h the AC S of L .6.1 ich req s that primary contal at be r credtoM.1 PERABLE atus within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

O f.1 and Y.2 4 l If all the vacuum breakers in Hone 1ine cannot be closed or 4. I restoredtoOPERA8LEstatuswi;hin}therequiredcompletion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be

( l l

brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 l 1

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are !

reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVE!LLANCE 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 perforeied by observing local or control room indications of vacuum breaker position or by verifying a differential pressure of ,

maintainedbetweenthereactorbuildingand(0.57psidis suppression chamber. The 14 day Frequency is based on engineering !

i (continued)

"" " SM

., 8 3.6-46 Rev-1,Gi,jGiji5 1

1 61) 4

N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.7 REACTOR BUILDING T0 SUPPRESSION CHAM ER VACUUM BREAKERS TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.1.7 "L.2" Labeled Comments / Discussions)

' Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by l 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.

The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against l each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the

! evaluation are presented below.

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

This change provides an exception allowing the vacuum breakers to be open when performing required Surveillances and when performing their i intended function (the exception is to the Surveillance that would otherwise require the vacuum breakers to be closed at all times). The vacuum breakers are not assumed to be an initiator of any previously _

8 analyzed accident. Therefore this change does not involve a <

significant increase in the probability of an accident previously %

l evaluated. The surveillance exception.is made only for circumstances

'where the vacuum breaker is under the immediate control of an operator (manually opening to confirm operability). or is performing its designed intended safety function (opening to relieve vacuum). As such, the vacuum breaker is expected to continue to perform its intended and assumed safety function and therefore this change does not involve a significant increase in the consequences of an accident previously evaluated.

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

The proposed change does not introduce a new mode of plant operation and i does not involve physical modification to the plant. Therefore, this l

change does not create the _ possibility of a new or different kind of j

! accident from-any accident previously evaluated. ,

1 FERMI UNIT 2 3 REVISION 5 04/30/99l l

l

T l t

! NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.7 REACTOR BUILDING TO SUPPRESSION CHAM ER VACUUM BREAKERS l

TECHNICAL CHANGES LESS RESTRICTIVE l

(Soecification 3.6.1.7 "L.2" Labeled Comments / Discussions)

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

l The change will not result in a significant reduction in a margin of MI l l l safety because the vacuum breakers are still required to be Operable. {

l The exception is made only for circumstances where the vacuum breaker is %

under the immediate control of an operator (manually opening to confirm operability), or is performing its designed intended safety runction (opening to relieve vacuum). As such, the vacuum breaker it expected to l continue to perform its intended and assumed safety functior.. and therefore this change does not involve a significant reduction in the margin of safety.

l FERMI - UNIT 2 4 REVISION 5. 04/30/99l t

3 Suppression Chamber to Drywell Vacuum Breakers B 3.6.1.8 BASES ACTIONS (continued)

An open vacuum breaker allows communication between the )

drywell and suppression chamber airspace. and, as a result. I there is the potential for suppression chamber 1 overpressurization due to this bypass leakage if a LOCA were 1 y to occur. Therefore, the open vacuum breaker must be closed 4 (confirmation of the closed status would follow procedures as outlined in the Bases for SR 3.6.1.8.1). The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months k completion time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment.

C,1 and C.2 If the inoperable suppression chamber-to drywell vacuum <

breaker cannot be closed or restored to OPERABLE status within the required Completion Time, the plant must be brought to a H00E in which the LC0 does not apply. To achieve this status, the plant must be brought to at least l H00E 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating '

experience, to reach the required plant conditions from full l power conditions in an orderly manner and without l challenging plant systems.

SURVEILLANCE SR 3.6.1.8.1 i REQUIREMENTS j 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 l position indication or by verifying that a differential (

pressure of 0.5 psid between the sup)ression chamber and !

drywell is maintained for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months wit 1out 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 i

2) closed indication while not able to establish a tores to drywell differential pressure, alternate methods of verifying that the vacuum brea(er is closed are detailed in Technical Requirements Manual (TRH).

l FERMI UNIT 2 83.6.1.8-4 Revision 5 04/30/99 l

t

Suppression Chamber-to Drywell Vacuum Breakers l B 3.6.1.8 l l

BASES SURVEILLANCE REQUIREMENTS (continued)

If position indication appears reliable (dual or open indication while torus to-drywell differential pressure is steady at 0 psid), and indicates open, the alternate methods outlined in the TRM can prove the indication to be in error and the vacuum breaker closed. However, in this case the vacuum breaker is assumed open until otherwise proved to satisfy the leakage test, and this confirmation must be performed within the Technical Specification 3.6.1.8 Required Action B.1 Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 7 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.

Notes 1 and 2 are added to this SR which allows suppression chamber to drywell vacuum breakers opened in conjunction with the performance of a Surveillance or open while performing their intended function to not be considered as failing this SR. These periods do not represent inoperable vacuum breakers.

SR 3.6.1.8.2 Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position. This ensures that the safety analysis assumptions ere valid. The Frequency of

" prior to entering MODE 2 or 3 from MODE 4 if not performed in the previous 92 days" is based upon the demonstrated reliability of the vacuum breakers and the potential for the test to resdit in a stuck open vacuum breaker, which could be caused by a failure of the pneumatically operated test mechanism. Since the vacuum breaker is inaccessible in MODES 1, 2. and 3, test induced inoperability would result in a forced shutdown of the unit. In addition, there exists substantial redundancy in that 4 vacuum breakers must fail to open before the safety function is lost. In addition, this functional test is required within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after a discharge of steam to the suppression chamber from the safety / relief valves.

j FERMI - UNIT 2 B 3.6.1.8 - 5 Revision 5. 04/30/99 l

l

SPEcsrocAT10N 3.(o I.g CONTAINMENT SYSTEMS SURVEfttANCE RE001REMENTS 4.6.4 Each suppression chamber - drywell vacuum breaker shall be: I gg 3./,,g,7,g /.1 Anad27 4./

k'

a. 400 NOTEf closed Verifte at least once per 7 days. [

b. Demonstrated OPERABLE:

1. During each COLD SHUTDOWN, if not performed within the previous 92 days, and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after any discharge of 'I g g, g , y , g steam to the suppression chamber from the safety / relief I J

l valves by:

l Cycling each vacuum breaker through at least one I I a) l complete cycle of full travel.

l b) erifying bot osition indic s UFtKAutt qr I observing ected valve m ment during M cyclin I l

tut. l l 2. At least once per 18 months by; S k 3,(,,( ,y.,3 a) Verifying the opening setpoint, from the closed position, to be less than or equal to 0.5 psid, and 3 LA,1

&)b Verif ng both position indi fors OPERABLE by p armance of a CHANNEL BRATION.

j Verify the opening for switch actuatio o be less I (c than or equal to . 3 inches.

l l

l FERMI - UNIT 2 3/4 6-49 Amendment No. 96 PAGE 1 OF 02 bf

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.8 SUPPRESSION CHAPEER T0 DRYWELL VACVUM BREAKERS l

ADMINISTRATIVE A.1 In the conversion of the Fermi 2 current Technical Specifications ,

(CTS) to the proposed plant specific Improved Technical Specifications (ITS). certain wording preferences or conventions are adopted which do not result in technical changes (either l actual or interpretational). Editorial changes, reformatting, and revised numbering are adopted to make the ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications NUREG 1433. Rev. 1. 1 A.2 CTS 3.6.4.1 details that the suppression chamber to-drywell vacuum breakers are to be " closed and Operable." ITS LC0 3.6.1.8 simply requires Operability. Since Operability addresses the entire '

safety related function, and is adequately detailed in the Bases, elimination of the explicit statement to be closed (as a subset of Operable) is administrative, with no impact on safety.

A.3 Not used. l TECHNICAL CHANGES MORE RESTRICTIVE I None i

TECHNICAL CHANGES LESS RESTRICTIVE , l

" Generic" 4

LA.1 CTS 3.6.4.1 Actions and associated surveillance requirements for the vacuum breaker position indicators are being relocated to the Technical Requirements Manual.and ITS Bases. The vacuum breaker position indication instrumentation does not support the Operability (i.e., safety function) of the vacuum breaker and therefore, does not directly support the safe operation of the facility. The instrumentation only provides a monitoring capability of the vacuum breaker position. Therefore, the requirements associated with the instrumentation can be removed from ITS consistent with the BWR STS. NUREG 1433. Revision 1.

These details can be adequately defined and controlled by the provisions of 10 CFR 50.59, and by the Bases Control Program.

This detail is not required to be. in the ITS to provide adequate protection of the public health and safety acceptable because it does not impact the requirement to maintain the Vacuum breakers Operable.

FERMI UNIT 2 1 REVISION 5. 04/30/99

DISCUSS 10N OF CHANGES ITS: SECTION 3.6.1.8 SUPPRESSION CHAM ER-TO DRYWELL VACUUM BREAKERS 1

TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic~ <

l L.1 CTS 4.6.4.1.a requires that the vacuum breakers be closed at all l times: with no explicit allowance to be open when performing their )

intended function (i.e. when relieving vacuum), and no allowance '

l for opening during performance of required Surveillances (e.g..

I functional testing of the vacuum breakers): however, these periods of opening reflect periods clearly within the intent of l considering the vacuum breaker capable of performing their s intended function and therefore being considered operable. ITS \

SQ SR 3.6.1.8.1 has two Notes: Note 1 stating that the vacuum breakers can be opened when performing required Surveillances, and Note 2 stating that vacuum breakers can be open when performing ,

L their intended function. These additions provide specific ITS l l direction which is consistent with the intent of maintaining

" operable" vacuum breakers. These allowances will not affect the vacuum breaker ability to perform its intended functions of l relieving vacuum or of providing an isolated containment barrier in the event of positive containment pressure. Therefore, these ,

changes introduce no negative impact on safety.

l l

l l RELOCATED SPECIFICATIONS l

l None l

TECHNICAL SPECIFICATION BASES l The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.6.1.8 consistent with the BWR STS.

I NUREG 1433. Rev. 1.

1 1

FERMI UNIT 2 2 REVISION 5. 04/30/99 i

l m_

~

tuppression Chamber-te-Drywell Vacuum Breakers

. B 3.6.1.8 l

I f* BASES (continued) j l

ACTIONS L1 l

With one of the required vacuum breakers inoperable for I I

opening (e.g., the vacuum breaker is not open and may be Of.'[ stuck closed or not within ils opening setpoint limit, so that it would not function as designed w ing an event that depressurized the drywell , the remair.fr., M OPERABLE { U O1dn.C6 pr# ( d,d L rs vacuum breakers are capab e of providing the vacuum relief function. However, overall system reliability is reduced 7

feriod,* ootp pur.ctb#

D'# (5:p.

I 22M-le ! !i T ? fii'2-^ '" 22: Of th? 7: Ei-Us = =~ >

tr&vould result in an excessive suppression chamber-of 4e rM O3 to tAODc AAAM.t.

to-drywell differentiai pressure during a D8A. Therefora, e

6 E with one Of tt: 'nia;] n;9ad vacuum breakerX inoperable, 36*g.%.

cit y

[ gs 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore :t h;;t x: ' the inoperable vacuum breakerg to OPERABLE status,;; ti.; ;; hat i

i

@ dtge l gn ;;;dttiene re ---*i t zt .;ith tis,;; ...

5:& :nu:h. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is conside ed

';r th. J, ;9n I acceptable due to the low probability of an went in which the remaining vacuum breaker capability would not be adequate.

L1 An open vacuum breakertallows communication between the drywell and suppressiori: chamber airspace, and, as a result,

/

( yfr% there is the potentialifor suppression chamber N overpressurization due.'to this bypass leakage if a LOCA were 1 Cl*d SO Mg ,to occur. Therefore, E fo((w paccdes a5 closed / 3, ;hs,,; .. gths open vacuum is allowed to closebreaker mustbreaker the vacuum be N Ng 4 ,4 Boses due to the low probability of an event that would crassurize .

primarycontainment.l'Ifv uum breaker position indication '

fror .M 3.G./ 8 /)* h /is ngtteliab , an alt sedistoveriythatadiffrfnthe ate method ofj efifying that

$ gkog brldidn ers are c ppression 3

chaser.

tial and/

'N /p/vaedumbre ressur dryw is f[0.5) maint ned d between for 1 the hour thout makeu f

r ired 2 hou Coepletion Ti is considered,p / The /adequaMr o

n' N4 l o 'l\ erform this

-- - est. f C.1 and C.2 If the inoperable suppression chamber-to-drywell vacuum breaker 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 (continued)

BWa/' TS- B 3.6-51 ":: 1,^4/07/7, -

EV

JUSTIFICATION FOR DIFFERENCES FROM NUREG 1433

, ITS: SECTION 3.6.1.8 - SUPPRESSION CIW BER-T0 DRYWELL VACUUM BREAKERS NON BRACKETED PLANT SPECIFIC CHANGES i P.1 These changes are made to NUREG 1433 to reflect Fermi 2 current l licensing basis: including design features, existing license l l

requirements and commitments. Additional rewording, reformatting, and revised numbering is made to incorporate these changes consistent with Writer's Guide conventions. ,

l l P.2 Bases changes are made to reflect plant specific design details, equipment terminology, and analyses.

P.3 Bases changes are made to reflect changes made to the Specification. I l Refer to the Specification change JFD for additional detail. I P.4 Fermi CTS contains expanded detail regarding oetermination of the closed status of vacuum breakers. This detail is relocated to the l

l Bases for SR 3.6.1.8.1. As such, the SR 3.6.1.8.1 Bases regarding non reliable or faulty position indication, and means for b

c4 verifying closed status.in this event, are revised for clarity. I

~

Since reference to alternate methods of verification are included c in more detail in SR 3.6.1.8.1 Bases, similar (but less detailed) T information is removed from Required Action B.1 Bases and replaced with a reference to the detail provided in the SR 3.6.1.8.1 Bases.

g ,

4 P.5 Editoritl Bases changes made, which are necessitated by removal of -

the RfR Suppression Pool Spray System Specification (based on not l meeting " split" criteria).

I P.6 NUREG 1433 LC0 3.6.1.8 recognizes the allowance f7 vacuum breakers to be open if performing their intended function (an exception to the l normal requirement for them to be closed). With the Fermi 2 CTS conversion, simplified presentation of the LC0 is warranted (because there is not a different number of sacuum breakers required operable from that required to be closed). With this simplification, the exception is appropriately located with the Surveillance (SR 3.6.1.8.1 Note 2). This is an editorial change only, consistent with the Writer's Guide conventions.

P.7 The reference to the IFC Policy Statement has seen replaced with a more appropriate refercnce to the Improved Technical Specification

~

" split" criteria found in 10 CFR 50.36(c)(2)(ii).

FERMI - UNIT 2 1 REVISION 5. 04/30/99l l

i

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.8 SUPPRESSION CHMBER TO DRYWELL VACUUM BREAKERS l TECHNICAL CHANGES - LESS RESTRICTIVE (Soecification 3.6.1.7 "L.1" Labeled Comments / Discussions)

Detroit Edison has evaluated the proposed Technical Specification change

' identified as."Less Restrictive" in accordance with the criteria specified by

'10 CFR 50.92 and has determined that the proposed change does not involve a l significant hazards consideration.

The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against cach of the criteria in 10 CFR 50.92. The criteria and the conclusions of the i evaluation are presented below.

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

7e s change provides exceptions allowing the vacuum breakers to be open 3

n performing Jequired Surve111ances and when performing their

..itended function (the exceptions are to the Surveillance tnat would I otherwise require the vacuum breakers to be closed at all t:mes). The ,

vacuum breakers are not assumed to be an initiator of any previously 1 analyzed accident. Therefore. this change does not involve a significant increase in the probability of an accident previously

( i evaluated. The surveillance exception is made only for circumstances where the vacuum breaker is under the immediate control of an operator (manually opening to confirm operability), or is performing its designed intended safety function (opening to relieve vacuum). As such, the vacuum breaker is expected to continue to perform its intended and assumed safety function, and therefore this change does not involve a significant increase in the consequences of an accident previously evaluated.

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

The proposed change does not ' 1troduce a new mode of plant operation and does not involve physical modification to the plant. Therefore. this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

1 FERMI UNIT 2 1 F.EVISION 5 04/30/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.1.8 SUPPRESSION CHAEER TO DRYWELL VACUUM BREAKERS j l

I TECHNICAL CHANGES LESS RESTRI(JIVE i (Soecification 3.6.1.7 "L.1" Labeled Comments / Discussions) )

3. Does this change involve a significant reduction in a margin of safety? ,

1 The change will not result in a significant reduction in a margin of T safety because the vacuum breakers are still required to be Operable. j The exception is made only for circuntstances where the vacuum breaker is under the immediate control of an operator (manually opening to confirm operability). or is performing its designed intended safety function (opening to relieve vacuum). As such. the vacuum breaker is expected to continue to perform its intended and assumed safety function, and therefore this change does not involve a significant reduction in the margin of safety.

l 1

FERMI - UNIT 2 2 REVISION 5. 04/30/99l a

DISCUSSION OF CHANGES ITS: SECTION 3.6.1.9 MSIV LEAKAGE CONTROL SYSTEM Y

LA.2 CTS 4.6.1.4.c includes details relating to methods for performing g Surveillances. These details are not included in the ITS but are relocated to the Bases. These details are not required to be in the ITS to provide adequate protection of the public health and {

safety because these details do not impact the requirement to q maintain the equipment Operable and the ITS definition for l l Operability ensures that all equipment required to maintain '

Operability is functioning. Therefore, these requirements can be adequately defined and controlled in the Bases which require change control in accordance with ITS 5.5.10. Bai;es Control Program. :

l LA.3 CTS 4.6.1.4.d. requires the verification of the pressure control l l (pressure and Ap) instrumentation to be Operable and specifically requires the performance of a Channel Check, Channel Functional Test and Channel Calibration of this pressure control instrumentation. ITS 3.6.1.9 Surveillance Requirements require the

! MSIV LCS to be Operable, but does not explicitly require the performance of a Channel Check, Channel Functional Test or Channel Calibration of this pressure control instrumentation. This is acceptable because this instrumentation is required to be Operable to support the Operability of the MSIV LCS, and therefore. is implicitly included in the ITS requirement to maintain the MSIV LCS Operable. However, since the MSIV LCS is a manually actuated system, the reliance on this instrumentation is less critical than y for automatically actuated functions credited for accident g mitigation. Therefore, these requirements will be adequately 4 defined and controlled in the Technical Requirements Manual, which requires change control in accordance with 10 CFR 50.59.

lg FERMI - UNIT 2 2 REVISION 5. 04/30/99l l

7 l Suppression Pool Average Temperature 3.6.2.1 3.6 CONTAINMENT SYSTEMS l 3.6.2.1 Suppression Pool Average Temperature LC0 3.6.2.1 Suppression pool average temperature shall be:

pl a. s 95*F with THERMAL POWER > lt RTP and no testing that adds heat to the suppression pool is being performed:

1" b. s 105'F with THERMAL POWER > 11 RTP and testing that

$l adds heat to the suppression pool is being performed; and I c. s 110*F with THERMAL POWER s it RTP.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Suppression pool A.1 Verify suppression Once per hour average temperature pool average

> 95*F but s 110*F. temperature s 110*F. i a e i THERMAL POWER A.2 Restore suppression 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months !

> 11 RTP. pool average temperature to a s 95 F.

Not performing testing that adds heat to the i suppression pool. '

(continued) i I

1 i

l I

l FERMI UNIT 2 3.6 24 Revision 5 04/30/99 ;

l l

l 1

l l l

Suppression Pool Average Temperature 3.6.2.1 ACTIONS (continued) !

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ylg associated Completion Reduce THERMAL POWER to s it RTP.

l

- Time of Condition A :

g not met.

C. Suppression pool C.1 Suspend all testing Immediately !

average temperature that adds heat to the

> 105*F. suppression pool. l M

THERMAL POWER > lt RTP.

E Performing testing that adds heat to the suppression pool.

D. Suppression pool D.1 Place the reactor i [mmediately average temperature mode switch in the l > 110*F but s 120*F. shutdown position.

N @

l

l D.2 Verify suppression Once per pool average 30 minutes '

I temperature s 120 F.

M D.3 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued) l FERMI - UNIT 2 3.6-25 Revision 5. 04/30/99 i

1 1

Suppression Pool Average Temperature l 3.6.2.1 l ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Suppression pool E.1 Depressurize the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months average temperature reactor vessel to l

> 120*F. < 200 psig. I d E a

( E.2 Be in. MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1.1 Verify suppression pool average 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months temperature is within the applicable limits. MLQ 5 minutes when performing testing that adds heat to the suppression pool l FERMI UNIT 2 3~6 26

. Revision 5, 04/30/99

i i

Suppression Pool Average Temperature B 3.6.2.1 BASES l

APPLICABLE SAFETY ANALYSES (continued) assumed for the Reference 1 and Reference 2 analyses.

Reactor shutdown at a pool temperature of 110*F and vessel ,

depressurization at a pool temperature of 120*F are assumed l for the Reference 2 analyses. The limit of 105'F. at which '

testing is terminated. is not used in the safety analyses l because DBAs are assumed to not initiate during unit l testing. I Suppression pool average temperature satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

LC0 A limitation on the suppression pool average temperature is required to provide assurance that the containment conditions assumed for the safety analyses are met. This limitation subsequently ensures that peak primary containment pressures and temperatures do not exceed maximum allowable values during a postulated DBA or any transient ,

resulting it, heatup of the suppression pool. The LC0 l requirements are:

a. Average temperature s 95*F with THERMAL POWER > 11 l RATED THERMAL POWER (RTP) and no testing that adds heat g to the suppression pool is being performed. This

, requirement ensures that licensing bases initial conditions are met.

Ij

b. Average temperature s 105'F with THERMAL POWER > lt RTP and testing that adds heat to the suppression pool is being performed. This required value ensures that the unit has testing flexibility. and was selected to provide margin below the 110*F limit at which reactor shutdown is required. When testing ends, temperature must be restored to s 95'F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months according to Required Action A.2. Therefore. the time period that the temperature is > 95"F is short enough not to cause g a significant increase in unit risk.

$l E

c. Average temperature s 110*F with THERMAL POWER s it RTP. This requirement ensures that the unit will be shut down at > 110*F. The pool is designed to absorb decay heat and sensible heat but could be heated beyond design limits by the steam generated if the reactor is not shut down.

l FERMI - UNIT 2 B 3.6.2.1 - 2 Revision 5. 04/30/99

Suporession Pool Average Temperature B 3.6.2.1 BASES ACTIONS (continued)

E.1 and E.2 If suppression pool average temperature cannot be maintained at s 120*F. the plant must be brought to a MODE in which the LC0 does not a) ply. To achieve this status, the reactor pressure must )e reduced to < 200 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and g the plant must be brought to at least MODE 4 within i 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable.

based on operating experience, to reach the recuired plant kl conditions from full power conditions in an orcerly manner and without challenging plant systems.

Continued addition of heat to the suppression pool with suppression pool temperature > 120*F could result in exceeding the design basis maximum allowable values for primary containment temperature or pressure. Furthermore, if a blowdown were to occur when the temperature was

> 120*F. the maximum allowable bulk and local temperatures could be exceeded very quickly.

SURVEILLANCE SR 3.6.2.1.1 REQUIREMENTS The suppression pool average temperature is regularly monitored to ensure that the required limits are satisfied.

The average temperature is determined by taking an arithmetic average of OPERABLE suppression pool water temperature channels. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency has been shown, based on operating experience, to be acceptable. When heat is being added to the suppression pool by testing, however, it is necessary to monitor suppression pool temperature more frequently. The 5 minute Frequency during testing is justified by the rates at which tests will heat up the suppression pool, has been shown to be acceptable based on operating experience, and provides assurance that allowable pool temperatures are not exceeded. The Frequencies are further justified in view of other indications available in the control room, including alarms, to alert the operator to an abnormal suppression pool average temperature condition.

REFERENCES 1. UFSAR. Section 6.2.

2. UFSAR. Section 15.1.4.

j. FERMI UNIT 2 B 3.6.2.1 - 5 Revision 5 04/30/99

98 / PlcA 170A 16.'2-. l A lso see_ Sp4dAca &>> 7.t,. / . / ) i CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION SYSTEMS

['l NO 54.4 6/4N[kabih 3.6.2.2.)

\ i i

SUPPRESSIDH CHAMBER LIMITING CONDITION FOR OPERATION l L.C O 3.6.2.1 b h- <"-Ch^' '^

0"E"'* 3 1th:

a. The )ool water:

1. ~ Volume between 121.080 ft3 and 124,220 ft3 , equivalent to a 5 4 Spect reak- (level between

(+2 inches 14'4" indicationi and(-2a inches indication) and 14'8" c 3'b'E' 2. Ma_xtmum average temperature of 95'Fidurino OPERATIONALN >1'l.( !

$,(2.l /,(o /M A. (CONDITION 1 or 2,_excep,tt,that the maximum average temperature !

W may be permitted to increase to:

go % g, a) 105'F during testing which adds heat to the suppression $"' Q chamber.

b) 110 F with IIHERMAL POWER less than or equal to 1% of) '

LCo lluu C,. (RATEDTHERMALPOWER.; g, ,3 3

ACT70/3 01 lE~ FMaximum VONDITION N, except average twr"-average that the maximum nuretemperature or m durinn may normartnuar be permitted to increase to 120*Fm- '-e em etamm i t n a_ -

Ocl;tc. =l=: :le;;41following a scram, b A total leakage oetween the suppression chamber and drywell of less Socihcobo" b. than the equivalent leakage through a 1-inch diameter orifice at a ,

3 6 ld differential oressure of approximately 1 psid. I APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION: !

a. With the suppression chamber water level outside the above limits, Set- restore the water level to within the limits within I hour or be in Spec \(itah,er at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN :

3 . (., . *L . '2- within the followino 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 'l:

With the suppression chamber average water temperature greater than Acriorj 4 95'F, restore the average temperature to less than or equal to 95'F 4 '2. i l

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least SiOT 5HUIDOWN within the nextN iz nours anc in LULD SHUIDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , except)

AC M O as cermitted above %s "/o RJ P J. *"' i

1. With the suppression chamber / average water temperature greater I ACTioel C than 105'FvduFi~n'g"Hsting* wh'ich adds heat to the suppression f chamber, stop all testing which adds heat to the suppression

, _ _ _ .. _chambe.r,Olid restore the average temperature to less than 95'F i within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at leastjHOI >HUluuwn wnnin 6ne nexp A cTiew A SCW N O (T2 hours and in L.utu ususuoWN within the followino 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. With the suppression chamber average water temperature greater gg than:

95'F for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and THERMAL POWER greater NA a) than 1% of RATED THERMAL POWER, be in at leastJdTl ACT10t) 0 fg 7 ,-

/}CTlo fj p b) 110*F, place the reactor mode switch in the Shutdown position ana op ate at lea _s yone residuay heat rep 6vaW D '

i Goop v1 t1e s jorossion DooY coolino modL/

3. With the suppression chamber average water temperature greater 4CUOM g than 120*F, depressurize the reactor pressure vessel to less than 200 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

O D.5 \ Ml fA00:Reawezo AcnorJ FERMI - UNIT 2 8EavonD Acm> E<2/

3/4 6 15 l4 1 i

PAGE OF 03 /f w 5' 4

$pEufic-Attee 3.G,.2.,l N h CY lCO & 3.G.f.l )

.5D

MIb (4 MM 3 0 "Le7-Gl[IU NMENT 5YSTEMS LIM TING CONDITION FOR OPERATION (Continued)

EL gt: (Continuec) _

'. . .na6rumentation channe

c. r with one supprus on pavi wasur s. w..

inoperable, ve fy suppression pool w er temperature to within limits at le t once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

1. If SRV actuation has oc rred since the ch el was d ared inoperable, the verage suppression col water erature shall be c uted as follows: e maximum lg temperatura indicati of the seven OPE E channels shall be gl i used as the tempera re indication of t inoperable channel in computing the pool.

erage water temper ure in the suppressio { (-

l 2. If an SRV a untion has occurred ince the channel was declared operable, for a per d of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months followin he SRV act tion, the average s ression pool water t rature shall e computed as follow . The maximum temperatu ind ation of the seven 0 BLE channels shall be neressed by 5'F-and shall be use as the temperature indi ion of the operable channel in mouting the average wat temperature n the suppression p 1. After 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months tne a rage water temperature snali computeo as described i action col.

l d. th more than one s pression pool water temper ure s instrumentation ch el inoperable, restore at east seven temperature inst entation channels to OPE E status within ours or be in least HOT SHUTDOWN withi he next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months nd in; OLD SHUTDOWN, ithin the following 24 hou

e. With one narrow range suppression chamber water level instrumentation enannel inoperable, restore the inoperable narrow g range suppression enamber water. level channel to OPERABLE status L' Iwithin 7 days or verify suppression pool water level to be within

$pedfic8 TIM the limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

3.G .2. l2.-

f. With both narrow range suppression chamber water level instrumentation channels inoperable, restore at least one suppression chamber water level channel to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUT 00WN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in (COLD SHUTDOWN within the*following 24 h6urs.

g. With the drywell-to suppression chamber leakage in excess of the 5f e icd 6 limit, restore the bypass leakage to within the limit prior to 3.f .hl increasing reactor coolant temperature above 200*F.

SURVEILLANCE RE001REMENTS 9 4.6 1 In rassion enamoer snali ce oemonstrateo OPERABLE:

w r,d'e 31,,1. . verifying the suppression chamoer water volume to be within the at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in OPERATIONAL CONDITION 1 or 2 by R M.2.4. ) verifying the suppression chamber average water temperature to be less than or equal to 95'F, execpt: 4 FERMI - UNIT 2 3/4 6-16 ,

1 PAGE A OF 03 fev s'

> G 2.l S fecifica%rt (So $e,C, %d'cibdort b ,j,l C Atso se gecif;cdon u 24 l CONTAI RENT $ 1851 1 SURVEILLANCE KEDUIkM81tTS (Continued) '

1. At least once per 5 minutes during testing which adds heat to G R, 3. /,,1.. ).1 the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105Y.

4 , 2. At igast once per hour when suppression chamber average water temperature is greater than or equal to 95T, by verifying:

g gdMott, Suppression chamber average water temperature to be less A.\ 4) than ar aa"al to 1104. and b) N RMAL POWER to be less than or equal to 1% of RATED , b.3 THERMAL POWER after suppression chamber average water temperature has exceeded 95T for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. At least_ once per 30 minutes in OPERATIONAL CONDITION 3 followine a legpgregn scram un auppression chamber average water temperature greater L'g' D .'t a or equal to 957, by verifying suppression chamber avera0e ater temperature less than or equal to 120T. -

^

external ' ua1 examinati f the su ession ch r after

d. By ety/rel valve operat ith the ression r aver e k.7 water erature grea han or to 160*F reactor olant sy a pressure gr r than 20 sie. _

@ At least once per 18 months by a visual inspection of the accessible interior and exterior of the suppression chamber.

S hecib 3'/,,l.l g e.- By veri ing eight -

ression pool ater temperature N i ff. y performan of a: gr)

) ins ntation CHANNE annels OPERAB ECK at less ce per 24 h ,

[nA I i 3.

. C FUNCTIONAL EL Call 8RA at T at least least e per e per 31 e 18 and water high temoerature alarm <='aaint' for < 10S*F., with [the

/

j ik'

g. y verifying both narrow range suppression chamber water level instrumentation channels OPERABLE by performance of a:

1. CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

. e

) 68',' 2. CHANNEL FU'1CT10NAL TEST at least once per 31 days, and k,tob {3. CHA8fMEL CAllBRATION at least once pea 18 months, j eC thC l With the water level alarm setpoint for: )

. l. 2.1 l

1. High water level 514'8' - l

2. Low water level 2 14'4" (TWMS Narrow Range) 1

h. t least once per 18 months by conducting a drywell-to suppression !

ghamber c bypass leak test at an initial differential pressure of x

1 psi and verifying that the differential pressure does not decrease by more than 0.20 inch of water per minute for a period of 10 minutes. If any drywell to suppression chamber bypass leak test l

$6 gn falls to meet the specified limit, the test schedule for subsequent t

ec &a tests shall be reviewed and approved by the Commission, if two f i consecutive tests fail to meet the specified limit, a test shall be

$tP t, \ performed at least every 9 months until two consecutive tests meet the specified limit, at which time the 18 month test schedule sty be resumed.

FERMI - UNIT 2 3/4 6 17 PAGE_1 0F 03 gy F

DISCUSSION OF CHANGES ITS: SECTION 3.6.2.1 - SUPPRESSION POOL AVERAGE TEMPERATURE !

l TECHNICAL CHANGES MORE RESTRICTIVE !

M.1 CTS 3.6.2.1. Action b.2. requires a reactor scram if average pool f temperature is > 110"F. and Action b.3 requires depressurizing the reactor to 200 psig if average pool temperature > 120 F. With these actions completed. the reactor renains in Mode 3 with no further action required. ITS Required Actions D.3 and E.2 are provided to N

require continuation of the plant . shutdown to Mode 4. This more l k' restrictive change is acceptable because it does not introduce any unanalyzed operation, while requiring an appropriate conservative response. .

l TECHNICAL CHANGES LESS RESTRICTIVE

" Generic" LR.1 CTS 3.6.2.1. Action b.2. requires operation of "at least one residual heat removal loop in the suppression pool cooling mode" when suppression pool average temperature exceeds 110 F. The requirement is not required to remai6. in the Technical Specifications for suppression pool temperature, because this !

activity must be coordinated with other operator actions that may i be required when suppression pool average temperature exceeds 110 F. This change is acceptable because efforts would be under l way to reduce temperature to the extent practical whenever suppression pool temperature is above 95 F. However, circumstances could dictate that RHR subsystems be dedicated to functions other than suppression pool cooling. These more prudent uses of RHR could include ECCS injection or removing decay heat directly from the reactor coolant using the Shutdown Cooling Mode of RHR. Operating procedures that consider more than simply l enforcing suppression pool temperature limits will direct the activities necessary to return the plant to a safe stable configuration. A Technical Specification requirement to render an ECCS system inoperable by requiring it to be placed in the l suppression pool cooling mode of operation may not be prudent under all circumstances. Regulatory control of changes to these requirements (e.g.. Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the i public health and safety since the Technical Specifications !

continue to mandate maintenance of suppression pool temperature to kss than 95 F.

FERMI UNIT 2 2 REVISION 5. 04/30/99l

DISCUSSION OF CHANGES l ITS: SECTION 3.6.2.1 SUPPRESSION P0OL AVERAGE TEMPERATURE l 4

CTS 3.6.2.1. Action c and d. and surveillance 4.6.2.1.f. Y LA.1 establish. Actions and Surveillance Requirements for the instrumentation used to monitor suppression pool temperature.

lh i This instrumentation performs an alarm only or indication only function, performs no automatic function and is not assumed in any event that depends on operator action. Alarm only and indication-only functions do not necessarily relate directly to the Operability of the related systems. ITS 3.6.2.1 require that the suppression pool temperature be maintained, but do not specify the requirements for the instrumentation. These requirements are relocated to the TRM. where changes are controlled by 10 CFR 7 50.59. These requirements are not necessary to be in the Technical Specifications to provide adequate protection of the public health and safety since the Technical Specifications I continue to mandate maintenance of suppression pool temperature to less than 95 F.

TECHNICAL CHANGES LESS RESTRICTIVE "Speci fic" L.1 CTS 4.6.2.1.c requires verification at least once per 30 minutes that suppression chamber average water temperature is s 120 F following a scram when suppression chamber average water temperature is 2 95 F. ITS 3.6.2.1. Required Action D.2. requires this verification every 30 minutes only if suppression pool temperature is > 110 F. Not starting the verification of temperature at 30 minute intervals until the temperature is

> 110 F is acceptable because the intent is to ensure that suppression pool average temperature does not exceed 120 F.

Operator knowledge of plant conditions that could result in rapid heating of the suppression pool and the ITS requirement to monitor the temperature every 30 minutes once the temperature is > 110 F provides a very high degree of assurance that operators will identify the condition and take 'ppropriate action before the suppression pool temperature exceeds 120 F.

L.2 CTS 4.6.2.1.d requires an external visual examination of the suppression chamber after an SRV discharge while average pool water temperature is 2 160 F and RCS pressure is > 200 psig. This requirement is deleted. NED0 30832. " Elimination of Limit on BWR lT Suppression Pool Temperature for SRV Discharge with Quenchers." E December,1984, provides an NRC approved evaluation to justify lT FERMI - UNIT 2 3 REVISION 5 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE i raising the suppression pool temperature limits. While this i specific change is not being sought in Fermi 2 ITS. this reference ]

(and the corresponding NRC SER) provides a conclusion that SRV ]

discharge quenchers (which are installed in Fermi 2) are effective in reducing excessive loading on the suppression pool structure.

y j

~

This reduction in excessive loading is the basis for eliminating the subject visual examination, a I

L.3 CTS 3.6.2.1 a.2 and a.3 present requirements inconsistent with the intended limitations on suppression chamber water temperature.

CTS 3.6.2.1.a.2 limits the temperature to s 95 F only when in Mode 1 or 2 with thermal power > lt RTP: allowing a 110*F limit when s it RTP. CTS 3.6.2.1.a.3 imposes a 95*F limit during Mode 3 J (which is always s it RTP). and does not allow the post scram ;

exception for a 120 F limit when an MSIV is open. Therefore, the j CTS only allow the 110 F limit during the brief period in Mode 2 l but s it RTP. ITS 3.6.2.1 allows the 110*F limit at all times !

s it RTP. Also with this change. CTS 4.6.2.1.2.b), which presents !

a surveillance to verify thermal power to be s it RTP when l temperature is >95*F for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , is eliminated. Since the ITS '

requires temperature to be restored to s 95*F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . or i power reduced to s 11 RTP. no periodic confirmation that this action l is being complied with is deemed necessary in the ITS. l Historically the STS that the Fermi original license was based on the majority of other licenses issued with STS based Technical Specifications, and the NRC approved and issued STS NUREG 1433.

all allow the 110 F limit during all of Mode 3 (i.e., at all times s it RTP). These precedents support the engineering judgement that allowing the temperature limit to increase from 95 F to 110 F during all operation at s it RTP. and increased frequency of verifying that power remains s it RTP will not result in any significant impact on safety.

RELOCATED SPECIFICATIONS 1

-None l

l 1

FERMI ' UNIT 2 4 REVISION 5 04/30/99l

_h

DISCUSSION OF CHNEES ITS: SECTION 3.6.2.1 SUPPRESSION P0OL AVERAGE TEMPERATURE ,

l TECHNICAL SPECIFICATION BASES l

The CTS Bases for this Specification have been replaced by Bases that reflect l the format and applicable content of ITS 3.6.2.1 consistent with the BWR STS. I NUREG 1433. Rev. 1. l l

1 l

l l

FERMI UNIT 2 5 REVISION 5. 04/30/99l[

i Suppression Pool Averaga Temperature 3.6.2.1 ;

3.6 CONTAINMENT SYSTEMS

[dTS 3.6.2.1 Suppression Pool Average Temperature <3.C,.2.1 LCO 3.6.2.1 Suppression pool average temperature shall be:

^-^: ""-

g[ghWC.

a*

5.k_.9 5. f

F:;',;m ,r. i. .'T.

^'.'.*"...' T. n.

3. ..'..:

-- r .:,;.

C. . ; _. M. . .r. ._._.:-

. v.,..... ,m__ . _,y . ..

,g jbw(ft }l% gfP h.Y,.7andnotest<ngthataddsheattothesuppression poo is being performed; 8. ;

'g b. s $105Y'F ..* :.. n, ^FERA0LC !"" d.ea..:1 h ; Y25/40,8 - to a,2h di'. i:h .: Of Sl' ::.le :. ".r;: i and testing that adds j heat to the suppression pool is being performed; and c-

...-----.---...____,___m,... Lto al.b))

G...H.%....,1__=.. .. =... n.... m... v.. =..,vn_-_

i$ AL(0VRf19e RTP 4 APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Suppression pool A.1 Verify suppression Once per hour average temperature pool average

> ;95KF but temperature (Y.62.I.b.7

$ (110{ F. s p10)/F.

m *pr4MWI a

-Any OPCRACLE IRT- A.2 Restore suppression 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3.G,.2.1, Acm%

[ {g - Q.=a ', { QS/-p pool average temperature to h b.h b.2.4 q o . u i vi.. .. . ..

-seek c6 "=g: 7;- f QSyF.

m flot perfoming testing that adds heat to the suppression pool.

(continued)

.DWRf4-GTS 3.6-31 RevAr-041&Tf95

.Y

Suppression Pani Averaga Temperature 3.6.2.1 1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and 8.1 Reduce THERMAL POWER 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i associated Completion Time of Condition A ,33jl .l! pT:;;;AL nn un.on.i.

y,g,2,;) g5 not met. Q Sj'G k djJ u h..:- 4 00C 4'?-

p_.virscowon

"'" ~

l?oR --

f,g i C. Suppression pool C.1 Suspend all testing Immed'iately I average temperature that adds heat to the

>Q05{F. suppression pool. (3,4 7,g, go,a u)

M

-Ai,y ;?i;;h k e u m f 'fjernulfower-N9i l

> $$36[i- ) i % 8TP 'hEg

w a y 3 3 i Utl4 UI IW5l

---seelv cr. Rer.ge 7.'

O l Performing testing that adds heat to the suppression pool.

l D. Suppression pool D.1 Place the reactor Immediately average temperature mode switch in the y,c.2.g, t co a,3 but shutdown position. 3,g.g up.ta(-

M <~4

.L D.2 Verify suppression pool average Once per q 30 minutes i temperature (y,y,2 /, c_

s(120rr.

M D.3 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Doc. Al')

(continued)

BWR/44TS 3.6-32 Rs. 1,-05/07/45 et/5

Suppression Pool Average TempGrature 3.6.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 4

E. Suppression pool E.1 Depressurize the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months average temperature reactor vessel to .G.21 bog bS)

>f120gF. <g00gpsig. /

m l N

E.2 Be in MODE 4. g6hoursA

<Coc M} \h SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY j 1

.SR 3.6.2.1.1 Verify suppression pool average 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (4.6.2.(, b temperature is within the applicable limits. M l 1

5 minutes when l performing testing that ,

adds heat to l the suppression Pool (V.621.b.l 86 3.6-33 dieud , ^'/n?/ E

[N

Suppression Pool Average Temperature B 3.6.2.1

. l

. BASES (continued) l APPLICABLE The postulated D8A against which the primary containment SAFETY ANALYSES performance is evaluated is the entire spectrum of postulated pipe breaks within the primary containment.

Inputs to the safety analyses include initial suppression I pool water volume and suppression pool temperature 1

-(Reference for LOCAs and Reference 2 for the pool .

p, t.mperatu m= e e = - = m . An inittai pool temp ture of 951*F is assumed for the Reference 1 andReference2 anal)yses. Reactor shutdown at a pool I temperatureof$1 F and vessel depressurization at a pool I temperature of>t12 F are assumed for the Reference 2 l analyses. The ' limit of $105)*F, at which testing is j terminated, is not used in the safety analyscs because DBAs '

are assumed to not initiate during unit testing.

Suppression pool average temperature satisfies Criteria 2

.g'q ' ;4R0 Foi ii.y n... I and3o$f0 cf! 50.%(c)(af5 ) '

l LC0 A limitation on the suppression pool average temperature is i required to provide assurance that the containment l conditions assumed for the safety analyses are met. This i limitation subsequently ensures that peak primary I containment pressures and temperatures do not exceed maximum .

allowable values during a postulated DBA or any transient resulting in heatu d tha <Snnra " inn neol. The LCO requirements are: HA wnmu poses. > / % Wre 7WBAM I Fou/Frc (grP

a. Average temperature s2:95FF . ..= x; 0F:rn. - i t) p*g -i. t. ;i i. . y. -.. ter (!%9 J......el 1e ; " b l

--4Hvisione of f;i eeele e,. Rer.;; 7 and no testing that

/'0K ),, '

adds heat to the suppression pool is being performed.

This requirement ensures that licensing bas s initial conditions are met. ggg3tggyj e4 g7p y

b. Average temperature s N -..... .. y vr uwwu. . --

,ob

53 ;;,1 i:-: f*S/'.O d.';i; .r.; ef fell ;; ele ...

F' e 7 and testing that adds heat to the suppression "rlisbeingperformed.

poo This required value ensures I that the unit has testing flexibility, and was selected to provide margin below thed410*}?F limit at which reactor shutdown is required. yhen testing ends, temperature must be restored to $>f95FF within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months according to Required Action A.2. Therefore, the time period that the temperature is > 4853'F is (continued)

BWR/t US- B 3.6-59 h r 1 # 107195-

Suppression Pool Average Temperature B 3.6.2.1 BASES LC0 short enough not to cause ignificant increase in (continued) unit risk. ;mg pg g g gp -

c. Average temperature 1 4110 T ;= 3 " '"' .!j .. . g

'b ' - - - - > - ---- - ------

tr.e '. This requirement ensures that the unit will. N i

be shut down at > 41109'F. The pool is designed to absorb decay heat and sensible heat but could be Q heated beyond design limits by the steam generated if I the reactor is not shut down. I Note that;f25/40Fdivisions of full scale on IRM Range 7 is a convenient measure of when the reactor is producing power essentially equivalent to 1% RTP. At this power level, heat input is approximately equal to normal system heat losses.

l APPLICA8ILITY In MODES 1, 2, and 3, a 08A could cause significant heattp of the suppresrion pool. In MODES 4 and 5, the probability and consequencas of these events are reduced due to the pressure and temperature limitations in these MODES.

Therefore, maintaining suppression pool average temperature within limits is not required in MODE 4 or 5.

l ACTIONS A.1 and A.2 l

With the suppression pool average temperature above the specified limit when not performing testing that adds heat to the suppression pool and when above the specified power indication, the initial conditiens exceed the conditions f./y - assumed for tht/ Refer te 1, 2. cr.d 4 analyses. However, primary containment cooling capability still exists, and the primary containment pressure suppression function will occur at temperatures well above those assumed for safety analyses. Therefore, continued operation is allowed for a limited time. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is adequate to allow the suppression pool average temperature to be restored below the limit. Additionally, when suppression pool temperature is > $95FF, increased monitoring of the suppression pool temperature is required to ensure that it remains G104*F. The once per hour Completion Time is adequate based on past experience, which has shown that pool temperature increases relatively slowly except when testing (continued)

"""/' !?S B 3.6-60 Rev 1, O'/07/05

Suppression Pool Averaga Temperature 8 3.6.2.1 BASES ACTIONS D 1 and D. (continued) experience. Given the high suppression pool average temperature in this Condition, the monitoring frequency is increased to twice that of Condition A. Furthemore, the 30 minute Completion Time is considered adequate in view of other indications available in the control room ' O.A;;..,

f,L # - ,Toalerttheoperatortoanabnormalsdpression pool average temperature condition.

E.1 and E.2 If suppression poc1 average temperature cannot be maintained at $4J20$'F, the plant must be brought to a M00E in which the LCO does not apply. To achieve this status, the reactor pressure must be reduced to <,1200fasig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and the plant must be brought to at least MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Tites are reasonable, G based on operating experience, to reach the required plant w conditions from full power conditions in an orderly manner W and without challenging plant systems. ,%

Continued addition of heat to the suppression pool with ,

suppression pool temperature >:$120FF could result in exceeding the design basis maximum allowable values for primary containment temperature or pressure. Furthermore, if a blowdown were to occur when the temperature was

> T120TF, the maximum allowable bulk and local temperatures could be exceeded very quickly.

SURVEILLANCE SR 3.6.2.1.1 REQUIREMENTS The suppression pool average temperature is regularly monitored to ensure that the required limits are satisfied.

The average temperature is determined by taking an arithmetic average of OPERABLE suppression pool water temperature channels. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency has been shown, based on operating experience, to be acceptable. When heat is being added to the suppression pool by testing, however, it is necessary to monitor suppression pool temperature more frequently. The 5 minute Frequency during testing is justified by the rates at which tests will heat up the.

suppression pool, has been shown to be acceptable based on (cont 4nued)

=*/' HS 8 3.6-62 Aav 1 ^*/07/95

l JUSTIFICATION FOR DlFFERENCES FROM NUREG 1433 ITS: SECTION 3.6.2.1 - SUPPRESSION P0OL AVERAGE TEMPERATURE l

NON-BRACKETED PLANT SPECIFIC CHANGES l P.1 Not used.

l l P.2 Bases changes are made to reflect plant specific design details. -

i equipment terminology, and analyses. Specifically, in this l Condition. Fermi 2 design has no additional alarms that may alert 3 the operator to further increases in temperature.

\

I P3 Not used. lb-g P.4 Not used. lk j l li Editorial presentation preference to simplify Bases presentation P.5 !

of References. Generic references are sufficient in this context.

P.6 Editorial Bases corrections made. Since there is no ~ requirement" l for a normal cooldown per the associated Action, the sentence is revised to more accurately reflect the intent. j P.7 Bases for Required Action D.3 are missing from the NUREG. and are 1 added for completeness.

P.8 The NUREG is revised to replace the specific mechanism to monitor core power (IRM range 7), with the intended power level

(11 RTP"). This presentation is also consistent with CTS. l l

I FERMI - UNIT 2 1 REVISION 5. 04/30/99l

SpecihEL l5n 3. L 2 2 l$ O Sc e $PCCkcabON$ S$ $* $

0)L8 % $*1.

COM"A"NMENT SYSTEMS

llM T' NG CONDITION FOR OPERATION (Continued) l AGLQ!1: (Continueo;

g. With one suppression pool water temoerature instrumentation channel inoperable, verify suppression pool water temperature to be within l

limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

1. If nor SRV actuation has occurred since the channel was declared inoperable, the average suppression pool water l temperature shall be computed as follows: The maximum i temperature indication of the seven OPERABLE channels shall be l used as the temperature indication of the inoperable channel i in computing the average water temperature in the suppression l pool. j

2. If an SRV actuation has occurred since the chunnel was I declared inoperable, for a period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months following the g SRV actuation, the average suppression pool water temperature n

o, shall be computed as follows: The maximum temperature indication of the seven OPERABLE channels shall be increased

"( l by 45'F-and shall be used as the temperature indication of the j g[S . , .\ inoperable channel in computing the average water temperature I s in the suppression pool. After 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months tne average water j temperature shall be coputeo as described in action c.1. I 1

d. With more than one suppression pool water temperature l instrumentation channel inoperable, restore at least seven I temperature instrumentation channels to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUT 00WN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l

,e hthonenarr range suppression chamber water level ),

instrumen ion channel noperable, res re the inoperabi narrow bN range s pression ch er water lev channel to OPE status with 7 days or rify suppress pool water lev to be within t limits at ast once per ours.

f 6 With both arrow range sy ression chambe ater level inst tation chann M inoperable, re) are at least on supp sion chamber ater level chanpel to OPERABLE s us within 8 ,

ho or be in a east HOT SHUT 00,WN within the nex 2hoursandinj l Q0LDSHUTDOWNw'thinthe*following24h6urs. c .

Sec g. With the drywell-to suppression chamber leakage in excess of the limit, restore the bypass leakage to within the limit prior to 6 y M. . \,\ g increasing reactor coolant temperature above 200*F. LA.1 !

SURVEILLANCE pE0VIREMENTS 4.6.2.1 Ine suppression cnamoer snall oe oemonstrateo OP RABLL- [e y e[,

a. By verifying the suppression chamoer water 4 o be within the

{R3.6.2.2.I b.

limits at 11ast once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in OPERATIONAL CON 0! TION 1 or 2 by verifying the suppression chamber average water temperature to be less than or equal to 95'F except:

SCOgfQ W.

, (, .1 \

FERMI - UNIT 2 3/4 6-16 PAGE b 0F 05 <

1

S e e c 4 co h c,n 3. G . 2. 2

&lso see specdkhrt 36.I.D Go St.t yeciOCokio!"l 3'6*2.I CONTAlletENT SYSTEMS l SURVEILLANCE REQUIREMENTS (Continued)

1. At least once per 5 minutes during testing which adds neat to the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105*F.

2. At igast once per hour when suppression chamber average water temperature is greater than or equal to 95*F by verifying:

a) Suppression chamber average water temperature to be less than or equal to 110*F, and b) ThERNAL POWER to be less than or equal to 1% of RATED THERMAL POWER after suppression chamber average water temperature has exceeded 95*F for more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c6 ,

c. At least once per 30 minutes in OPERAT10KAL CON 0! TION 3 following a scram with suppression chamber average water temperature greater !

'(, .N than or equal to 95*F, by verifying suppression chamber average water temperature less than or equal to 120*F.

> ) t

)

d. By an external visual examination of the suppression chamber after safety / relief valve operation with the suppression chamber average water temperature greater than or equal to 160*F and reactor coolant f system pressure greater than 200 psig.

e. At least'once per 18 months by a visual inspection of the accessible Gud'h interior and exterior of the suppression chamber.

3,\

j

. By verifying eight suppression pool water temperature instrumentation channels OPERABLE by performance of a: )

54 1 1. CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , CHANNEL FUNCTIONAL TEST at least once per 31 days, and 2.

fQg$W @g 3. CHANNEL CALIBRATION at least once per 18 months, with the water high temperature alarm setpoint for 5105*F. 'g rifying b h narrow ran suppressio. haaber w, r1 l. ,) . b I 9 .' B ormance 'a:

nstrumentat channel RABLE by

1. C EL CHECK p ast once 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ' {

2. HANNEL FUN 0:4AL TEST a east onc er 31 days and t CHANNEL IBRATION at ast once 18 month f setpoin or: !

With the ter level a -

I

1. gh water lev $ 14'8* y

2. ' Low water level 214'4* $ Narrow Range; f j I. At least once per 18 months by conducting a drywell-to suppression chamber bypass leak test at an initial differential pressure of I 1 psi and verifying that the differential pressure does not decrease f b& by more than 0.20 inch of water per minute for a period of ;

['g(DW

. 10 minutes. If any drywell to-suppression chamber bypass leak test t c' eD fails to meet the specified limit, the test schedule for subsequent ,

tests shall be reviewed and approved by the Consission. If two j o g,1,} consecutive tests fail to meet the specified limit, a test shall be j D' performed at least every 9 months until two consecutive tests meet j the specified limit, at which time the 18 month test schedule may be i resumed.

FERMI - UNIT 2 3/4 6 17 PAGE 6 0F 05 J

gg

c DISCUSSION OF CHANGES ITS: SECTION 3.6.2.2 - SUPPRESSION POOL WATER LEVEL LA.2 CTS 3.6.2.1 Actions e and f. and Surveillances 4.6.2.1.g. j establish Actions and_ Surveillance Requirements for the instrumentation used to monitor suppression pool level. This i instrumentation performs an alarm only or indication-only function, performs no automatic function and is not assumed in any event that depends on operator action. Alarm only and indication- d only functions do not necessarily relate directly to the f

l l Operability of the related systems. ITS 3.6.2.2 requires that the suppression pool level be maintained, but does not specify the

$ l requirements for the instrumentation. This is acceptable because the monitoring instrumentation, as described above does not impact the requirement to maintain suppression pool level. These items are relocated to the TRM where changes are controlled by 10 g

CFR 50.59. ITS control of these items is not necessary to provide adequate protection of the public health and safety since the Technical Specifications continue to require suppression pool

. level be maintained.

TECHNICAL CHANGES - LESS RESTRICTIVE

" Specific" l l

L.1 CTS 3.6.2.1, Action a and CTS 3.5.3, Action a. both require that when suppression pool water level is not within required limits '

when in Modes 1, 2. and 3 that it must be restored "within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months " l or the reactor must be shutdown within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

l Under the same conditions, ITS 3.6.2.2, Required Action A.1, allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to restore suppression pool water level to within limits or the reactor must be shutdown within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . An unplanned change in suppression pool level requires that the cause be identified and addressed, and that the appropriate system be aligned to raise or lower the pool level.

These activities may require longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to accomplish.

This change is acceptable because any level change is expected to occur slowly and be discovered with only a minimal deviation from the required level. Therefore, with water level below the minimum level, it is expected that the pressure suppression function, as l

well as sufficient ECCS NPSH and recirculation flow, still exists.

l If suppression pool level is above the maximum level, protection against overpressurization still exists to the extent that there is margin in the peak containment pressure analysis coupled with the capability of the drywell spray system. Therefore, continued

! operation for a limited time is allowed. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion FERMI UNIT 2 2 REVISION 5. 04/30/99l l

[T !

RHR Suppression Pool Cooling 3.6.2.3 1 i

l l 3.6 CONTAINMENT SYSTEMS '

3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling i j

l I

LC0 3.6.2.3 Two RHR suppression pool cooling subsystems shall be .

OPERABLE. l 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 1 OPERABLE status. j B. Two RHR suppression B.1 Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months i

-pool cooling suppression pool !

subsystems inoperable. cooling subsystem to j OPERABLE status. i C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion d Time of Condition A or 6E l 1 B not met.

l C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Q

l l

i i

l l l l 1

I l

l FERMI L UNIT 2 3.6-28 Revision 5. 04/30/99 !

l l

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 l 1s acceptable in light of the redundant RHR suppression pool l cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

U WithtwoRHRsuppressionpoolcoolingsubsystemsino!erable, one subsystem must be restored to OPERABLE status wi hin 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Comp;etion Time is based on this loss N of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a )lant I

shutdown transient that could result in the need for t1e RHR suppression pool cooling subsystem to operate.

C.1 and C.2 If the Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status. the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging p? ant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suparession pool cooling mode flow path provides assurance t1at the proper flow path exists for system o)eration. This SR does not apply to valves that are locced, 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 l FERMI UNIT 2 B 3.6.2.3 -3 Revision 5, 04/30/99

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 l experience. l l

SR_1.6.2.3.2 Verifying that each RHR pump develops a flow rate a 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 T required by ASME Code Section XI (Ref. 2). This test ,

confirms one point on the pump design curve, and the results I

( 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. ASME. Boiler and Pressure Vessel Code.Section XI.

l FERMI UNIT 2 B 3.6.2.3 -4 Revision 5. 04/3'0/99

RHR Suppression Pool Cooling B 3.6.2.3 BASES i

J ACTIONS L 1 (continued) cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

(/DSEte T l . .1 and g y,k If the Requi d Action and associated comoletion T'me.of di Condition A _cannot be est f- : - - i.;.. .. ,..;; W ;M n 7 Jr i r - ;;; sueoresCa=-poot-m== ==nvm are]

= _ a d lhe plant must De brought to a MODE in which the %@

LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an '

orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIRENENTS 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 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 (continued)

SWR /4-ST N B 3.6-69 Rev-l W /07/95' l l

RHR Suppression Pool Cooling B 3.6.2.3 Insert B 3.6.2.3 1 IL1 With two RIE suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containemt pressure and temperature mitigation y function. The :'. nour Completion Time is based on this loss of i i function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant g

shutdown transient that could result in the need for the RfR suppression pool cooling subsystem to operate.

1 i

i l

1 l

l FERMI UNIT - 2 Page B 3.6 69 (INSERT) Revision 5 04/30/99l t-

RHR Suppressicn Pool Cooling B 3.6.2.3 l

\

BASES l

SURVEILLANCE SR 3.6.2.3.1 (continued) l REQUIREMENTS -

l 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

/o,ooo pgpm while operating in the suppression pool cooling

-e with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle.

Flow is a normal test cf centrifugal pump performance s required by ASME Code,Section XI (Ref. 2). This test g confirms one point on the pump design curve, and the results

are indicative of overall performance. Such inservice lk 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,or S2 d:ys}.

REFERENCES 1.L(FSAR,Section]6.2{.

2. ASME, Baller and Pressure Vessel Code,Section XI.

't.,j4 STS- B 3.6-70 Reri, v4 /vi/95-fE1/5

r Prirary Containment Hydrogen Recombiners 3.6.3.1 ,

i 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydro 9en Recombiners LC0 3.6.3.1 Two primary containment hydrogen recombiners shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS l

i CONDITION REQUIRED ACTION COMPLETION TIME l

A. One primary A.1 - - -- NOTE--- ----

containment hydrogen LC0 3.0.4 is not !

recombiner inoperable. applicable. l Restore primary 30 days containment hydrogen recombiner to j OPERABLE status.

B. Two primary B.1 Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months l

_., containment hydrogen administrative means !

3l recombiners that the hydrogen M i E inoperable. control function is l e maintained. Once per '

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter E .

. I B.2 Restore one primary 7 days containment hydrogen l recombiner to o OPERABLE status.

(continued) l FERMI UNIT 2 3.6 30 Revision 5 04/30/99

Prirary Containment Hydrogen Recombiners B 3.6.3.1 l

B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 Primary Containment Hydrogen Recombiners BASES BACKGROUND The primary containment hydrogen recombiner eliminates the

- potential breach of primary containment due to a hydrogen

' oxygen reaction and is part of combustible gas control required by 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light Water Cooled Reactors" (Ref.1).

and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2). The primary containment hydrogen recombiner is required to gl' reduce the hydrogen concentration in the primary containment following a loss of coolant accident (LOCA). The 3rimary containcent hydrogen recombiner accomplishes this )y recombining hydrogen and oxy 0en to form water vapor. The vapor remains in the primary containment, thus eliminating any discharge to the environment. The primary containment i 4l hydrogen recombiner is manually initiated since flammability i limits would not be reached until several days after a s Design Basis Accident (DBA).

i 4 The primary containment hydrogen recombiner functions to l 4l maintain the hydrogen gas concentration within the containment (both drywell and . suppression chamber) at or ,

Sl below the flammability limit of 6.0 volume percent (v/o) following a postulated LOCA. It is fully redundant and consists of two 100% capacity subsystems. Each primary containment hydrogen recombiner consists of an enclosed blower assembly, heater section, reaction chamber, direct contact water spray gas cooler, water separator, and associated piping, valves, and instruments. The primary containment hydrogen recombiner will be manually initiated 4 from the main control room when the hydrogen gas concentration in the primary containment reaches 1.0 v/o.

When the primary containment is inerted (oxygen concentration < 4.0 v/o), the primary containment hyarogen recombiner will only function until the oxygen is used up (2.0 v/o hydrogen combines with 1.0 v/o oxygen). Two recombiners are provided to meet the requirement for redundancy and independence. Each recombiner is powered from a separate Engineered Safety Feature bus and is provided with separate power panel and control panel.

l FERMI UNIT 2 B 3.6.3.1 - 1 Revision 5 04/30/99

l l

Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES BACKGROUND (continued)

The )rocess gas circulating through the heater, the reaction cham)er, and the cooler is automatically regulated to 150 scfm. The process gas is heated to 1300*F. The hydrogen and o ngen gases are recombined into water va)or, which is then condensed in the water spray gas cooler )y the associated residual heat removal subsystem and discharged with some of the effluent process gas to the suppression chamber. The majority of the cooled effluent process gas is mixed with the incoming process gas to dilute the incoming gas prior to the mixture entering the heater )

section. .

APPLICABLE The primary containment hydrogen recombiner provides

- l SAFETY ANALYSES the capability of controlling the bulk hydrogen

.l. concentration in primary containment to less than the lower !

gl flammable concentration of 6.0 v/o following a DBA. This '

control would prevent a primary containment wide hydrogen burn, thus ensuring that pressure and temperature conditions assumed in the analysis are not exceeded. The limiting DBA i relative to hydrogen generation is a LOCA. I l

Hydrogen may accumulate in primary containment following a l LOCA as a result of:

a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant: or

b. Hydrogen contained in the water in the Reactor Coolant System from radiolytic decomposition and the hydrogen water chemistry control program.

To evaluate the potential for hydrogen accumulation in primary containment following a LOCA. the hydrogen generation is calculated as a function of time following the initiation of the accident. Assum)tions recommended by Reference 3 are used to maximize t1e amount of hydrogen calculated.

The calculation (Ref. 4) confirms that hydrogen and oxygen can be safely and effectively controlled to the limits of Table 1 of Reference 5.

l FERMI UNIT 2 B 3.6.3.1 - 2 Revision 5. 04/30/99

Primary Containment Hydrogen Recombiners .

B 3.6.3.1 l l

BASES APPLICABLE SAFETY ANALYSES (continued)

The primary containment hydrogen recombiners satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). l LC0 Two primary containment hydrogen recombiners must be OPERABLE. This ensures operation of at least one primary containment hydrogen recombiner subsystem in the event of a worst case single active failure.

Operation with at least one primary containment hydrogen gl recombiner subsystem ensures that the post-LOCA hydrogen concentration can be prevented from exceeding the Nj flammability limit.

1 I

In MODES 1 and 2, the two primary containment hydrogen fl APPLICABILITY recombiners are required to control the hydrogen concentration within primary containment below its gl flammability limit of 6.0 v/o following a LOCA, assuming a worst case single failure.

In MODE 3. both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the DBA LOCA. Also, because of the limited time in this MODE. the probability of an accident requiring the primary containment hydrogen recombiner is low.

Therefore, the primary containment hydrogen recombiner is not required in MODE 3.

In MODES 4 and 5, the probability and consequences of a LOCA are low due to the pressure and temperature limitations in these MODES. -Therefore, the primary containment hydrogen recombiner is not required in these MODES.

ACTIONS A1 With one primary containment hydrogen recombiner inoperable, the inoperable recombiner must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE recombiner is adequate to perform the hydrogen control function. However, the overall reliability is reduced because a single failure in the OPERABLE recombiner l FERMI - UNIT 2 B 3.6.3.1 - 3 Revision 5, 04/30/99

Primary Containment Hydrogen Recombiners l B 3.6.3.1 i

BASES ACTIONS.(continued) could result in reduced hydrogen control capability. The 30 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen in NI amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent exceeding this limit, and the low probability of failure of the OPERABLE primary containment hydrogen recombiner.

Required Action A.1 has been modified by a Note indicating that the provisions of LC0 3.0.4 are not applicable. As a result, a MODE change is allowed when one recombiner is ino)erable. This allowance is provided because of the low N 3ro) ability of the occurrence of a LOCA that would generate lydrogen in amounts capable of exceeding the flammability limit, the low probability of the failure of the OPERK.iE subsystem, and the amount of time available after a postulated LOCA for operator action to prevent exceeding the flammability limit.

B.1 and B.2 Y With two primary containment hydrogen recombiners inoperable, the ability to erform the hydrogen control k'l

,l function via alternate capa ilities must be verified by administrative means within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen I

control capabilities are provided by the Primary Containment Inerting System. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time allows a il reasonable period of time to verify that a loss of hydrogen control function does not exist. In addition, the alternate 41 hydrogen control system capability must be verified once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter to ensure its continued availability.

Both the initial verification and all subsequent verifications may be performed as an administrative check by examining logs or other information to determine the availability of the Primary Containment Inerting System. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the Primary Containment Inerting System. If the ability to perform the hydrogen control function is maintained. continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days.

Seven days is a reasonable time to allow two hydrogen 9 recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of g the occurrence of a LOCA that would generate hydrogen in amounts capable of exceeding the flammability limits.

j . UNIT 2 B 3.'6.3.1 - 4 Revision 5. 04/30/99

[

DISCUSSION OF CHANGES ITS: SECTION 3.6.3.1 PRIMARY CONTAINENT HYDR 0 GEN REC 0 MINERS LA.2 CTS 4.6.6.1.a and CTS 4.6.6.1.b.2 require performing a system functional test and the verification of the hydrogen recombiner i heater resistance, including details of how the tests are performed and the acceptance criteria for the tests. ITS ,

SR 3.6.3.1.1 and SR 3.6.3.1.3 require these tests, but do not i detail how the tests are to be performed. These details are @

relocated to the Bases. This is acceptable because the test g methodology does not impact the ITS requirement to perform the N:

test and verify equipment Operability. Therefore, this information can be adequately defined and controlled in the ITS Bases which require change control in accordance with ITS section 5.5.10. Bases Control Program.

LA.3 CTS 4.6.6.1.b.3 requires the performance of a visual examination and details example abnormal conditions to look for during a i visual examination. ITS SR 3.6.3.1.2 requires a visual I

examination to be performed, but does not define example abnormal conditions to look for. These details are relocated to the Bases. l6 This is acceptable because the CTS information does not impact the ITS requirement to perform the examination. The information k'

provided in this section provides guidance to an inspector of what constitutes abnormal conditions in the hydrogen recombiner. This criteria provides qualitative criteria which is not directly related to the Operability of the hydrogen recombiner. Therefore,

! this informatior; can be adequately defined and controlled in the Bases, which requires change control in accordance with ITS section 5.5.10. Bases Control Program.

l l LA.4 CTS 3.6.6.1 details, defining the primary containment hydrogen recombiner system, are relocated to the ITS Bases. The information provided in this section, defines what constitutes a primary containment hydrogen recombiner. This information is not directly

related to the Operability of the hydrogen recombiner. Therefore.

l this information can be relocated. These requirements can be adequately defined and controlled in documents which require change control in accordance with ITS 5.5.10. Bases Control Program.

1 l

l FERMI UNIT 2 2 REVISION 5. 04/30/99l l

l

Primary Containment Hydrogen Recombiners 3.6.3.1 l l

3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners (i' p:,T .....u, 2 CTS)

,,;telled)- ,

l LCO 3.6.3.1 Two primary containment hydrogen recombiners sht11 be OPERABLE. h.d.6./)

APPLICABit.ITY: MODES 1 and 2.

ACTIONS l

CONDITION REQUIRED ACTION COMPLETION TIME l

A. One primary A.1 --

-NOTE--------

containment hydrogen LCO 3.0.4 is not recombiner inoperable. applicable. Doc L.1)

Restore primary 30 days [3. (,. (,' /

containment hydrogen J recombiner to AcTio4)

OPERABLE status.

1

[Twoprimary B.1 Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months containment hydrogen administrative means Doc L.2) recombiners inoperable.

that the hydrogen E !

control function is -

saintained. Once per i % ,,L 12 hours <

s thereafter f

/ >s i m !

B.2 Restore one primary 7 days l containment hydrogen j recombiner to c OPERABLE status.

l (continued) l I

l lr4R/4-STS 3.6-40 R w 4, Oi/07f96- '

1 0EV $

l l

i

Primary CIntainment Hydrog:n Recombinirs j B 3.6.3.1 ,

B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1. Primary Containment Hydrogen Recombiners I

BASES BACKGROUND The primary containment hydrogen recombiner eliminates the.

potential breach of primary containment due to a hydrogen oxygen reaction and is part of combustible gas control required by 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light-Water-Cooled Reactors" (Ref.1),

and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2). The 7-primary c-ontainment hydrogen recombiner is required to A reduce t'ne hydrogen concentration in the primary containment T following a loss of coolant accident (LOCA). The primary containment hydrogen recombiner accomplishes this by recombining hydrogen and oxygen to form water vapor. The vapor remains in the primary containment, thus eliminatirg any discharge to the environment. The primary containment hydrogen recombiner is manually initiated since flammability limits would not be reached until several days after a Design Basis Accident (DBA). ,

00N b The primary containment hydrogen recombiner functions to ci n / s uf f f' # hmaintainthehydrogengasconcentrationwithinthe containeen t or below the flammability limit of 4d volume ChC4 Mbec) perce /c) following a postulated LOCA. It is fully redundant and consists of two 100% capacity subsystems.

Each primary containment hydrogen recombiner consists of an enclosed blower assembly, heater section, reaction chamber, direct contact water spray gas cooler, water separator, and associated piping, valves, and instruments. The primary containment hydrogen recombiner will be manually initiat d -

from the main control room when the hydrogen gas o J.

concentrationintheprimarycontainmentreachesf3 When the primary containment is inerted (oxygen y o. g 2

concentration < 4.0 v/c), the primary containment hydrogen recombiner will only function until the oxygen is used up (2.0 v/o hydrogen combines with 1.0 v/o oxygen). Two recombiners are provided to meet the requirement for redundancy and independence. Each recombiner is powered from a separate Engineered Safety Feature bus and is provided with separate power panel and control panel.

The process gas circulating through the heater, the reaction cham >er, and the cooler is automatically regulated to

$150 scfe,5y th = af an acifice n1 ate installed in the_.

h (continued)

C /4 GTS- B 3.6-78 Rev-Ir-94f07/95-fCl 5

l Primary Containment Hydrogen Recombiners B 3.6.3.1 l

BASES i tbop ,

BACKGROUND soolen The process gas is heated to 'F. The l (continued) hydrogen and oxygen gases are recombin d into water. vapor, l which is then condensed in the water spray gas cooler by the i associated residual heat removal subsystem and discharged j with some of the effluent process gas to the suppression chamber. The majority of the cooled, effluent process gas j is mixed with the incoming process gas to dilute the l incoming gas prior to the mixture entering the heater :

section.

APPLICABLE The primary containment hydrogen rec abiner provides SAFETY ANALYSES the capability of controlling the bulk hydrogen n l concentration in primary E5'ntainment to less than the lower -

i flassable concentration ofM. v/o following a DBA. This control would prevent a primary containment wide hydrogen

,( !

}

burn, thus ensuring that pressure and temperature conditions 4 assumed in the analysis are not exceeded. The limiting DBA j relative to hydrogen generation is a LOCA. ;

91 y Hydrogen may accumulate in primary containment following a

, pp #, j LOCA as a result of:

D' roq*cher a. A metal steam reaction between the zirconium fuel rod I 4h cladding and the reactor coolant; or

.g y 4 N 'r p[<geP'k'<3[O'ddNd?A7"""""

\o t be h,ew' c0 g jr o To evaluate the potential for hydrogen accumulation in primary containment following a LOCA, the hydrogen !

$entration I f.1 nitiation ofisthe calculated accident. as.a function reconnended Assumptions of time following by the !

Reference 3 are used to maximize the amount of hydrogen j

"" '"I Uef. 4 )

g e n. I h droqca 3 The calculatio confirms that when-the ;;itigetin, unum -

N *~ et" t* h "4'"" " i t vency-procedur::, the coa g afeljeg*teoM d -peak-hydr.oge aaarentratia'in-th""e primary-contathment 4s-- ,

c{fCM g of l

, to the The primary containment hydrogen recombiners satisfy l ge(erc6ce 6. Criterion 3 of ": ".C ";1 icy Ctat; .;-^ r.

f PA W"3b l i

(continued) j

$WR/4-SYS--- B 3.o-79 Rev-Ir-04/07195-~ !

1 I

(,_ .

Rell !

Primary Containment Hydrogen Recombiners 8 3.6.3.1 ;

BASES (continued) J LC0 Two primary containment hydrogen recombiners must be OPERA 8LE. This ensures operation of at least one primary containment hydrogen recombiner subsystem in the event of a worst case single active failure.

=

Operation with at least one primary containment hydrogen -

recombiner subsystem ensures that the post-LOCA hydrogen-concentration can be prevented from exceeding the flammab,ility limit. 'Q s

~

APPLICABILITY In MODES 1 and 2, the two primary containment hydrogen I k

g-i i

- recombiners are required to control the hydrogen concentration within primary containment below its M

'g flannability limit of eve-v/o following a LOCA, assuming a q worst case single failure !

In MODE 3, both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the D8A LOCA. Also, because of the limited time in this MODE, the probability of an accident requiring the primary containment hydrogen recombiner is low.

Therefore, the primary containment hydrogen recombiner is not required in MODE 3.

l I

In MODES 4 and 5, the probability and consequences of a LOCA are low due to the pressure and temperature limitations in f these MODES. Therefore, the primary containment hydrogen l recombiner is not required in these MODES. l ACTIONS M With one primary containment hydrogen recombiner inoperable, I the inoperable recombiner must be restored to OPERABLE !

status within 30 days. In this Condition, the remaining 1 OPERABLE recombiner is adequate to perform the hydrogen n control function. However, the overall reliability is i reduced because a single failure in the OPERABLE recombiner I could result in reduced hydrogen control capability. The ;

~

30 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen in i

~j-amounts capable of exceeding the flammability limit, the -

amount of time available after the event for operator action $

(continued)

SWR /4 M B 3.6-80 Rev 4 -04/07795~ l i

I h

1 i

a

( Primary Containment Hydrogen Recombiners l B 3.6.3.1 BASES ACTIONS L.1 (continued) to prevent exceeding this limit, and the low probability of failure of the OPERABLE primary containment hydrogen recombiner.

Required Action A.I has been modified by a Note indicating l that the provisions of LCO 3.0.4 are not applicable. As a I result, a MODE change is allowed den one recombiner is l inoperable. This allowance is provided because of the low !

probability of the occurrence of a LOCA that would generate i hydrogen in amounts capable of exceeding the flasmiability 7 limit, the low probability of the failure of the OPERABLE subsystem, and the amount of time available after a Q postulated LOCA for operator action to prevent exceeding the flammability limit.

B.1 and B.2 Newer'snum T;,e raadition is M v A h;;J Tur units with an alternate hvdre;:n ;eiiirvi 6 4 :--"+=hle lo the A C staff-l - '

i l With two primary containment hydrogen recombiners inoperable, the ability to perform the hydrogen control p function via alternate capabilities must be verified by ly administrative means within I hour. The alternate hydrogen control capabilities are provided by the4 Primary Containment Inerting System er One ::.;t;ystam4f-_the 0;nteir-.; 't .e;-t;r; Di'"the S;;t;;;). The I hour l CompletionTimeaIlowsareasonableperiodoftimetoverify l .that a loss of hydrogen control function does not exist.

og P.evt=:r'e Mete

The fe!! = W S t; te ;;ed if e ;;r.

P i

l L dechice! Saecificatica alternete hydre;en 00:tr:1 f;nctha h "esd te j" tify thh Ondith: In addition, the lLt .

l alternate hydrogen control system capability must be l

verified once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter to ensure its j %.

continued availability.X 46oth}<the )tinitialfverification Aandallsubsequentver'fications)'maybeperformedasan administrative check by examining logs or other information p O 'Y ,J to determine the availability of the a Me--ete hydr;;;r.

Coediw C ~ ~7 0 tr;l system. It does not mean to perform the h Survelliances needed to demonstrate OPERABILITY of the Jnerfiny j/ alterants hyd-a;en eaa+*al sveta=- If the ability to y perfo a the hydrogen contro1' function is maintained, (continued)

BWR/4-STS- B 3.6-81 Rev 1, M/Mf95~

Rev 5'

Primary Containment Hydrogen Recombiners B 3.6.3.1 1 l

BASES l ACTIONS B.1 and B.2 (continued) , I coatinued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Seven days is a reasonable time to allow two. hydrogen recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of the 7 occurrence of a LOCA that would generate hydrogen in amounts <!t-capable of exceeding the flamability limit. X G.1 If any Required Action and associated Completion Time 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.1.1 REQUIREMENTS

/ Perfonsance of a system functional test for each primary containment hydrogen recombiner ensures that the recombiners are OPERABLE and can attain and sustain the temperature necessary for hydrogen recombination. In particular, this SR verifies that the minimum heater sheetnexperature d4* j increases t *F in s [1.5' M m and that it.is SM maintained 150 rd- F200T ST k W LhourF thereafter to chec theabilityoftherecomb'herto$ '7 function properly (and to make sure that significant heate '""' " b 5,, ,

elements are not burned out). Operating experience has shown that these component usually pass the Surveillance when performed at the $ month Frequency. Therefore, the Frequency was concluded to be acce table from a reliability i standpoint. ~ N '

(i.e., loose. Mriu3 ar sht(wd (sucekrHS, j Op.y SR 3.6.3.i.2 5* [ k"_M $#*>Nl This SR ensures there are no physical problems that could j affect recombiner operation. Since the recombiners are .

(continued)

-8WR/4-STS-- B 3.6-82 Rev4r-04/07/95 l

l l

l

l 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.

l l

APPLICABILITY: MODES 1, 2, and 3. .

I During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, 1 During operations with a potential for draining the reactor ;

vessel (0PDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

$l A. Secondary Containment A.1 Restore railroad bay 7 days inoperable due to one door to OPERABLE <

n railroad bay access status.

g door inoperable.

V

l B. Secondary containment B.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

-inoperable in MODE 1, containment to 2, or 3 for reasons OPERABLE status.

other than Condition A.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or 8NQ B not met.

C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

~l FERMI UNIT 2- 3.6 33 Revision 5, 04/30/99 l

1 Secondary Containment 3.6.4.1 l

ACTIONS (continued) '

CONDITION REQUIRED ACTION COMPLETION TIME D. Secondary containment - - --

- NOTE- -- - -- --

N inoperable during LC0 3.0.3 is not applicable.

'\ movement of irradiated --- - --- - -

fuel assemblies in the k secondary containment, during CORE 0.1 Suspend movement of irradiated fuel Immediately ALTERATIONS, or during assemblies in the OPDRVs. secondary containment.

8NQ l D.2 Suspend CORE Immediately ALTERATIONS.

MQ D.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a 0.125 inch of vacuum water gauge.

(continued) l FERMI - UNIT 2 3.6 34 Revision 5. 04/30/99

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued) ,

SURVEILLANCE FREQUENCY SR 3.6.4.1.2 --- --

-- NOTE - - ---

Not required to be met for one railroad bay access door until:

a. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after opening for entry.

T exit. or testing; and

b. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after opening for new fuel E

% receipt activities, provided the other door remains OPERABLE and closed.

Verify all secondary containment 31 days equipment hatches. pressure relief doors and railroad bay access doors are closed and sealed.

SR 3.6.4.1.3 Verify one secondary containment access 31 days door in each access opening is closed.

u SR 3.6.4.1.4 Verify steam tunnel blowout panels are Prior to

2. closed. entering MODE 2

{ or 3 from MODE 4 if not performed in the previous 'j 31 days SR 3.6.4.1.5 Verify each standby gas treatment (SGT) 18 months on a subsystem will draw down the secondary STAGGERED TEST containment to a 0.25 inch of vacuum BASIS water gauge in s 567 seconds.

SR 3.6.4.1.6 Verify each SGT subsystem can maintain 18 months on a a 0.25 inch of vacuum water gauge in the STAGGERED TEST secondary containment for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a BASIS flow rate s 3000 cfm.

l FERMI - UNIT 2 3.6 35 Revision 5. 04/30/99

Secondary Containment B 3.6.4.1 BASES g l ACTIONS M With a Secondary Containment railroad bay access door inoperable there remains a redundant access door in an OPERABLE status. This ' . is capable of maintaining the Secondary Containment function. Therefore, the 7 day Completion Time gives a reasonable period of time to correct c) the problem given the availability of the other access door 1 and the low probability of an event occurring that will g challenge the Secondary Containment during this time period, bl M If secondary containment is inoperable for reasons other 4l than Condition A, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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 OPEPABILITY) 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 the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

j FERMI UNIT 2 B 3.6.4.1 - 3 Revision 5, 04/30/99

i Secondary Containment l B 3.6.4.1 BASES l

ACTIONS (continued) 0.1. D.2. and D.3 Hovement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, and OPDRVs can be postulated to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the i

environment. CORE ALTERATIONS and movement of irradiated fuel assemblies must be immediately suspended if the secondary containment is inoperable.

Suspension of these activities shall not preclude completing i an action that involves moving a component to a safe position. Also, action must be immediately initiated to l suspend OPDRVs to minimize the probability of a vessel l draindown and subsequent potential for fission product ,

release. Actions must continue until 0PDRVs are suspended.

{

E The Required Actions have been modified by a Note stating Tl that LCO 3.0.3 is not applicable. If moving irradiated fuel l

I assemblies while in H00E 4 or 5. LC0 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in l MODE 1. 2, or 3, the fuel movement is independent of reactor '

operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

l l'

SURVEILLANCE SR 3.6.4.1.1 REQUIREMENTS This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under i expected wind conditions. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR l was developed based on operating experience related to l secondary containment vacuum variations during the i applicable H00ES and the low probability of a DBA occurring '

between surveillances.

Furthermore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal secondary containment vacuum condition.

l FERMI - UNIT 2 B 3.6.4.1 - 4 Revision 5, 04/30/99 l

L

Secondary Containment B 3.6.4.1 BASES.

SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.4.1.2 and SR 3.6.4.1.3 Verifying that secondary containment equipment hatches.

pressure relief doors, railroad bay access doors, and one i access door in each access opening are closed ensures that j the infiltration of outside air of such a magnitude as to j prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur. In this application, the term

" sealed" has no connotation of leak tightness. Maintaining secondary containment OPERABILITY requires verifying one

- door in each access opening is closed. An access opening !

contains one inner and one outer door. In some cases, secondary containment access openings are shared such that a secondary containment barrier may have multiple inner or .

multiple outer doors. The intent is not to breach the j secondary containment at any time when secondary containment !

is required. This is achieved by maintaining the_ inner or ,

outer portion of the barrier closed at all times. However. l all secondary containment access doors are normally kept ;

closed, except when the access opening is being used for j l-entry and exit or when maintenance is being performed on an i access opening. The 31 day Frequency for these SRs has been shown to be adequate, based on o mrating experience, and is !

considered adequate in view of tie other indications of door l and hatch status that are available to the operator, j l 4 A Note is added to SR-3.6.4.1.2 to allow a secondary L containment railroad bay access door to be open for up j

( to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for entry, exit or testing, and up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months fcr new fuel receipt activities. These activities do not l

indicate a problem with a railroad bay access door and the !

door should not be considered inoperable. Also, with one l

@ railroad bay door remaining closed, secondary containment OPERABILITY is maintained. The times allowed are reasonable for the activities being performed considering the j

l 4

availability of the redundant door, i

L FERMI UNIT 2 B 3.6.4.1 - 5 Revision 5. 04/30/99 l

l l

Secondary Containment B 3.6.4.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.4.1.4 If the steam tunnel blowout panels are open the integrity of the Secondary Containment is lost. Since the steam tunnel blowout panels are inaccessible during plant operation, this SR is only required to be performed during MODE 4. but only if it has been greater than 31 days since the last verification. This frequency has been shown to be adequate based on operating experience, and in view of other i indications of the status of the steam tunnel blowout panels '

available to the operator.

l SR 3.6.4.1.5 and SR 3.6.4.1.6 The SGT System exhausts t

secondary containment atmosphere to the environment through appropriate treatment equipment. To ensure that all fission products are treated.

SR 3.6.4.1.5 verifies that the SGT System will rapidly establish and maintain a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary. This is confirmed by demonstrating that one SGT subsystem will draw down the secondary containment to = 0.25 inches of vacuum water gauge in s 567 seconds. This cannot be accomplished if the secondary containment boundary is not intact. :

SR 3.6.4.1.6 demonstrates that one SGT subsystem can l maintain = 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a ;

flow rate s 3000 cfm. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months test period allows

~

secondary containment to be in thermal equilibrium at steady state conditions. Therefore, these two tests are used to i ensure secondary containment boundary integrity. Since ,

these SRs are secondary containment tests. they need not be 1 performed with each SGT subsystem. The SGT subsystems are tested on a STAGGERED TEST BASIS however, to ensure that in i addition to the requirements of LC0 3.6.4.3. either SGT l subsystem will perform this test. Operating experience has I shown these components usually pass the Surveillance when j performed at the 18 month Frequency. Therefore the '

Frequency was concluded to be acceptable from a reliability i standpoint. i REFERENCES 1. UFSAR. Section 15.6.5. !

2. UFSAR. Section 15.7.4.

4iFERMI-UNIT 2 B 3.6.4.1 - 6 Revision 5. 04/30/99 i

qSicendarygontainment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 4

3.6.4.1 Secondary Containment D LC0 3.6.4.1 Thegsecondarygcontainment shall be OPERABLE. 3.6 6 I APPLICA81LITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the AFsecondary14:entainment, .

During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME lf.4 4.(-l a'

, ASecondaryJc W.1 Restore $econdaryK 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

< containment inoperable ff/ containment to

.. in MODE 1, 2, or 3. OPERABLE status. (fto5l;Acnwo.1) p l kreasms e%che (.d:b c.

p. Required Action and 4r.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

(. associated Completion Time of Condition A g 6 6J @N M

/

not met. F.(,.S. I . A ct1N b.I 0 O X.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.

N

,2 g

4 Secondary P containment inoperable gh 4.r=------NOTE---------

LCO 3.0.3 is not Q

during movement of f! irradiated fuel M~ applicable. / \

assemblies in the /305la Acbd 41

)psecondaryja '/ . Suspend movement of Ismediately containment, during irradiated fuel CORE ALTERATIONS, or (3.G 5.I, Actrod b2 assemblies in the ,

during OPDRVs. pecondaryJ6 containment.

E (continued) wwn, , a i .r 3.6-47 Rev-4r-44fS7frX--

Ilw C

Secondary Containment 3.6.4.1 INSERT 3.6.4.1 1 c0 A. . Secondary Containment A.1 Restore railroad 7 days l _!,

inoperable due to one railroad bay access bay door to g

, OPERABLE status.

door inoperable.

FERMI- UNIT 2 Page 3.6 47 (Insert) REVISION 5. 04/30/99l i

I Containment ,

(Seeinda 3.6.4.1 l ACTIONS CONDITION REQUIRED ACTION CONPLETION TINE r

p. (continued) 2'. 2 Suspend CORE Imediatel

.D D ALTERATIONS. \

7, ,g, g,7 hiik % G.lA ca p b.t.,

I g.3 Initiate action to Imediately D suspend OPDRVs.

SURVEILLANCE REQUIRENENTS SURVEILLANCE FREQUENCY f.f,.5.l.a) ;

,* SR 3.6.4.1.1 Verify 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 g +,/

2l0.;[,inchofvacuumwatergauge.secondaryYcontainme 1956TLT 0,12 5 4p L y.c.+1-2__ 3 ,.n gs ,. g,c,,g, g,94 n,o g)

_ SR 3.6.4.1.2 Verify all k'secondaryfcontainment

,W<.ssure.rdaW equipment hatches are closed and sealed. 31 days (4.t,.6.I,b.l) a..n 43A cama waum ,iweJ

\ > nu T i SR 3.6.4.1.3 Verify /aaek)[secondarypcontainment i 31 days 4. 5. ) . b ,'2. I

(/N56Rr} , n e,c L- access doores closed _ :::::' = is-3lo.4.l-3 ic'55 Cf** fSI"5Ur~f.[.2.

3[N-I-5 IN 2^IE-

--_-_------u

9. l

-4 SR 3.6.4.1 Verify each standby gas treatment $18[ months on \.6 5.f.4.1 (SGT) subsystem will draw tinwn the a STAGGERED

' containment to TEST BASIS ysecondaryfnchofvacuumwatergauge 2(0.25%,

in s seconds.

(continued) l BWR/4-GTS 3.6-48 Sert;-04/07793' i

I 8/ b

\

l

I

(

Secondary Containment 3.6.4.1 l

l

)

l INSERT 3.6.4.1 2 )

.................. NOTE- ---------- - -- -- I Not required to be met for one railroad !

bay' access door until:

a. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after opening for entry. I exit, or testing: and Y '

b. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after opening for new fuel receipt activities, g

provided the other door remains OPERABLE l and closed.

JNSERT3.6.4.1-3 l

SURVEILLANCE FREQUENCY SR 3.6.4.1.4 Verify steam tunnel blowout Prior to y panels are closed. entering MODE 2 i or 3 from MODE 4 if not g

performed in the previous 31 days FERMI - UNIT 2 Page 3.6-48 (Insert) REVISION 5. 04/030/99l m___

(Secondary { Containment B 3.6.4.1 BASES APPLICABLE products entrapped within the Xsecondaryj containment j SAFETY ANALYSES structure will be treated by the SGT System prior to j (continued) discharge to the environment. '

th; O

{,Q

{.9fQ Secondary 1 t tr.;ntr{ containment satisfies Criterion 3/0CMU50 v. % @

LC0 AnOPERABLE1 secondary:I.containmentprovidesacontrol volume into which fiss on products that bypass or leak from primary containment, or are released from the reactor coolant pressure containment, canboundary be dilutedcomponents and processlocated priorinTsecondary{

to release to the environment. Forthe(seconda containment to be considered OPERABLE, it must have adeq te leak tightness to ensure that the required vacuum can be established and maintained. l APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to(secondaryp containment. Therefore, (secondarypcontainmentOPERAB.LITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the l LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining fsecondaryfcontainmentOPERABLEisnotrequiredinMODE4 or 5 to ensure a control volume, except for other situations for. which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE' ALTERATIONS, or during movement of irradiated fuel assemblies in thegsecondary{ containment.

ACTIONS 64.1 (.Cr y VIker (c>nd; f f /N$@T J If fsecondar/1 containment is inoperable,41t must be g 'g'q ,( ) '

restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time'to correct the k'

'3 problem that is coamensurate with the importance of (continued)

I M/4 sis- B 3.6-98 6 1, ^'/M/QL 1

keVf

Secondary Containment B 3.6.4.1 Insert B 3.6.4.1 1 to aa 1j

' 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 othor access door and the low probability of an event occurring that will challenge the Secondary Containment during this time period.

FERMI UNIT 2 Page B 3.6 98 (INSERT) Revision 5. 04/30/99l

1 pecondaryfContainment B 3.6.4.1 8ASES l

ACTIONS ,hil(continued) maintaining (secondarypcontainment during MODES 1, 2 k and 3. This time period also ensures that the probability 7 l of an accident (requiring disecondary( containment OPERABILITY)is containment inoperable is minimal.occurringdurungperiodswhere ,

I W

and If$ secondary containment cannot be restored to OPERABLE statuswithin}therequiredCompletionTime,theplantmust l be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least l MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The i 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.

. an 3 Movement of irradiated containment, CORE fuel assemblies ALTERATIONS, and OPDRVsin canthe(secondary be postulate {d to cause fission product release to the isecondaryU containment. Insuchcases,*he2secondaryfconta'neentis the only barrier to release of fission products to the environment. CORE ALTERATIONS and movement of irradiated fuel assemblies must be imediately suspended if the

,Tsecondaryfcontainmentisinoperable.

Suspension of these activities shall not preclude completing an action that involves moving a component to a safe position. Also, action must be imediately initiated to suspend OPORVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions t continue until OPDRVs are suspended.

Required Acti f b3 LCO 3.0.3 is not applicable.beenmodifiedbyaNotestatin$that If moving irradiated fue l4 assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend (continued) 4WR/44T: B 3.6-99 Rev-1,04/07/;3 fEU Y

gSecondary); Containment l B 3.6.4.1 l l

l BASES n

ACTIONS b! N P.1. 1.2. and Y.3 (continued) l movement of irradiated fuel assemblies would not be a i sufficient reason to require a reactor shutdown. I SURVEILLANCE SR 3.6.4.1.1 REQUIREMENTS This SR ensures that tha 4secondaryjecontainment boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR was developed based on operating experience related to \/

v isecondary% containment vacuum variations during the /

/

\ applicable MODES and the low probability of a DBA occurring between surveillances.

Furthermore, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal I

hecondarytcontainmentvacuumcondition. j 1 - \

1 l

SR 3.6.4.1.2 and SR 3.6.4.1.3 ceh rj[e,s, co,ilroad . Verifyingccess doorsthatXsecondaryt are closed ensurescontainment equipment that the infiltration of hatche ,

,1 g acctadooc)outside air of such a magnitude as to prevent maintaining Mderg-lb l

the desired negative pressure does not occur. Verifying T

I that all such openings are closed provides adequate assurance that exfiltration from the Xsecondary$ containment will not occur. In this application, the term " sealed" has e no connotation of leak tightness. Maintaining 4secondarvFM 7, containment OPERABILITY requires verifyingMdoor in access opening is p----

g closed, er. :pt det the

___._.__2 _m.

er::::

,u

r.ini; is 1MN heest 3EidEo' r drcN E$5$

25 nth [31$layYSUuMey g 3.4 4.t 'N ~ - _ for these SRs has been shown to dequate, based on

,~ operating experience, and is considered adequate in view of '

the other indications of door and hatch status that are l ,'

. available to the operator. j I~'Inse#

g 3. 6 9.\ ' N (continued) ]l

"""/4 373 8 3.6-100 Rev-tr-44/07/95--

f l

1 an*'*

l}

i t

1-

l i

Secondary Containment B 3.6.4.1 Insert B 3.6.4.1 2 1

A Note is added to SR 3.6.4.1.2 to allow a Secondary Containment railroad bay access door to be open for up to f

l 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for entry, exit or testing, and up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for k new fuel receipt activities. These activities do not indicate a problem with a railroad bay access door and the I door should not be considered inoperable. Also, with one I railroad bay access door remaining closed secondary containment OPERABILITY is maintained. The times allowed are reasonable for the activities being performed considering the availability of the redundant door.

SR 3.6.4.1.4 If the steam tunnel blowout panels are open the integrity of the Secondary Containment is lost. Since the steam tunnel blowout panels are inaccessible during plant operation, this SR is only required to be performed during MODE 4, but only if it has been greater than 31 days since the last verification. This frequency has been shown to be adequate l based on operating experience, and in view of other indications of the status of the steam tunnel blowout panels available to the operator.

i l

l Jnsert B 3.6.4.1-2 An access opening contains one inner and one outer door. In l some cases, secondary containment access egenings are shared such that a secondary containment barrier may have multiple inner or multiple outer doors. The intent is not to breach the secondary containment at any time when secondary containment is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all times. However, all secondary containment access doors are normally kept closed. except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening.

FERMI UNIT 2 Page B 3.6-100 (INSERT) Revision 5. 04/30/99l

SCIVs 3.6.4.2 l

ACTIONS I CONDITION REQUIRED ACTION COMP'ITION TIME A. (continued) A.2 -

- - NOTES -- - -

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked.

sealed, or otherwise secured may be verified by use of administrative means. Verify the affected Once per 31 days penetration flow path is isolated B. - -- NOTE --- -- B.1 Isolate the affected 4 hours Only applicable to )enetration flow path penetration flow paths )y use of at least with two isolation one closed and valves. de activated automatic valve. closed manual valve. One or more or blind flange. penetration flow paths with two SCIVs inoperable. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time of Condition A AND or B not met in MODE 1. 2. or 3. C.2 Be in MODE 4. 36 hours (continued) l FERMI - UNIT 2 3.6-37 Revision 5. 04/30/99

l SCIVs 3.6.4.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and -

                                                   -NOTE -    -    -

associated Completion LC0 3.0.3 is not applicable. O Time of Condition A -- ---- - -- -- or B not met during movement of irradiated D.1 Suspend movement of fuel assemblies in the irradiated fuel Immediately secondary containment, assemblies in the ! during CORE secondary 1 ALTERATIONS, or during containment. l' OPDRV . M D.2 Suspend CORE l ALTERATIONS. Immediately l M D.3 Initiate action to suspend OPDRVs. Immediately l 4 i l FERMI UNIT 2 3.6-38 Revision 5. 04/30/99

I SCIVs I 3.6.4.2 l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i SR 3.6.4.2.1 . -- -

                                                 - NOTES--        - - - - - --

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

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

Verify each secondary containment 31 days isolation manual valve and blind flange l not locked. sealed or otherwise secured that is required to be closed during accident conditions is closed. SR 3.6.4.2.2 Verify the isolation time of each power In accordance Ogl operated automatic SCIV is within limits. with the Inservice Testing Program ' SR 3.6.4.2.3 Verify each automatic SCIV actuates to 18 months the isolation position on an actual or simulated actuation signal. l FERMI - UNIT 2 3.6-39 Revision 5 04/30/99

E i SCIVs B 3.6.4.2 l l BASES APPLICABLE SAFETY ANALYSES (continued) ! containment performs no active function in response to I either of these limiting events, but the boundary established by SCIVs is required to ensure that leakage from , the primary containment is processed by the Standby Gas l Treatment (SGT) System before being released to the ' environment. i Maintaining SCIVs OPERABLE with isolation times within i l limits ensures that fission products will remain trapped ' inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment. i SCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). 1 LC0 SCIVs form a part of the secondary containment boundary. The SCIV safety function is related to control of offsite l radiation releases resulting from DBAs. l The power operated automatic isolation valves are considered OPERABLE when their isolation times are within limits and the valves actuate on an automatic isolation signal. The valves covered by this LC0. along with their associated stroke times, are listed in Reference 3. l l APPLICABILITY In MODES 1. 2. and 3. a DBA could lead to a fission product release to the primary containment that leaks to the l secondary containment. Therefore, the OPERABILITY of SCIVs i is required. In MODES 4 and 5. the probability and consequences of these events are reduced due to pressure and temperature licitations in these MODES. Therefore, maintaining SCIVs

OPERABLE is not required in MODE 4 or 5. except for other situations under which significant radioactive releases can i be postulated such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS or during movement of irradiated fuel assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1. 2. and 3.

l FERMI - UNIT 2 B 3.6.4.2 - 2 Revision 5. 04/30/99 l

i SCIVs l l B 3.6.4.2 j l l BASES ACTIONS (continued) containment penetrations required to be isolated following an accident, but no longer capable of being automatically isolated, will be in the isolation position should an event l occur. The Completion Time of once per 31 days is I appropriate because the valves are operated under administrative controls and the probability of their l misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves l verification that the affected penetration remains isolated. l Required Action A.2 is modified by two Notes. Note 1 applies to devices located in high radiation areas and allows them to be verified closed by use of administrative ! controls. Allowing verification by administrative controls l is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment, once they have been verified to be in the proper position, is low. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in l position and allows these devices to be verified closed by l use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently - repositioned. l [kl With two SCIVs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. l Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 4 hour Completion Time is reasonable considering the time required to isolate the penetration and the probability of a DBA which requires the SCIVs to close, occurring during this short time, is very low. The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of two penetrations. l FERMI UNIT 2 B 3.6.4.2 - 4 Revision 5 04/30/99

E SCIVs B 3.6.4.2 i BASES l l ACTIONS (continued) C.1 and C.2 If any Required Action and associated Completion Time cannot I be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to M0DE 4 ! within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the I recuired plant conditions from full power conditions in an ; orcerly manner and without challenging plant systems. D.1. D.2. and D.3 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LC0 does not apply. If applicable, CORE ALTERATIONS and the movement of irradiated fuel assemblies in the secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until OPDRVs are suspended. Jl The Required Actions have been modified by a Note stating 4 that LC0 3.0.3 is not applicable. If moving irradiated fuel

 %                       assemblies while in MODE 4 or 5. LC0 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. l l l FERMI UNIT 2 83.6.4.2-5 Revision 5. 04/30/99

SCIVs B 3.6.4.2 BASES SURVEILLANCE SR 3.6.4.2.1 REQUIREMENTS This SR verifies that each secondary containment manual isolation valve and blind flange that is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather. it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position. Since these SCIVs are readily accessible to personnel during normal operation and verification of their position is relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct positions. Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1. 2, and 3 for ALARA reasons. Therefore, the

                   )robability of misalignment of these SCIVs, once they have Jeen verified to be in the proper position, is low.

A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. SR 3.6.4.2.2 Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. l FERMI UNIT 2 B 3.6.4.2 - 6 Revision 5. 04/30/99 l l

f) SCIVs , B 3.6.4.2 l BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.6.4.2.3 Verifying that each automatic SCIV closes on a secondary j containment isolation signal is required to prevent leakage i of radioactive material from secondary containment following L a DBA or other accidents. This SR ensures that each i automatic SCIV will actuate to the isolation msition on a i secondary containment isolation signal. The .0GIC SYSTEM i FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide l 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 l - 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. I l REFERENCES 1. UFSAR. Section 15.6.5.

2. UFSAR. Section 15.7.4.

3. Technical Requirements Manual.

l l l FERMI UNIT 2 B 3.6.4.2 - 7 Revision 5 04/30/99 i 1

SPsco rtcAitod 2.co.st.2.- (A+% s.s.o ) CONTAINMENT SYSTEMS SURVElltANCE RE001REMENTS

              ~ ' S.5.!- SECONDARY CONTAINMENT INTEGRITY shall be demonstrated by:

1 Verifying at least once per 24 hours that the vacuum within the l a. secondary containment is greater than or equal to 0.125 inch of l vacuum water gauge. ;

b. Verifying at least once per 31 days that:

S ee- 1. All secondary containment equipment hatches and pressure

                    )                    relief doors are closed and sealed, and both railroad bay 3

SP 3 . ($.y.1

         ',A b-                          access doors are closed and sealed.                               .,

LI

2. At least one door in each cess to the secondary >

k containment is closed. ( A00 NofE 3 to $ A M. / 7- I g 1, 600 fJok. l Io 6A 3 6.'tl.Z.l . g y ,q,1,g bil secondary containment penetrations except for Steam Tunnel Blowout Panels not capable of being closed by L.3 h q I OPERABLE secondary containment automatic isolation

i dampers / valves and required to be closed during accident R u oin)A4.fiew A.2. sA cono giopp are closed Jb valves, blank flanges, or O s l{eactivated'ajojaQc camle{sTyJipj] secured in the closed C...Andnoflock.4) s'ented or secord posTtT6n. kAdd rdok'514 2. +o Rajuired Ac.hi).- 4.2.

Verifying Steam Tunnel Blowout Panels are closed during each COLO j l $ c. SHUTDOWN if not performed within the previous 31 days. g

d. At least once per 18 months:

 .3 re.                 .

1. Verifying that one standby gas treatment subsystem will draw down the secondary containment to greater than or equal ]

gt;[;g. , to 0.25 inch of vacuum water gauge in less than or equal to - i J.(o.1/. I 567 seconds at a flow rate not exceeding 3800 cfm, and 1

2. Operating one standby gas treatment subsystem for I hour and .

maintaining greater than or ecual to 0.25 inch of vacuum , J water gauge in the secondary containment at a flow rate not exceeding 3000 cfm. 3/4 6 51a Amendment No M , 49 FERMI - UNIT 2 PAGE I 0F 03 N

l-I ShcomeArrod 3 4.% 2-CONTAINMENT SYSTEMS M.l i 2 SECONDARY CONTAINMENT AUTOMATIC ISOLATION DAMPERS LIMITING CONDITION FOR OPERATION ldO .0.0.0 Ihe secondary containment ventilation system automatie isolation O.I f dampers Gr.;.; . '- !=;e ;.0.5.2 'shall be OPERABLE pr. .;e;.Mer n;n# & g*f'g D - - n . n r- --- : :- ;c- - tem ; 2.5.5.: . .- APPLICABILITY: OPERATIONAL N0!TIONS 1, 2, 3 and *. FAoo NOTE s1 L'i Aeo now L} ACTION. [:Aoo em 3 -- Oa.s h #I system automatic l With one or more of the>sec5Kdary contai ventilat isolation dampers sh= - :=:: :. .;.: noperable,Aaintain at seast one2 ,U Osolatton damper OPERABLE in eacn a tecteo penetration that is operfand within I 8 hours either: , _j g g,g g

                        ,      o.....u.            1____    u_   m___,.s       m   mar 3, e .1 _     __-               g,q

b. Isolate each affected penetration by use of at least one deactivated n.ovwd bbe damper secured in the isolation position, or l

     'D a.1          c.      Isolate each affected penetration by use of at least one closed I                               manual valve or blank flange.

1 Otherwise, in OPERATIONAL CONDITION 1, 2, or 3, be in at least HOT 4 A eri u C. SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours. i Otherwise, in Operational Condition *, suspend handling of irradiated fuel AcTioeJ D in the secondary containment, CORE ALTERATIONS and operations with a potential for draining the reactor ve'sel. s The provisions of Specification 3.0.3 are not applicable. - SURVEILLANCE RE0VIREMENTS _ 4.6.5.2 Each secondary contain t ventilation system automatic isolation damper @e all be demonstrated OPERAELE:

                          . Prior          returning th damper to service aft r maintenance, re             ir,] LR,1 or r acement work i performed on the da er or its associa d act tor, control or power circuit by cyc ng the damper the gh at I le st one complete ycle of full travel                    d verifyina the < ecified)
                                 . _ al at i nn + 4 ==                                                                    , 1
   . fg 3.(, y.1 3       b. CTL                                               at least once per 18 months by             (

verifying that ca a containment isolation te t signal each is91ation damper actuates to its isolation position. acLi sesir,wlakd -- R.5

c. By verifying the isolation time to be within its limit when tested 9 h .4.2. t pursuant to Specification 4.0.5.

                 *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.                                                                     .

FERMI - UNIT 2 3/4 6 52 PAGE 5) 0F 03 b5 l-S

DISCUSSION OF CHANGES , ITS: SECTION 3.6.4.2 SCIVs l A.5 CTS 4.6.5.2.b requires the performance of a system functional test of the secondary containment automatic isolation dampers, which includes the requirement for each automatic isolation damper to actuate on a ** test signal." ITS SR 3.6.4.2.3 permits the system functional to be initiated by an " actual or simulated" isolation signal. This change allows satisfactory automatic isolations to be used to fulfill the system functional Surveillance requirement. Operability is adequately demonstrated because the isolation dampers can not discriminate between " actual" or " test" isolation signal. This is an administrative change with no impact on safety because it is a reasonable interpretation of the existing requirement. A.6 CTS 4.6.5.1.b.3 requires verification that the isolated penetration remains closed every 31 days. ITS 3.6.4.2. Note 1 to l Required Action A.2 and Note 1 to SR 3.6.4.2.1, allows for administrative verification when the isolation device is in an 6 area with limited access due to high radiation. Note 2 to Required Action A.2 allows for administrative verification when the isolation device is locked, sealed, or otherwise secured closed. These allowances constitute details of acceptable methods for complying with the CTS requirement for verification. Therefore, this change is editorial in nature and does not involve l a technical change (either actual or interpretational) to the TS. l The change is consistent with NUREG 1433. ' TECHNICAL CHANGES - MORE RESTRICTIVE None l l l 4 l l FERMI UNIT 2 2 REVISION 5 04/30/99l l

i DISCUSSION OF-CHANGES ITS: SECTION 3.6.4.2 SCIVs l TECHNICAL CHANGES LESS RESTRICTIVE l " Generic" ! LA.1 CTS Table 3.6.5.2 1, and various references to it in CTS LCO 3.6.5.2. will be relocated from the Technical Specifications to the Technical Requirements Manual (TRM). The specific relocation of component lists, and their isolation times from Technical l4 i Specifications is consistent with the direction of Generic Letter 9108 " Removal Of Component Lists From Technical Specifications." Relocation of the list of valves and associated maximum isolation > time to the TRM maintains the consistency with NUREG 1433. These l ) details can be adequately defined and controlled by the provisions ! of 10 CFR 50.59. These details are not required to be in the ITS l to provide adequate protection of the public health and safety j since the requirement for valve Operability remains in the j Technical Specifications. ! l LR.1 CTS SR 4.6.5.2.a requires a demonstration of Operability after maintenance or repair on an isolation valve. The proposed change removes this requirement from Technical Specifications. Verifying proper Operability including stroke time of these valves after maintenance on these valves is normal maintenance and operating practice. In addition, the requirement to verify the correct stroke time of these valves per the IST Program is required by ITS SR 3.6.4.2.2. Consequently. Operability of these valves is periodically verified and removal of the explicit requirement to verify Operability of the valve after maintenance is considered acceptable. The removal of CTS SR 4.6.5.2.a maintains consistency with NUREG 1433. Regulatory control of changes to these , requirements (e.g. Technical Specification amendment or 10 CFR i 50.59) is not necessary to provide adequate protection of the public health and safety since these details do not impact the i requirement to maintain the equipment Operable. 1 I I l l l FERMI UNIT 2 3 REVISION 5. 04/30/99l

DISCUSSION OF CHANGES ITS: SECTION 3.6.4.2 SCIVs b Not used. l Eo\ LR.2 c ' TECHNICAL CHANGES LESS RESTRICTIVE

 " Specific" L.1          ITS 3.6.4.2 includes an explicit allowance for intermittently opening closed Secondary Containment Isolation Valves under administrative control as is allowed in the CTS for primary containment isolation valves. The allowance is included in Actions Note 1 and SR 3.6.4.2.1 Note 2. As described in the Bases for ITS 3.6.4.2 Actions, administrative controls that allow this exception consist of stationing a dedicated operator, who is in communication with the control room, at the controls of the isolation device. In this way, the penetration that is opened to               j support an necessary operational activity can be rapidly isolated            j when a need for secondary containment isolation is indicated.                 1 Therefore, this less restrictive change has minimal impact on plant safety.

L.2 CTS 3.6.5.2 Actions for inoperable secondary containment isolation dampers, which requires maintaining one isolation damper Operable, would not be met in the event both dampers in a penetration are inoperable. In this event, an immediate shutdown (per CTS 3.6.5.2 ,

             "otherwise " Action) is required. ITS 3.6.4.2, Action B.                     t provides 4 hours for isolation, prior to commencing a required shutdown. This 4 hour period is consistent with time allowed for an inoperable secondary containment, and is therefore an appropriate allowance.

L.3 CTS 4.6.5.1.b.3 addresses the monthly verification of secondary containment isolation with non automatic valves. By virtue of being associated with CTS 3.6.5.1, any failure of this ; surveillance results in applying either a 4 hour restoration (in ' MODES 1. 2, and 3) or an "immediate" restoration (other required b ; condition). ITS combines all penetration isolation valve y l requirements in ITS 3.6.4.2, and allows an 8 hour restoration. I l Furthermore. ITS Actions apply an allowance for separate Condition ) entry (Actions Note 2). These relaxations provide consistent i treatment for secondary containment penetrations with, inoperable isolation devices. Since these Actions have been found acceptable j for inoperable automatic isolation valves, these changes will not ) introduce any unacceptable impact on safety.

FERMI UNIT 2 4 REVISION S, 04/30/99l j

1 l DISCUSSION OF CHANGES l ITS: SECTION 3.6.4.2 - SCIVs L.4 CTS 4.6.5.2.b requires an automatic isolation valve test, but restricts performance of this test to "during Cold Shutdown or Refueling." ITS SR 3.6.4.2.3 requires this same test, but the l details regarding requisite plant conditions and scheduling is deleted. This is acceptable because these scheduling limitations do not impact the requirement to maintain the valves Operable. Furthermore, the Surveillance test continues to ensure that all automatic SCIVs function properly (note that the ITS Bases mention the basis of the 18 month frequency as being related to the l prudent desire to perform many of these test during a plant outage). These scheduling details are adequately defined and y controlled without direct Technical Specification control. g Regulatory control of changes to these requirements (e.g., -- Technical Specification amendment or 10 CFR 50.59) is not necessary to provide adequate protection of the public health and ( i safety since these details do not impact the requirement to maintain the equipment Operable or the test conditions. l L.5 CTS 4.6.5.1.b addresses the monthly verification of secondary containment isolation with non automatic valves. ITS SR 3.6.4.2.1 l requires this same monthly verification, but excludes valves that l are locked, sealed, or otherwise secured in the closed position. Excluding these valves from the monthly verification is acceptable i based on the controls inherent in locking, sealing or securing the valve after verifying it to be closed. Since the valve is reasonably assured of being closed when required, this change has no negative impact on safety. RELOCATED SPECIFICATIONS None l TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.6.4.2 consistent with the BWR STS. NUREG 1433. Rev. 1. l l FERMI - UNIT 2 5 REVISION 5. 04/30/99l

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 NO - - - - - i hIsolationdevicesin 2, tsolafimd8 vices be $ed t b + d I8' d > use of administrative 8 seAket, of *04%'b' s< ans. t l teencef nwybc - i veined H uSC Verify the affected ofr ad.minIJfr #m Once per 31 days mtar s . . penetration flow path is isolated. (%.5.l. b.3) B. ---

               --NOTE-----           B.1    Isolate the affected      4 hours Only applicable to                     penetration flow path penetration flow paths                 by use of at least with two isolation                     one closed and                         j valves.                                de-activated
     - - - - - - - - - - - - - - -          automatic valve,                      (Doc L.2.)s closed manual valve, One or more                            or blind flange.

penetration flow paths with two SCIVs inoperable. C. Required Action and C.1 Be in MODE 3. 12 hours j associated Completion Time of Condition A 8tiQ

                                                                                /g,4'g'7i j'4,0"\

N j

                                                                                                  / i or B not met in MODE 1, 2, or 3.                 C.2    Be in MODE 4.             36 hours (continued) l l

l BWR/4-GTS 3.6-51 th W.O410y% N6V i i

l

SCIVs 3.6.4.2 ACTIONS (continued) CONDITION REQUIRED ACTION CONPLETION TINE g D. Required Action and D.I T- NOTE---

                                                                      .      s&

associated Completion Time of Condition A LCO 3.0.3 is not applicable. N/g ,4,g'z g*\/ 4 - or B not met during " movement of irradiated fuel assemblies in the y Suspend movement of Isunediately Asecondaryjo irradiated fuel containment, during assemblies in the CORE ALTERATIONS, or jsecondaryk} during OPDRVs. containment. M < D.2 Suspend CORE Imeediately ALTERATIONS. M D.3 Initiate action to Isumediately ' suspend OPDRVs. l l 4 I CR/4-STS 3.6-52 Rerir44/0496 Rd

SCIVs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 - ----- -- NOT E S------------

1. Valves and blind flanges in high poc g,6) l radiation areas may be verified by i use of administrative means.

l

2. Not required to be met for SCIVs that /

are open under administrative N00C. b* I ) C. l c _ _ 'atr'15- ,__

                     ' Verify each secondary containment             31 days orM*D" d isolation manual valve and blind flange I

that is required to be closed during . (,.6./. k 3) l accident conditions is closed. SR 3.6.4.2.2 Verify the is ion time of each power accordan operated automatic SCIV is with the within 11 Inservice C.2 restins .r,s.2.c) fC'9r** **- _" """ ear _ SR 3.6.4.2.3 Verify each automatic SCIV actuates to the isolation position on an actual or (18(months simulated actuation signal. '4'6'1*h 6 3.6-53 Rn 1, 647U7795 t:,

SCIVs 8 3.6.4.2 BASES APPLICABLE established by SCIVs is required to ensure that leakage from SAFETY ANALYSES the primary contairraent is processed by the Standby Gas (continued) Treatment (SGT) System before being released to the environment. Maintaining SCIVs OPERABLE with isolation times within , limits ensures that fission products will remain trapped l by the SGT Systes (prior to discharge to the environment.insid l l O[.(>SCIVs satisfy Criterion 3 of %SkMOS "aC Mig ::tets.t LCO SCIVs form a part of theVsecondaryy' containment boundary. The SCIV safety function ns related to control of offsite i radiation releases resultina from D8As. I Wf9f5eND The power operated solau on ru ves are considered OPERABLE l when their isolation times are within limits and the valves l actuate on an automatic isolation signal. The valves I covered by this LCO, along with their associated stroke times, are listed in Reference 3. (thenormall closed isolation v ves or blind flange are considered PERABLE when manu valves are closed o open in p accordan with appropriate inistrative contro , I*g automat SCIVs are de-act ated and secured in eir closed l positi , and blind flan are in place. The passive isol ion valves or dev es are listed in Re rence 3. APPLICABILITY In MODES I, 2, and 3, a DBA could lead to a fission produc.t , release to the primary containment that leaks to the l Tsecondary)< containment. Therefore, the OPERABILITY of SCIVs is required. l In MODES 4 and 5, 'the probability and consequences of these events are reduced due to pressure and temperature-Itaitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant radioactive releases can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE (continued) ng sis 8 3.6-103 kv 1, 04/07/95 Revf

SCIVs . 8 3.6.4.2 BASES ACTIONS A.1 and A.2 (continued) isolate the penetration, and the probability of a DBA, which requires the SCIVs to close, occurring during this short time is very low. For affected penetrations that have been isolated in accordance with Required Action A.1, the affected penetration must be verified to be isolated on a periodic i basis. This is necessary to ensure that ={secondarfk- i containment penetrations required to be isolated following l an accident, but no longer capable of being automatically ' isolated, will be in the isolation position should an event occur. The Completion Time of once per 31 days is appropriate because the valves are operated under administrative controls and the probability of their misalignment is low. This Required Action does not require any testing or device manipulation. Rather, it involves verification that the affected pe at isolated. Required Action A.2 is modified b Note 6 applies to devices located in high radiation areas and allows them to b be verified closed by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of g l I misalignment, once they have been verified to be in the ' [ proper position, is low.A j j 63@_f_b L1 With two SCIVs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 4 hour Completion Time is reasonable considering the time required to isolate the penetration and the probability of a DBA, which requires the SCIVs to close, occurring during this short time, is very low. The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths (continued) SWRf+-SYS- B 3.6-105 Rev-tr44/07/95-

SCIVs B 3.6.4.2 Insert B 3.6.4.2-1 l Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing l components is to ensure that these devices are not inadvertently repositioned. l l l

l FERMI UNIT - 2 Page B 3.6-105 (INSERT) Revision 5, 04/30/99 l

SCIVs B 3.6.4.2 BASES ACTIONS A d (continued) with two isolation valves. This clarifles that only Condition A is entered if one SCIV is inoperable in each of two penetrations. C.1 and C.2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 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. D.1. D.2. and D.3 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply. If applicable, CORE ALTERATIONS and the movement of irradiated fuel assemblies in the strecondary)< containment must be immediately suspended. Susper.sion of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Acti continue until 0PDRVs are suspended. Required Actio- --- --- been modified by a Note stating that 'g LCO 3.0.3 is not applicable. If moving irradiated fuel ,y assemblies while in MODE 4 or 5 LCO 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. I (continued) SWR /44TS- B 3.6-106 Rey-i m fo7/gs_ 6V b l 1 l .. . . ..

SCIVs B 3.6.4.2 BASES (continued) SURVEILLANCE SR 3.6.4.2.1 Wlodeado d ebs W REQUIREMENT %

                                                         @A .sw.e4 ;

This SR verifies that each secondary agg;a nual 5 isolation valve and blind flange that is Yequired to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids-or gases outside of theTs'ocondargcontainment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in$econdary}Ccontainment that are capable of being mispositioned are in the correct position. Since these SCIVs are readily accessible to personnel during normal operation and verification of their position is relatively easy, the 31 day Frequency was chosen to provide added assurance that the SCIVs are in the correct positions. Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high ; radiation areas and allows them to be verified by use of ' administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these SCIVs, once the been verified to be in the proper position, is low. y have A second Note has been included to clarify that SCIVs that are open under administrative controls are not required to meet the SR during the time the SCIVs are open. SR 3.6.4.2.2 g 'g Verifying that the isolation time of each power operated.andr

automatic SCIV is within limits is required to demonstrate OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and frequency of this SR are Tin accordance with the Inservice Testing Program = 92 t ys].

(continued) GG/4 STS B 3.6-107 Rev 1, v4/6ff95--

l JUSTIFICATION FOR DIFFERENCES FROM NUREG - 1433 ITS: SECTION 3.6.4.2 - SCIVs NON-BRACKETED PLANT SPECIFIC CH ANGES P.1 Not used. l l P.2 Not used. P3 Not used. P.4 The Bases Background reference to DBAs is general- not specific only to LOCAs, l which is what Reference 1 entails. Eliminating reference to the UFSAR Section ; for LOCA safety analyses will have no impact on the Bases content or l understanding. ! P.5 The Bases discussion of normally closed SCIVs is eliminated. This editorial I preference is based on incomplete (and therefore potentially misleading) discussion of these valves, as well as an inconsistent level of detail when compared to other isolation devices. Elimination of this detail does not modify the requirements, or the interpretation of those requirements. , l The LCO Bases are intended to provide a few details regarding OPERABILITY. These details are not all-encompassing, but only serve to outline salient features (in this case of SCIV OPERABILITY). The paragraph discussing abnorm' ally closed SCIVs attempts to define OPERABILITY of these valves, but makes statements that are not true in all cases. There maybe lines with normally closed SCIVs where & the SCIV could be an automatic isolation valve. These valves are NOT required to 1 be " deactivated and secured in their closed position" to be OPERABLE. Also, cr blind flanges are addressed as part of the secondary containment boundary, and do M not support OPERABILITY of normally closed SCIVs. Even with elimination of the erroneous discussions, this paragraph provides no necessary detail regarding OPERABILITY, and can be deleted without loss of information useful to the Operator in determining OPERABILITY. It is not deemed necessary to expound on any OPERABILITY criteria for normally closed SCIVs. ! P.6 The reference to the NRC Policy Statement has been replaced with a more appropriate reference to the Improved Technical Specification " split" criteria found l in 10 CFR 50.36(c)(2)(ii). l l l FERMI- UNIT 2 1 REVISION 5, 04/30/99 l

1 NO SIGNIFICANT HAZARDS EVALUATION ) ITS: SECTION 3.6.4.2 SCIVs 1 TECHNICAL CHANGES - LESS RESTRICTIVE i (Soecification 3.6.4.2 "L.3" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change l identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. j The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against i each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the ) evaluation are presented below. l

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? y s 1 This change relaxes the Actions to provide consistent treatment for M l I

secondary containment penetrations with inoperable non automatic I isolation devices. Tnis change will not result in a significant increase in the probability of an accident previously evaluated because secondary containment isolation is not considered as an initiator of any previously analyzed accident. This change will not result in a significant increase in the consequences of an accident previously evaluated since these Actions have been found acceptable for inoperable i automatic isolation valves: this change only consistently applies this approved allowance to other penetration inoperabilities.

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

The proposed change does not involve any physical changes to plant systems, structures, components (SSC) or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. FERMI - UNIT 2 5 REVISION 5, 04/30/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 SCIVs TECHNICAL CHANGES LESS RESTRICTIVE l (Soecification 3.6.4.2 "L.3" Labeled Comments / Discussions) l

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

l The change relaxes the Actions to provide consistent treatment for hs I secondary containment penetrations with inoperable non-automatic T isolation devices. These Actions have been found acceptable for Q inoperable automatic isolation valves: this change only consistently y l applies this approved allowance to other penetration inoperabilities. l l Therefore, this change will not significantly affect the margin of l safety. l l l l FERMI - UNIT 2 6 REVISION 5 04/30/99l

l NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 - SCIVs TECHNICAL CHANGES - LESS RESTRICTIVE , (Soecification 3.6.4.2 "L.4" Labeled Comments / Discussions) l Detroit Edison has evaluated the proposed Technical Specification change identified as "Less Restrictive" in accordance with the criteria specified by 10 CFR 50.92 and has determined that the proposed change does not involve a significant' hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below.

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

This change eliminates an explicit limitation on scheduling the test of automatic isolation for Secondary Containment Isolation Valves. This g g change will not result in a significant increase in the probability of - an accident previously evaluated because secondary containment isolation is not considered as an initiator of any previously analyzed accident. This change will not result in a significant increase in the consequences of an accident previously evaluated because the proposed surveillance testing continues to provide an acceptable test of the OPERABILITY of the Secondary Containment Isolation Valves.

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

The proposed change does not involve any physical changes to plant systems, structures, components (SSC) or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. FERMI - UNIT 2 7 REVISION 5. 04/30/99l

r.- N0 SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 - SCIVs TECHNICAL CHANGES LESS RESTRICTIVE l (Soecification 3.6.4.2 "L.4" Labeled Comments / Discussions) l l

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

This change eliminates an explicit limitation on scheduling the test of , automatic isolation for Secondary Containment Isolation Valves. The A l proposed surveillance testing continues to provide an acceptable test of the OPERABILITY of the Secondary Containment Isolation Valves. ( ) l Therefore. this change will not significantly affect the margin of ( ( safety. l l l l 1 1 l l 1 l FERMI UNIT 2 8 REVISION 5. 04/30/99l

NO SIGNIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 SCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.4.2 "L.5" Labeled Comments / Discussions) Detroit Edison has evaluated the proposed Technical Specification change l identified as "Less Restrictive" in accordance with the criteria specified by i 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. The bases for the determination that the proposed change does not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92. The criteria and the conclusions of the evaluation are presented below. l l l

1. Does the change involve a significant increase in the probability or !'

consequences of an accident previously evaluated? This change excludes the monthly position verification for valves that are locked, sealed, or otherwise secured in the closed position. This change will not result in a significant increase in the probability of l an accident previously evaluated because secondary containment isolation

     .is not considered as an initiator of any previously analyzed accident.

h j

     'This change will not result in a significant increase in the                   l consequences of an accident previously evaluated because the proposed        1 exception continues to provide an acceptable assurance that the valve will be in the closed position when required.                                {

2. Does the change create the possibility of a new or different kind of l accident from any accident previously evaluated? I The proposed change does not involve any physical changes to plant systems, structures, components (SSC) or changes in normal plant operation. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

i FERMI - UNIT 2 9 REVISION 5 04/30/99l

NO SIGIIFICANT HAZARDS EVALUATION ITS: SECTION 3.6.4.2 - SCIVs TECHNICAL CHANGES LESS RESTRICTIVE (Soecification 3.6.4.2 "L.5" Labeled Comments / Discussions)

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

This change excludes valves that are locked, sealed. or otherwise I secured in the closed position. The proposed exception continues to I, provide an acceptable assurance that the valve will be in the closed position when required. Therefore, this change will not significantly affect the margin of safety. l 1 1 2 10 REVISION 5, 04/30/99l 1

l l SGT System I 3.6.4.3 ACTIONS i CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend movement of Immediately irradiated fuel assemblies in secondary containment. 8NQ C.2.2 Suspend CORE Immediately , ALTERATIONS. l l ANQ 1 l C.2.3 Initiate action to Immediately I suspend OPDRVs. D. Two SGT subsystems D.1 Enter LC0 3.0.3 Immediately inoperable in MODE 1

2. or 3.

E. .Two SGT subsystems - ---

                                                 --NOTE-- --      -- --                        '

inoperable during LC0 3.0.3 is not applicable. n) movement of irradiated - -- --- -- --- - - fuel assemblies in the 'i secondary Immediately E.1 Suspend movement of k containment, during CORE ALTERATIONS or irradiated fuel assemblies in during OPDRVs. secondary containment. 6N_Q (continued) j FERMI UNIT 2 3.6 41 Revision 5 04/30/99

~ SGT System B 3.6.4.3 1 B 3.6 CONTAINMENT SYSTEMS B 3.6.4.3 Standby Gas Treatment (SGT) System BASES BACKGROUND The SGT System is required by 10 CFR 50. Appendix A GDC 41, i

                               " Containment Atmosphere Cleanup" (Ref. 1). The function of     l the SGT System is to ensure that radioactive materials that     I leak from the primary containment into the secondary            ;

containment following a Design Basis Accident (DBA) are l filtered and adsorbed prior to exhausting to the !

                              -environment.

bl 3 The SGT System consists of two independent fully redundant subsystems, each with its own set of ductwork, dampers, k charcoal filter train, and controls. Each charcoal filter train consists of (components listed in order of the direction of the air flow):

a. A moisture separator: .

1

b. A prefilter: !

c. An electric heater:

d. A high efficiency particulate air (HEPA) filter:

e. A charcoal adsorber:

f. A second HEPA filter:

g. An exhaust fan: and

h. A cooling air fan installed in parallel with the exhaust fan.

The sizing of the SGT System equipment and components is based on the results of an infiltration analysis, as well as an exfiltration analysis of the secondary containment. The internal pressure of the SGT System boundary region is maintained at a negative pressure of 0.25 inches water gauge when the system is in operation, which maintains a negative pressure that precludes direct leakage out of the secondary containment, c l FEP.MI UNIT 2 83.6.4.3-1 Revision 5, 04/30/99 l

SGT System B 3.6.4.3 BASES ACTIONS (continued) E.1. E.2. and E.3 When two SGT subsystems are inoperable, if applicable. CORE ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe msition. Also, if applicable, actions must immediately a initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product i release. Actions must continue until 0PDRVs are suspended. Ql . The Required Actions have been modified by a Note stating l that LC0 3.0.3 is not applicable. If moving irradiated fuel 4 assemblies while in MODE 4 or 5. LC0 3.0.3 would not spacify any action. If moving irradiated fuel assemblies while in MODE 1. 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. j j i SURVEILLANCE SR 3.6.4.3.1 ' REQUIREMENTS Omrating each SGT subsystem from the control room with flow t1 rough the HEPA filters and charcoal adsorbers for = 10 continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for = 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in ' consideration of the known reliability of fan motors and controls and the redundancy available in the system. 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. 3). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical l FERMI - UNIT 2 83.6.4.3-5 Revision 5. 04/30/99

I PE CIFico T10td r 3bY3 CONTAINMENT SYSTEMS STANDBY GAS TREATMENT SYST @ LIMITING CONDITION FOR OPERATION 3.6.5.3 Twof andby gas treatment subsystems shall be OPERABLE. APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, and *. ACTION:

a. With one standby gas treatment subsystem inoperable, restore the bSN b inoperable subsystem to OPERABLE status within 7 days, or:

1. In OPERATIONAL CONDITION 1, 2, or 3, be in at least HOT AC.T10A1 b SHUTDOWN within the next 12 hours and in C')LD SHUTDOWN within the folio ing 24 hours.

k[ ADO 2. Repirul Ac.b CCondition In Operational I *, suspend handling of irradiated fuel in the secondary containment, CORE ALTERATIONS and ' 04 6 operations with a potential for draining the reactor vessel. l The provisions of Specification 3.0.3 are not applicable,

b. With both standby gas treatment subsystems inoperable in

   $cTtord E           Operational Condition *, suspend handling of irradiated fuel in the secondary containment, CORE ALTERATIONS or operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable.

(Acmoo 0 - Ace > - 4 . 2. SURVElllANCE REOUIREMENTS 4.6.5.3 Each standby gas treatment subsystem shall be demonstrated OPERABLE:

a. ;;;O SR J,6,4,3,l At_thre;.:h ff6 least once per "Mer:

the HEP" 31 daysIby wtuting,

nd chirces' free id::rk ri tne ::r.tr:p;ifying e,.ujver that the subsystem operates for at least 10 hours with the heaters koperat4@ ,3

          *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.

FERMI - UNIT 2 3/4 6-54 PAGE / OF 03 b

DISCUSSION OF CHANGES ITS: SECTION 3.6.4.3 STANDBY GAS TREATENT (SGT) SYSTEM TECHNICAL CHANGES - LESS RESTRICTIVE " Generic" LA.1 The following CTS details for performing Surveillances are not included in the ITS. These detailed methods for performing Surve111ances will be moved to the Bases:

a. CTS 4.6.5.3.a details the method of starting a subsystem

(" initiating, from the control room.") and details of system operation (" flow through the HEPA filters and charcoal adsorbers");

b. CTS 4.6.5.3.d.2 system functional test actuation includes details of system operation (" starts and isolation dampers open"): and

c. CTS 4.6.5.3.d.4 contain details the method opening and starting the filter cooling bypass dampers and fan (" remote manually") .

These details can be adequately defined and controlled in the Bases. Changes to the Bases require change control in accordance with Chapter 5 of the ITS. These details are not required to be in the ITS to provide adequate protection of the public health and safety since the details in the ITS are adequate for performing the required Surve111ances. LA.2 CTS LCO 3.6.5.3 provides a detail defining the SGT System (i.e..

            " independent"). The details relating to system design, function, and Operability are not necessary in the ITS. This detail is relocated to the ITS Bases (which requires change control in accordance with ITS 5.5.10. Bases Control Program). The                   j  4 relocation of this information maintains the consistency with              ,

NUREG 1433. The definition of Operability and 10 CFR 50.59 5 provide sufficient control of the design details. These details & are not required to be in the ITS. and ITS LCO. to provide adequate protection of the public health and safety, because these details do not impact the requirement to maintain the equipment Operable. FERMI UNIT 2 2 REVISION 5 04/30/99l 1

DISCUSSION OF CHANGES ITS: SECTION 3.6.4.3 STANDBY GAS TREATNENT (SGT) SYSTEM KCHNICAL CHANGES LESS RESTRICTIVE l " Specific" L.1 CTS 3.6.5.3. Action a.2. requires that the applicable activities (handling irradiate fuel. Core Alterations, and OPDRV) must be suspended immediately if one inoperable standby gas treatment subsystem cannot be returned to Operable status within 7 days. Under the same conditions. ITS 3.6.4.3. Required Action C.1. allows these applicable activities to continue if the Operable subsystem of SGT is placed in operation. This new option is acceptable because the action ensures that the remaining Operable subsystem is sufficient to mitigate any accident: since operating. no failures that could prevent automatic actuation can occur; and any other failure will be readily detected. Therefore, this change does not significantly affect safety. RELOCATED SPECIFICATIQNS None TECHNICAL SPECIFICATION BASES The CTS Bases for this Specification have been replaced by Bases that reflect the format and applicable content of ITS 3.6.4.3 consistent with the BWR STS. NUREG 1433. Revision 1. FERMI UNIT 2 3 REVISION 5. 04/30/99lh

r SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend movement of Imediately irradiated fuel assemblies in 8.4 TS, AcTtod d..h (secondaryK containment. O i C.2.2 Suspend CORE Imediately ALTERATIONS. l C.2.3 Initiate action to Imediately suspend OPORVs. j D. Two SGT subsystems D.1 Enter LCO 3.0.3 Immediately inoperable in MODE 1, 2, or 3. 00( O.2.\y n E. Two SGT subsystems inoperable during movement of irradiated h e- +- NOTE - - ---

                                      ~LCO 3.0.3 is not applicable.~

o k i fuel assemblies _in the --------------------- g g ,g,3 ggg l secondary / p[ontainmen c , during # Suspend movement of Imedia ely CORE ALTERATIONS, or irradiated fuel during OPDRVs. assemblies in I Msecondaryi? D o c [,1 ! containment. g i I (continued) 1 I SWR /4-GTS 3.6-55 R + 1. 6410495 06 T

SGT System B 3.6.4 3 0 8 3.6 CONTA!W1ENT SYSTEMS 8 3.6.4.3 Standby Gas Treatment (SGT) System BASES BACKGROUND The SGT System is required by 10 CFR 50, Appendix A. GDC 41,

                                       " Containment Atmosphere Cleanup" (Ref.1). The function of the SGT System is to ensure that radioactive materials that leakfromtheprimarycontainmentintothe,1(econdar                      l containment following a Design Basis Accident (DBA)      are F      j filtered and adsorbed prior to exhausting _to_ the                d environment.

4 The SGT System consists of two fully redundant subsystems, each with its own set of ductwork, dampers, charcoal filter train, and controls. Each charcoal filter train consists of (components listed in order of the direction of the air flow):

a. A dentetepuer moisture separator; C, .

Anelectrichea~t% 6 g A profilter;

d. A high efficiency particulate air (HEPA) filter;

e. A ' charcoal adsorber;

f. A second HEPA filter; a b, )( d h k 1 fany '3 (Co bS ^ 'f , g.

     % ta ta IIeo                     Th>e sizing of the SGT System equipment and components is m[2-fW A Uel W'M               .

based on the results of an infiltration analysis, as well as g g ""54 / an exfiltration analysis of thepcondarff" containment. The internal pressure of the SGT System boundary region is

   .f g                              maintained at a negative pressure of>fC.257 inches water gauge when the system is in operation, which resie;=n d the
                                     .internel-press.ie i wv;.       is ensurs zero exfiltration of Mal.ii' I^ #         n&          iir-from-the-building-$then-exposed-to-e-flyj spn^ wind lowing-at-an.angleaf--[45]'-to-the buihing_

d W pre . P g e( dNf'o[f O(4 The iaier is rovided to remove entrained water in the air while the e actric heater reduces the relative humidity in e4I' N' "" (continued) L 4WR/4 sis B 3.6-109 Re 1, 04/07/95-kW

SGT System ! B 3.6.4.3 BASES l ACTIONS E.1. E.2. and E.3 (continued) draindown and subsequent potential for fission product release. Actions continue until OPDRVs are suspended. q h Required Acti E -r been modified by a Note statin that l LC0 3.0.3 is not applicable. If moving irradiated fue W j assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify i any action. If moving irradiated fuel assemblies while in ! MODE 1, 2, or 3, the fuel movement is independent of reactor i operations. Therefore, in either case, inability to suspend ! movement of irradiated fuel assemblies would not be a sufficient reason to require a reacter shutdown. c -

                                                        ~       _.

SURVEILLANCE SR 3.6.4.3.1 Crum k cw4tol room WH4 flow hrw3k

                                          +W SEPA h\krs ad cWcoat adsubers Operating each SGT subsystem                                s ensures that;fbothysubsystems are PERABLE and that all h.4                associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation
                   #fGIlth the heaters on (automatic heater cycling to maintain temperature}}<for 2410)< continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.

SR 3.6.4.3.2 This SR verifles 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. 3). 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. (continued) M /4 575 B 3.6-113 R:V 1, 04/07/ W f E\/ Y

INSERT THIS PAGE IN FRONT OF VOLUME 11 Volume 11: CTS MARKUP COMPILATION-Remove Replace 3.6.1.2 CTS hW (3/4 6-9) pg 2 of 2 3.6.1.2 CTS M/U (3/4 6-9) pg 2 of 2 Rev 5 l 3.6.1.5 CTS M/U (3/4 6-13) pg i of 1 3.6.1.5 CTS AW (3/4 6-13) pg 1 of 1 Rev 5 3.6.2.1 CTS hW (3/4 615) pg 1 of 3 3.6.2.1 CTS M/U (3/4 6-15) pg 1 of 3 Rev 5 3.6.2.1 CTS M/U (3/4 6-16) pg 2 of 3 3.6.2.1 CTS M/U (3/4 6-16) pg 2 of 3 Rev 5 3.6.2.2 CTS M/U (3/4 6-16) pg 4 of 5 3.6.2.2 CTS M/U (3/4 6-16) pg 4 of 5 Rev 5 3.6.2.1 CTS hW (3/4 6-17) pg 3 of 3 3.6.2.1 CTS M/U (3/4 6-17) pg 3 of 3 Rev 5 l 3.6.2.2 CTS M/U (3/4 6-17) pg 5 of 5 3.6.2.2 CTS hW (3/4 6-17) pg 5 of 5 Rev 5 3.6.1.8 CTS M/U (3/4 6-49) pg 2 of 2 3.6.1.8 CTS M/U (3/4 6-49) pg 2 of 2 Rev 5 3.6.1.7 CTS M/U (3/4 6-50) pg 1 of 1 3.6.1.7 CTS M/U (3/4 6-50) pg i of 1 Rev 5 3.6.4.2 CTS M/U (3/4 6-51a) pg i of 3 3.6.4.2 CTS M/U (3/4 6-51a) pg i of 3 Rev 5 3.6.4.2 CTS M/U (3/4 6-52) pg 2 of 3 3.6.4.2 CTS M/U (3/4 6-52) pg 2 of 3 Rev 5 3.6.4.3 CTS M/U (3/4 6-54) pg 1 of 3 3.6.4.3 CTS M/U (3/4 6-54) pg 1 of 3 Rev 5 l Rev 5 04/30/99

                                                                           .crEc iFic ATroAl 3 6 o I . 7_.               I

(/ffs e s e e.fS ec t f**c aflan C. S) CONTAINMENT SYSTEMS & SURVEILLANCE REOUTREMENTS

4 ADO SR .l b e la b.ol f(/oTG,$ I 4 3, 5A3 4,8 Al 4.f,. .3 Eac primary containment air lock shall Pros Ces tM Lea t: byg znw demonstratedOPERABLE:k1 Pry

4. Within 7 days following each closing, except wnen the air lock is being used for multiple entries, then at least once per 30 days, ,9 by verifying seal leakage rate less than or equal to 5 scf per i hour when the gap between the door seals is pressurized to Pai 56.5 psig. l l

Prior to establishing PRIMARY CONTAINMENT INTEGRITY when the air l b. lock has been opened during periods when containment integrity was l not required. The demonstration shall verify a seal leakage rate l j less than or equal to 5 sef per hour when the gap between the door seals is pressurized to P 56.5 psig, unless the air lock is i

      $ce                  testedpursuanttoSpecific,ation4.6.1.3.c.2.

6geceFicais'o ri c. By conducting an overall air lock leakage test at P , 56.5 psig,

        'p                  and by verifying that the overall air lock leakage rate is within its limit:

1. Prior to initial fuel loading and at 30 months

intervals j thereafter,

2. Prior to establishing PRIMARY CONTAINMENT INTEGRITY when the air lock has been opened during periods when containment integrity was not required, if maintenance which could affect the leak tight integrity of the doors has been performed since the last successful test rsuant to Specification 4.6.1.3 _ ,

d. At least once per@ by verifying that only one door in each 6f 33 *I'2'1 air lock can be opened at a time.**

See f g ,,7fe,t;,

                *The provisions of Specification 4.0.2 are not applicable.
                       ' that       inner do      need not     opened to ver y interlock
     'I[   !       ERABILI' wher) the         mary   cont  nment   is iner      , provided;   t the        i door i riock is t          ed withi      hours   after t    primary   co ainmen been einerted.

3/4 6 9 Amendment No.108 FERMI - UNIT 2 Corrected August 19. 19 % PAdE 1 0F 02 Rev f

                                                                               ^5pecnicaf to rt 3.&,16         j i

CONTAINMENT SYSTEMS i DRYWELL AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION l 1 l.CO 3./../.C .6.i.7 Drywell average air temperature shall not exceed 145'F. l ) APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. ) ACI1Qt[: With the drywell average air temperature greater than 145'F, reduce the j jddj average air temperature to within the limit within 8 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the i g.fg g following 24 hours. j l l SURVEILLANCE REOUTREMENTS SR 3.4. I 4.0.1.7 a 7'I "he drvwell average air temperat 11 he v M ric avefage 7 $ .l l f (afdheMineratertrs at t W o' lowifnf loc sa /5 hall be determined to be ! within the limit at least once per 24 hours: levation A2Midh (At le st one at each elevation) I 90', 135S N

a. '0" 70* or 316'

                          . 597'0"                     , 75', 93', 135', 175'     00', 246',

4

                                        '               272', 306* or 345'                         g,j

c. 8" .- 0*, 90', 180* 270' d 648'6" 45', 135' 25' or 315'

e. 662'0" 0* , 180* or 2 l f. J '6' /O' or 180' FERMI - UNIT 2 3/4 6-13 Amendment No. 20 PAGE OF 01

9ECI Pica 170^) 3.lo.2.. \ Also see. SpsclAca Ho>, 3.c,.i.1 ) CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION SYSTEMS ['} dho 544 6/44MIGb'n F 3 6.2.2.)

SUPPRESSION CHAMBER LIMITING CONDITION FOR OPERATION LC,0 3.6.2.1 @h: : - n m. :h:" h ^"E"f 5 5 Nith:

a. The )on1 water:

                                            ~ Volume between 121,080 ft3 and 124,220 ft3 , equivalent to a 3 heg,1.

P level between 14'4" (-2 inches indication) and 14'8" (+2 inches indicationi and a 3*b' 2. Maximum average temperature of 95'Ffduring OPERATIONAL M >1* lek 3.4.2.l l.co /kt) A, (CONDITION _1 or 2, exce,,pt(that the piaximum average temperature

~ may be permitted to inc7e~ase to:

tco g% g, a) 105*F during testing which adds heat to the suppressionjP' g,7, chamber. b) 110*F with lfHERMAL POWER less than or equal to 1% of) LCD flue 4 C.. (ItATED THERMAL POWER.f Maximum average w-.- nure or m durino norutins E'3 hCTrolj p.)3}F nuntrinN 1r except that the maximum average temperature may be permitted to increase to 120*Fmm we m9 9nm v int 5# m= = n:: : n wing a scram. A total leakage cetween the suppression chamber and drywell of less M'M'" 34.l d

b. than the equivalent leakage through a 1-inch diameter orifice at a differential oressure of approximately 1 psid.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. ACTION:

a. With the suppression chamber water level outside the above limits, SR restore the water level to within the limits within 1 hour or be in Spe c.\(iccch,er- at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN

3. (, .*L ~2 - within the followina 24 hours.

b With the suppression chamber average water temperature greater than ACTiotJ f . 95'F, restore the average temperature to less than or eaual to 95'F g within 24 hours or be in at least PiOT 5HUIDOWN within the next Iz nours anc in LULD 5HUIDOWN within the following 24 hours, excep dCild 3 s cermitted above %; a/, gT P ). ' (

l. With the suppression chamber.' average water temperature greater ACTroPJC than 105*FvduFiWg"tesfincy kh'ich adds heat to the suppression chamber, stop all testing which adds heat to the suppression

                              , ,, .    ..,_chamben, '~aWd restore the average temperature to less than 95'F A cT1oeJ A                           within 24 hours or be in at leastAios dHuiUOwn witnin die next DON O                               (ITnours and in CULU SMUiUOWN within the followino 24 hours.

2. With the suppression chamber average water temperature greater 4.y, than:

95'F for more than 24 hours and THERMAL POWER greater BDNA a) than 1% of RATED THERMAL. POWER, be in at leastJ6Tl ACT70el b h r ACT70tjp b) 110*F, place the reactor mode switch in the Shutdown position Ano opprate at leasyone residua)/ heat rep 0vaD D QQop vf t1e suderptsien cony coolina modf/ 4 EON g 3. With the suppression chamber average water temperature greater than 120*F, depressurize the reactor pressure vessel to less than 200 psig within 12 hours.

                                                                        \          M./

N fA00:Reaazo Acnors D.5 FERMI - UNIT 2 86avoeen Ac rmJ EW 3/4 6 15 lE l PAGE OF 03 //ev 5~

Spearmon s.c,.2.1 [6 su s em cons.c././ ) CON"A'NMENT SYSTEMS (Aho su s eih cahai a c.z..z )

               .IM T' NG CONDITION FOR OpEpATION (Continued)

M ,Qti; (Continueo) ,

c. A lth one shyprus on puoi weser s.=,.. ^ . . .nurumentation channe inoperable, ve fy suppression pool w er temperature to within limits at le t once per 12 hours.

l l 1. If $RV actuation has oc rred since the cha el was d ared inoperable, the verage suppression col water erature shall be c uted as follows: e maximum ,g temperature indicati of the seven OPE E channels shall be Q'l used as the tempera re indication of t inoperable channel in computing the pool. erage water temper ure in the suppressio l (- 1 j 2. If an SRV a uation has occurred ince the channel was declared operable, for a .per d of 48 hours followin he SRV act tion. the average s ression pool water t rature shall e computed as follow . The maximum temperatu l ind ation of the seven OP BLE channels snall be neressed l by 5*F-and shall be use as the temperature indi ion of the I operable channel in mouting the average wat temperature n the suppression p 1. After 48 hours tne a rage water temperature snali computeo as described i ction c l.

d. th more than one s pression pool water temper ture e instrumentation ch el inoperable, restore at east seven temperature inst entation channels to OPE LE status within khoursorbein least HOT SHUTDOWN withi he next 12 hours nd in TOLD SHUTDOWN ithin the following 24 hou

e. With one narrow range suppression chamber water level instrumentation enannel inoperable, restore the inoperable narrow i i g range suppression enameer water. level channel to OPERABLE status j i within 7 days or verify suppression pool water level to be within

      $ptdpica g'M                 the limits at least once per 12 hours.

3.6.L 2. With both narrow range suppression chamber water level f. l instrumentation channels tnoperable, restore at least one I suppression chamber water level enannel to OPERABLE status within 8 ! hours or be in at least HOT SHUTDOWN within the next 12 hours and in I (COLD SHUTDOWN within the following 24 h6urs. 5A g. With the drywell-to-suppression chamber leakage in excess of the gf4c,ihcaQ limit, restore the oypass leakage to within the limit prior to 1( .bl increasing reactor coolant temperature above 200*F. SURVElllANCE RE0VIREMENTS su 4.6 .1 I ression enamoer snall De oemonstrated OPERABLL: i g f,ca b 3,G,q,,'1 4. verifying the suppression chamoer water volume to be within the limits at least once per 24 hours. I b. At least once per 24 hours in OPERATIONAL CONDITION 1 or 2 by l M 3'W'I verifying the suppression chamber average water temperature to be less than or eaual to 95*F, except: FERMI UNIT 2 3/4 6 16 t I PAGE A 0F 03 fevr

Sycc[hdce hkn L L2 2

                                                                   &lSo          se e S pecifcaSon S 3. 6. lo l            l CONTA'NMENT SYSTEMS ua 3.c.2 0 LIM' T' NG CON 01 TION FOR OpEpATION (Continued)

Agl21: (Continuso)

g. With one suppression pool water temoerature instrumentation channel inoperable, verify suppression pool water temperature ta be within limits at least once per 12 hours.

1. If nor SRV actuation has occurred since the channel was j declared inoperable, the average suppression pool water J temperature shall be computed as follows: The maximum I temperature indication of the seven OPERA 8LE channels shall be used as the temperature indication of the inoperable channel in computing the average water temperature in the suppression i pool. l

2. If an SRV actuation has occurred since the channel was declared inoperable, for a seriod of 48 hours following the f SRV actuation, the average suppression pool water temperature Yg shall be computed as follows: The maximum temperature Mp indication of the seven OPERABLE channels shall be increased by 45'F-and shall be used as the temperature indication of the l

[S.g ,7.\ inoperable channel in computing the average water temperature I in the suppression pool. After 48 hours tne average water temperature shall be computec as described in action col.

d. With more than one suppression pool water temperature i instrumentation channel inoperable, restore at least seven i temperature instrumentation channels to OPERABLE status within 8 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.

f e'." kthonenarr range suppression chamber water level .,1, instrumen on channel noperable restore the inoperabl narrow l k'2' range pression c er water. lev channel to OPE status with 7 days or rify suppress pool water lev to be within t limits at ast once per ours. [ With both arrow range s instrum tation chann ression chambe ater level inoperable. re) are at least on supprpfIston chamber ater level chanpel to OPERABLE s us within 8 hourt or be in a east HOT SHUTOOWN within the ne 2hoursandinj Q0LDSHUTDOWNw~thinthefollowing24h6urs. 7

g. With the drywell-to suppression chamber leakage in excess of the Sc 6 . d.\ limit, restore the bypass leakage to within the limit prior to 5 ef4g,\ increasing reactor coolant temperature above 200'F. Q,j SURVEILLANCE REOUIREMENTS 4.6.2.1 a.

Ine suppression enamoer snail De oemonstratect OP RABLL: By verifying the suppression chamber water 6 within the_ bd d 3.6.2.2.I b. limits at least once per 24 hours. At least once per 24 hours in OPERAT!ONAL CONDITION 1 or 2 by verifying the suppression chamber average water temperature to be less than or equal to 95'F. except: 6C gtM.IA

       ,6 0\

FERMI - UNIT 2 3/4 6-16 PAGE b 0F 05

5 f e cif-icafe> rt. L 6.2.I f

h (.4,c) 5,e.c 6peciNede' ort 3. d., l , I ) j

;                                                                         ( A(50 see Qeci6cadiort % 2.2)                               1 CONTAINMENT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

1. At least once per 5 minutes during testing which adds heat to (

6 Il 3 .(,. 2.. J. I the suppression chamber, by verifying the suppression chamber 1 average water temperature is less than or equal to 105T. i o At least once per hour when suppression chamber average water Q,4 ' 2. temperature is greater than or equal to 95'F, by verifying: Suppression chamber average water temperature to be less t A.\ a) thma ar aa"=1 to 110*F. and i b) 7fiERNAL POWER to be less than or equal to 12. of RATED THERMAL POWER after suppression chamber average water I.- . 3 ! temperature has exceeded 95T for more than 24 hours. l

c. At least once per 30 minutes in OPERATIONAL CONDITION 3 followinc a l

y pgredgh scram un suppresston chamber average water temperature greater L'I p .*2. a or equal to 95*F, by verifying suppression chamber average i-ater temperature less than or equal to 120*F.

                                     -                                                                                                i

d. By external ual examinati f the su ession ch r afte ety/rel valve operat ith the ression er av e L .2 water erature grea han or to 160*F d reactor lant sy a pressure gr r than 20 sia. -

    .Ch pn,             e.    [At least once per 18 months by a visual inspection of the accessible                                   1
  <-/

ec [ interior and exterior of the suppression chamber. i

f. By veri ing eight ression pool ater temperature y performan of a:

                                                                                                         %             j1 (q

ins ntation annels 0? ERA 8 [n I CHANNE ECK at less ce per 24 h , i , e per 31 e 3.

                                    .       C         FUNCTIONAL EL CALIBRA T at least at least      e per 18 and
                                                                                                   , With the                   ; k'  l I

water high temoerature alire i=+aa4at for < 105'F.

g. y verifying both narrow range suppression chamber water level ?

instrumentation channels OPERABLE by performance of a: CHANNEL CHECK at least once per 24 hours, I e de,. 1. CHANNEL FUNCTIONAL TEST at least once per 31 days, and J , I

                -C p.             2.

3. CHANNEL CALIBRATION at least once per 18 months, eC With the water level alarm setpoint for:

   'f. l..N                       1.        High water level 514'8"

2. Low water level 2 14'4" (TWHS Harrow Range)

h. ft least once per 18 months by conducting a drywell to-suppression chamber bypass leak test at an initial differential pressure of 1 psi and verifying that the differential pressure does not decrease by more than 0.20 inch of water per minute for a period of 10 minutes. If any drywell-to suppression chamber bypass leak test

  $60't, g, gn                     fatis to meet the specified limit, the test schedule for subsequent CCIP                            tests shall be reviewed and approved by the Commission. If two consecutive tests fail to meet the specified limit, a test shall be                                  i h'1.\     i                      performed at least every 9 months until two consecutive tests meet the specified limit, at which time the 18 month test schedule may be resumed.

FERMI - UNIT 2 3/4 6-17 j PAGE 3 0F 03 fu 5~

Spe c;ko&& u. 2.2 (Ao see see c,Aan 2.u,Q SO $ 8. 6 y e c i b C d [o l't 3 0.2. l) i CONTA NMEW SYSTEMS I SURVE LLAtCE REQUIREMENTS (Continued)

1. At least once per 5 minutes curing testing whica adds heat to l the suppression chamber, by verifying the suppression chamber average water temperature is less than or equal to 105'F. l

2. At igast once per hour when suppression chamber average water i temperature is greater than or equal to 95'F, by verifying: l a) Suppression chamber average water temperature to be less than or equal to 110*F, and b) THERNAL POWER to be less than or equal to if, of RATED THERMAL POWER after suppression chamber average water temperature has exceeded 95'F for more than 24 hours. l l ,

At least once per 30 minutes in OPERATIONAL CONDITION 3 following a I f c. l e,p f d gt scram with suppression chamber average water temperature greater than or equal to 95'F, by verifying suppression chamber average 3'6,N f} 7 I water temperature less than or equal to 120*F. l l

d. By an external visual examination of the suppression chamber after l safety / relief valve operation with the suppression chamber average l water temperature greater than or equal to 160*F and reactor coolant system pressure greater than 200 psig.

l 5 c.1"" e. At least once per 18 months by a visual inspection of the accessible interior and exterior of the suppression chamber. 3,)

                          . By verifying eight suppression pool water temperature                                     l instrumentation channels OPERABLE by performance of a:                                   l 54    1            1.       CHANNEL CHECK at least once per 24 hours, CHANNEL FUNCTIONAL TEST at least once per 31 cays, and g$'t#                2.

3. CHANNEL CALIBRATION at least once per 18 months, with the rif .b 4,g water high temperature alarm setpoint for i 105'F. Ty

[ B rifying h narrow ran suppressio haaber w ,

'a:

r1 bhb I nstrumentat channels BLE by ormance

1. EL CHECK ) east once 24 hour - '

l 2. HANNEL FUN ONAL. TEST a east one er 31 days and CHANNEL BRATION at ast once r 18 month l I With the ter level a setpoin or-

1. gh water lov s 14'8' y i 2. ' Low water level 114'4" 5 Narrow Range) f

6. At least once per 18 months by ' conducting a drywell-to-suppression chamber bypass leak test at an initial differential pressure of f 1 psi and verifying that the differential pressure does not decrease

[ E g, by more than 0.20 inch of water per minute for a period of

            .                   10 minutes. If any drywell to suppression chamber bypass leak test c oeCAQ(070                  fatis to meet the specified limit. the test schedule for subsequent i                            tests shall be reviewed and approved by the Consilssion. If two consecutive tests fail to meet the specified limit, a test shall be o g,\.}                      performed at least every 9 months until two consecutive tests meet D'

the specified limit. at which time the 18 month test schedule may be resumed. FERMI - UNIT 2 3/4 6 17 PAGE. 6 0F 05 l oc6 l

NECIFICAT10N 3(p.l.T CONTAINMENT SYSTEMS SURVEILLANCE RE0VIREMENTS 4.6.4.1 Each suppression chamber - drywell vacuum breaker shall be: I ) I asd27 L./ l SR 3./,,g.g.g /a.Avo Nortf closed at least once per 7 days. Verifie k' 1

b. Demonstrated OPERABLE:

During each COLD SHUTDOWN, if not performed within the ' 1. I g 3,4, f, y, g previous 92 days, and within 12 hours after any discharge of steam to the suppression chamber from the safety / relief I valves by: l I a) Cycling each vacuum breaker through at least one complete cycle of full travel. l I b) erifying b osition indic s UPLMAULL observin eted valve m during clin I tent. l

2. At least once per 18 months by; ;

1 gd3,4,[,y*3 a) Verifying the opening setpoint, from the closed position, to be less than or equal to 0.5 psid, and Verif rg both position indi fors OPERABLE by p ormance of a CHANNEL BRATION, c Verify the opening for switch actuati o be less than or equal to . 3 inches. FERMI - UNIT 2 3/4 6 49 Amendment No. 96 PAGE 1__ OF 02 fd

                                                                                                      $fEtiP IcArlorJ 34 /c 7                             l A.I CONTAINMENT SYSTEMS REACTOR BUILDING - SUPPRESSION CHAMBER VACUUM BREAKERS LIMITING CONDITION FOR OPERATION                                                                          ^

LC O 3 fo I 7 - 3.0.4.2- All Reactor B'uilding - suppression chamber vacuum breakers shall be OPERABLE [ana closedj g g ,y APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. ACTION:

a. With one Reactor Building - suppression chamber vacuum breaker M de-T10 M C inoperable for opening eut uown to be closgfrestore the 1 inoperable vacuum breaker to OPERABLE status within 72 hours or be d D O4 g in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours. l gg A 6b. With one Reactor Building - suppression chamber vacuum breaker open, l+- J!-

J isolate the associated vacuum breaker line by closing the isolation valve within 2 hours; restere the open vacuum breaker to the closed ( position within 72 hours or be in at least HOT SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the following 24 hours.

c. Wit the position cicator of any eactor Building-suppre ion J,l c mber vacuum aker inoperabl restore the inoperabl position ndicatcr to RABLE status wi in 14 days or verify e vacuum breaker t e closed at least nce per 24 hours by vi al inspect n. Otherwise, dec re the vacuum breaker operable or b in a east HOT SHUTDOWN hin the next 12 hour nd in COLD QH WN within the foi ing 24 hours y -

SURVEILLANCE RE0VIREMENTS 4.6.4.2 Each Reactor Building - suppression chamber vacuum breaker shall be: '1 5434.t.7.l -e- Verified closed at least once per 7 days NCD 1,2_\ L,7.

b. Demonstrated OPERABLE: f

1. At least once per 31 days by: I& L.l 5 8 34 l 7.L a) Cycling vacuum breaker through at least one complete test cycle of full travel.

                                                                                                                                                '1 (b)       Veri M ng the position indtrator UVLKAULL Dy f bservin t expfcted valve movement & fring the cycling /est.

2. At least once per 18 months by: ?

a) Demonstrating that the force required to open each - M 3.4.t.7. 3 vacuum breaker does not exceed (the/lequivAent AD 3 tC 0.5 psid.

                                                   @            "i:=' 5 ; :ti:0
                                                              - Ver   ing tne pos m       inoicator OPERABLE b/performan             lA

l

                                                            . of     CHANNEL CAllB      ION. j FERMI - UNIT 2                                              3/4 6-50 PAGE                0F       01

SPGc Ftc4Tr04 S.6,.</.1_

                                                                         &lso su Spu1(i& B 6 A*I )

CONTAINMENT SYSTEMS SURVElltANCE REOUTREMENTS

                '.5.5.1-  SECONDARY CONTAINMENT INTEGRITY shall be demonstrated by:

a. Verifying at least once per 24 hours that the vacuum within the secondary containment is greater than or equal to G.125 inch of vacuum water gauge.

b. Verifying at least once per 31 days that:

           -                  1. All secondary containment equipment hatches and pressure SN'IbMe                               reitef doors are closed and sealed, and both railroad bay 3 , (, ,4 1                        access doors are closed and sealed.

LI >

2. At least one door in each a cess to o o ge sgondgry g* .

n7 ( containment is closed._ All secondary containment penetrations except for Steam d g 34,q,g*g Tunnel Blowout Panels not capable of being closed by OPERABLE secondary containment automatic isolation L.3 Q I ' dampers / valves and required to be closed during accident R Oa vio)Adin 4 2. ~ A _ s cono gicap are closed Jb valves, blank flanges, or Meactivagd'apo]maQc d,a(e[sfvJlfe)) secured in the closed posTtT5n. g C...and fealtd v secw not.. locke) kAM rdoks l4 2. % Reyvived Achb 4.2_k ,_,-l Verifying Steam Tunnel Blowout Panels are closed during each COLD

                                                                                                       'l y      Fc. SHUTDOWN if not performed within the previous 31 days.

d. At least once per 18 months:

Ju. 1. Verifying that one standby gas treatment subsystem will draw down the secondary containment to greater than or equal g g.;{,- g m to 0.25 inch of vacuum water gauge in less than or equal to J.G N.1 567 seconds at a flow rate not exceeding 3800 cfm, and

2. Operating one standby gas treatment subsystem for I hour and maintaining greater than or eoual to 0.25 inch of vacuum water gauge in the secondary containment at a flow rate not exceeding 3000 cfm.

FERMI UNIT 2 3/4 6 Sla Amendment No. J/, 49 l PAGE l 0F 03 M

l l !- l 5Pkcawkrrod M4 2- l l l CONTAINMENT SYSTEMS l A.t i SECONDARY CONTAINMENT AUTOMATIC ISOLATION DAMPERS 1 LIMITING CONDITION FOR OPERATION l.-(O - 3.0.5." Jbe secondary containtnent ventilation system automatic isolation dampers Ghe.;. " !;ue 3.0.5.2 'shall be OPERABLE Wh ne;eu; . u;;; :ey bOI g, g ,g Qhr r ;e.a n r: me: :nn; " !;M 2.5.5.2 ' ; APPLICABILITY: OPERATIONAL A NDITIONS 1, 2, 3 and *. (rod McTE O QL.I

                              ' A e c New 1.)

ACTION [: Aco new 3 >- R.3 h OI l With one or more of the seco ary containee ventilatt system automatic isolation dampers (sT;.- - ::M: 2.;.;.: .. noperable,jmaintain at seast one2 LA l Osolation tlamper OPERABLE in eacn attecteo penetration that is openfand within 8 hours either: , j g g,y g x L "!:te t'e ' :;;. O h d::;;r(:) t: ^ ":".' " ' : :t:tx, :- .

b. Isolate each affected penetration by use of at least one deactivated QgnA (c. ben damper secured in the isolation position, or u

Q.1 c. Isolate each affected penetration by use of at least one closed manual valve or blank flange. Otherwise, in OPERATIONAL CONDITION 1, 2, or 3, be in at least HOT Acm a (, SHUTDOWN within the next 12 hours and in COLD SHUTOOWN within the following 24 hours. Othentise, in Operational Condition *, suspend handling of irradiated fuel AcmoeJ D in the secondary containment, CORE ALTERATIONS and operations with a potential for draining the reactor ve'sel. s The provisions of Specification 3.0.3 are not applicable. - SVRVElllANCE RE0VIREMENTS _ 4.6.5.2 Each secondary containm t ventilation system automatic isolation in i.uis-i.G.L. M all be demonstrated OPERABLE: damper (Ufe .1 l . Prior returning th damper to service aft r maintenance, re ir,] L R'I l or r acement work i performed on the da er or its associa d , act tor, control or power circuit by cyc ng the damper thr gh at I le st one complete ycle of full travel dverifyinotha<ecified) h n12tinn t4-* .

                                                                                                                     , 1 CE, i ny wm '=T".,= e, ^Er"EuYat least          once per 18 months by fg 3,(,,q,1 3       b.

verifying that on a containment isolation te t signal each is lation ( damper actuates to its isolation position. ac61 arsimu la kd 4.5

c. By verifying the isolation time to be within its limit when tested M M ~2 L pursuant to Specification 4.0.5.

                  *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.

FERMI UNIT 2 3/4 6 52 PAGE 5) 0F 03 b5 l

I PE C,iFicqTiord 3.C 4 3 CONTAINMENT SYSTEMS STAND 9Y CAS TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.3 Twof andby gas treatment subsystems shall be OPERABLE. l l APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, and *. EllQ!i:

a. With one standby gas treatment subsystem inoperable, restore the bGON b inoperable subsystem to OPERABLE status within 7 days, or:

1. In OPERATIONAL CONDITION l, 2, or 3, be-in at least HOT A c.T10 Al b SHUTDOWN within the next 12 hours and in COLD SHUTDOWN within the follo k[ ADO 2. Infeguirul Ac,%rn Operational Condition C./(ing

                                                          *, suspend         24 handling      hours.

of irradiated fuel in the secondary containment, CORE ALTERATIONS and AGO4 6 operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable.

b. With both standby gas treatment subsystems inoperable in

 @cTtor) E              Operational Condition *, suspend handling of irradiated fuel in the secondary containment, CORE ALTERATIONS or operations with a potential for draining the reactor vessel. The provisions of Specification 3.0.3 are not applicable.
      <:h oo-neo>

SURVEILLANCE REOUIREMENTS

                                                                        - 4 . 2.

4.6.5.3 Each standby gas treatment subsystem shall be demonstrated OPERABLE:

a. 20 :=tr: 7::s '

An least once per 31 daysfby 4-tttit* ;. 50:: d cM ter' rd::d;ri a.4], verifyin $R J,(,.4.3,l Me thre.;h th: FIP" "! t: : gat,thesubsystemoperatesforatleast10hourswiththeheaters

                                ]optedth@                  j l
          *When irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS and operations with a potential for draining the reactor vessel.                                                            ,

FERMI - UNIT 2 3/4 6-54 PAGE / OF03 W

r-INSERT THIS PAGE IN FRONT OF VOLUME 12

     -l             LVolume 12: IMPROVED TECHNICAL SPECIFICATIONS c                    <

Remove Replace 3.6.1.1 ITS pg 3.6-1 Rev 0 3.6.1.1 ITS pg 3.6-1 Rev 5 3.6.1.2 ITS pg 3.6-3 Rev 0 3.6.1.2 ITS pg 3.6-3 Rev 5 3.6.1.2 ITS pg 3.6-6 Rev 0 3.6.1.2 ITS pg 3.6-6 Rev 5 3.6.1.7 ITS pg 3.6-18 Rev 0 3.6.1.7 ITS pg 3.618 Rev 5 3.6.1.7 ITS pg 3.6-19 Rev 0 3.6.1.7 ITS pg 3.6-19 Rev 5 3.6.2.1 ITS pg 3.6-24 Rev 0 3.6.2.1 ITS pg 3.6-24 Rev 5 3.6.2.1 ITS pg 3.6-25 Rev 0 3.6.2.1 ITS pg 3.6-25 Rev 5 f 1 3.6.2.1 ITS pg 3.6-26 Rev 0 3.6.2.1 ITS pg 3.6-26 Rev 5 l 3.6.2.3 ITS pg 3.6-28 Rev 0 3.6.2.3 ITS pg 3.6-28 Rev 5 l 3.6.3.1 ITS pg 3.6-30 Rev 0 3.6.3.1 ITS pg 3.6-30 Rev 5 3.6.4.1 ITS pg 3.6-33 Rev 0 3.6.4.1 ITS pg 3.6-33 Rev 5 l l 3.6.4.1 ITS pg 3.6-34 Rev 0 3.6.4.1 ITS pg 3.6-34 Rev 5 t 3.6.4.1 ITS pg 3.6-35 Rev 0 3.6.4.1 ITS pg 3.6-35 Rev 5 3.6.4.2 ITS pg 3.6-37 Rev 0 3.6.4.2 ITS pg 3.6-37 Rev 5 3.6.4.2 ITS pg 3.6-38 Rev 0 3.6.4.2 ITS pg 3.6-38 Rev 5 3.6.4.2 ITS pg 3.6-39 Rev 0 3.6.4.2 ITS pg 3.6-39 Rev 5 3.6.4.3 ITS pg 3.6-4i Rev 0 3.6.4.3 ITS pg 3.6-4i Rev 5 Rev 5 04/30/99 i

Primary Containment 3.6.1.1 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment LCO 3.6.1.1 Primary containment shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 Restore primary 1 hour inoperable. containment to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. MQ B.2 Be in MODE 4. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l SR 3.6.1.1.1 Perform required visual examinations and In accordance ! y leakage rate testing except for primary with the j i 'i containment air lock, in accordance with Primary - the Primary Containment Leakage Rate Containment Testing Program. Leakage Rate Testing Program i I (continued) l l l l 1

  ! FERMI - UNIT 2                          3.6 1                Revision 5. 04/30/99 i

Pricary Containment Air Lock 3.6.1.2

    -3.6 CONTAI E NT SYSTEMS 3.6.1.2 Primary Containment Air Lock LC0 3.6.1.2                    The primary containment air lock shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3. ACTIONS

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

y~ l 1. Entry and exit is permissible to perform repairs of the air lock components. 4 2. . Enter applicable Conditions and Required Actions of LC0 3.6.1.1. " Primary Containment." when air lock leakage results in exceeding overall containment leakage rate acceptance criteria. CONDITION REQUIRED ACTION COMPLETION TIME l A. One primary ----.. . -- NOTES ' - -- - containment air lock 1. Required Actions A.1, door inoperable. A.2. and A.3 are not applicable if both doors in the air lock are inoperable and Condition C is entered.

2. Entry and exit is permissible for 7 days under administrative controls. .

A.1 Verify the OPERABLE 1 hour door is closed. l ANQ ! (continued) ! l l FERMI, UNIT 2 3.6 3 Revision 5. 04/30/99 I l l 1

Prizary Containment Air Lock 3.6.1.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME l l D. Required Action and D.1 Be in MODE 3. 12 hours associated Completion Time not met. a@ l D.2 Be in M00E 4. 36 hours i l l l l l SURVEILLANCE PIOU_IPINENTS SURVEILLANCE FRE0VENCY l N SR 3.6.1.2.1 --- -- ---- -- - NOTES - - - - - --- l g 1. An inoperable air lock door does not l I i invalidate the previot's successful performance of the ovarall air lock leakage test. Q j k 2. Results shall be evaluated against acceptance criteria applicable to j SR 3.6.1.1.1. - Perform required primary containment air In accordance lock leakage rate testing in accordance with the l with the Primary Containment Leakage Rate Primary Testing Program. Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary 24 months containment air lock can be opened at a time. l l l l l l FERMI UNIT 2 3.6 6 Revision 5, 04/30/99 l l l l

l i l Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7 3.6 CONTAINMENT SYSTEMS 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers l LC0 3.6.1.7 Each reactor building to suppression chamber vacuum breaker g shall be OPERABLE. APPLICABILITY: MODES 1. 2. and 3. ACTIONS M, ....................................-NOTE----- -- - - -- - ------ -- l k- $$!S!!.SS SS.!S 2. .! .SS.!!!...S$............................. I I CONDITION REQUIRED ACTION COMPLETION TIME l l i' A. One or more lines with A.1 Close the open vacuum 72 hours j one reactor building- breaker. to suppression chamber vacuum breaker not closed. . l 1 1 i 1 o B. One or more lines with B.1 Close one open vacuum 2 hours ) two reactor building- breaker. to-suppression chamber ! O vacuum breakers not 68 closed.

  \                                                                                                        l w                                                                                                          -

C. One line with one or B.1 Restore the vacuum 72 hours more reactor building- breaker (s) to to suppression chamber OPERABLE status. l 'l vacuum breakers inoperable for opening. ! l l

(continued) I i l l 1 l FERMI UNIT 2 3.6 18 Revision 5. 04/30/99 l l l l

Reactor Building to Suppression Chamber Vacuum Breakers 3.6.1.7 1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 4 0. Required Action and D.1 Be in MODE 3. 12 hours VP l Associated Completion g Time not met. ANQ l D.2 Be in MODE 4. 36 hours l , SURVEILLANCE REQUIREMENTS 1 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 s 0.5 psid. I FERMI - UNIT 2 3.6-19 Revision 5. 04/30/99

Suppression Pool Average Temperature 3.6.2.1 3.6 CONTAINMENT SYSTEMS 3.6.2.1 Suppression Pool Average-Temperature l LC0 3.6.2.1 Suppression pool average temperature shall be:

a. s %*F with THERMAL POWER > lt RTP and no testing that fl= adds heat to the suppression pool is being performed:

1 D s 105*F with THERMAL POWER > lt RTP and testing that

   $j                     b.

adds heat to the suppression pool is being performed:

                              -and                                                         (

l c. s 110*F with THERMAL POWER s it RTP. i APPLICABILITY: MODES 1. 2. and 3. ACTIONS 4 COEITION REQUIRED ACTION COMPLETION TIME 1 A. Suppression pool A.1 Verify suppression Once per hour average temperature pool average

             > 95*F but s 110*F.                temperature s 110*F.

e!E AN12 THERMAL POWER A.2 Restore suppression 24 hours

             > lt RTP.                          pool average temperature to eNQ                                s 95"F.

Not performing testing that adds heat to the j suppression pool. (continued) I FERMI - UNIT 2 , 3.6 24 Revision 5. 04/30/99

o j Suppression Pool Average Temperature 3.6.2.1 1 l ACTIONS (continued) . CONDITION REQUIRED ACTION COMPLETION TIME 1 B. Required Action and B.1 12 hours ) ! yl g associated Completion Reduce THERMAL POWER to s it RTP. Time of Condition A g not met. l l C. Suppression pool C.1 Suspend all testing Immediately average temperature that adds heat to the ) 1

            > 105*F.                     suppression pool.                           i i
            @                                                                        \

i THERMAL POWER > lt ! l RTP. ! l l AND j Performing testing that adds heat to the j suppression pool. l D. Suppression pool D.1 Place the reactor Immediately average temperature mode switch in the l > 110*F but 5 120*F. shutdown position.

 ~l                               D.2   Verify suppression        Once per pool average              30 minutes j                                   temperature s 120*F.

E D.3 Be in MODE 4. 36 hours l (continued) 1 l FERMI UNIT 2 3.6 25 Revision 5. 04/30/99 l

Suppression Pool Average Temperature 3.6.2.1 ACTIONS (continued) q C0f0ITION REQUIRED ACTION COMPLETION TIME j i i E. Suppression pool E.1 Depressurize the 12 hours average temperature reactor vessel to

           > 120*F.                           < 200 psig.

d E a ( E.2 Be in MODE 4. 36 hours l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i SR 3.6.2.1.1 Verify suppression pool average 24 hours ! I temperature is within the applicable ' limits. E j 5 minutes when performing i i testing that adds heat to the suppression pool l l l l FERMI - UNIT 2 3.6 26 Revision 5. 04/30/99 1

RHR Suppression Pool Cooling I 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LC0 3.6.2.3 Two RE suppression pool cooling subsystems shall be OPERABLE. APPLICABILITY: MODES 1. 2. and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l , A. One RE suppression- A.1 Restore RE 7 days l pool cooling subsystem suppression pool inoperable. cooling subsystem to OPERABLE status. B. Two RHR suppression B.1 Restore one RHR 8 hours pool cooling suppression pool subsystems inoperable. cooling subsystem to OPERABLE status. .; C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion d Time of Condition A or eg i B not met.

 .{:                                  C.2      Be in MODE 4.           36 hours 1

l 1 l FERMI UNIT 2 3.6 28 Revision 5. 04/30/99

Pricary Containment Hydrogen Recombiners l 3.6.3.1 ) 1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners LC0 3.6.3.1 Two primary containment hydrogen recombiners shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One primary A.1 --

                                                         - NOTE- -------

containment hydrogen LC0 3.0.4 is not i recombiner inoperable. applicable. l Restore primary 30 days containment hydrogen recombiner to OPERABLE status. l B. Two primary B.1 Verify by 1 hour _ containment hydrogen administrative means i 1l recombiners that the hydrogen AND l E inoperable. control function is ; .W maintained. Once per 12 hours thereafter 8NQ B.2 Restore one arimary 7 days . containment lydrogen I recombiner to OPEPJELE status. (continued) l FERMI UNIT 2 3.6-30 Revision 5. 04/30/99

E ' I Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS l 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE. APPLICABILITY: MODES 1. 2. and 3. j During movement of irradiated fuel assemblies in the j secondary containment. ' During CORE ALTERATIONS. During operations with a potential for draining the reactor vessel (0PORVs). ACTIONS C0EITION REQUIRED ACTION COMPLETION TIME 5l A. Secondary Containment A.1 Restore railroad bay 7 days inoperable due to one door to OPERABLE n railroad bay access status. 1 door inoperable. k l i l 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. L C. Required Action and C.1 Be in MODE 3. 12 hours

associated Completion Time of Condition A or Ng!

B not met. C.2 Be in MODE 4. 36 hours (continued) l l l FERMI - UNIT 2 3.6 33 Revision 5. 04/30/99 l L I

Secondary Containment 3.6.4.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Secondary containment - -

                                                   - NOTE -   - -     -

B inoperable during LC0 3.0.3 is not applicable. i movement of irradiated - - - - -- -- - Q fuel assemblies in the

 %          secondary containment. D.1        Suspend movement of     Immediately during CORE                          irradiated fuel ALTERATIONS, or during               assemblies in the OPDRVs.                              secondary                                  i containment.
                                      $N_Q D.2        Suspend CORE            Immediately ALTERATIONS.                               ;

8NQ ! l D.3 Initiate action to Immediately i suspend OPDRVs. l 1 SURVEILLANCE REQUIREME,gS__ _ SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is 24 hours ! m 0.125 inch of vacuum water gauge. ! (continued) I i l FERMI UNIT 2 3'.6 34 Revision 5. 04/30/99

Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.4.1.2 .. ........... NOTE - -- - - --- - l Not required to be met for one railroad bay access door until:

a. 4 hours after opening for entry.

T - b. exit, or testing: and 12 hours after opening for new fuel I receipt activities, provided the other door remains OPERABLE and closed. Verify all secondary containment 31 days equipment hatches, pressure relief doors and railroad bay access doors are closed and sealed. SR 3.6.4.1.3 Verify one secondary containment access 31 days i door in each access opening is closed. to SR 3.6.4.1.4 Verify steam tunnel blowout panels are Prior to

2. closed. entering MODE 2

{ or 3 from liODE 4 if not performed in the previous 31 days j SR 3.6.4.1.5 Verify each standby gas treatment (SGT) 18 months on a subsystem will draw down the secondary STAGGERED TEST containment to a 0.25 inch of vacuum BASIS water gauge in s 567 seconds. SR 3.6.4.1.6 Verify each SGT subsystem can maintain 18 months on a m 0.25 inch of vacuum water gauge in the STAGGERED TEST secondary containment for 1 hour at a BASIS flow rate s 3000 cfm.

    ! FERMI   UNIT 2                                    3.6 35       Revision 5. 04/30/99

SCIVs 3.6.4.2 l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 -- NOTES - - -

1. Isolation devices in high radiation g areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated. B. -- NOTE - --- B.1 Isolate the affected 4 hours Only applicable to )enetration flow path penetration flow paths )y use of at least with two isolation one closed and valves. de activated

           ......................             automatic valve, closed manual valve.

One or more or blind flange. penetration flow paths with two SCIVs inoperable. C. Required Ac an and C.1 8e in MODE 3. 12 hours associated Cunipletion Time of Condition A AND or B not met in MODE 1. 2. or 3. C.2 Be in MODE 4. 36 hours (continued) l FERMI UNIT 2 3.6 37 Revision 5. 04/30/99

SCIVs 3.6.4.2 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and -- -

                                              - NOTE        -  ---

associated Completion LC0 3.0.3 is not applicable. O Time of Condition A - -- - - - - or B not met during movement of irradiated D.1 Suspend movement of 4 fuel assemblies in the irradiated fuel Immediately I secondary containment, assemblies in the during CORE secondary ALTERATIONS. or during containment. OPDRVs. 62 D.2 Suspend CORE l ALTERATIONS. Immediately I l 6NQ I D.3 Initiate action to suspend OPDRVs. Immediately l

 '! FERMI    UNIT 2                     3.6 38                     Revision 5. 04/30/99

SCIVs 3.6.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.2.1 - --

                                             - NOTES -         ----  -

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

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

Verify each secondary containment 31 days isolation manual valve and blind flange l not locked, sealed, or otherwise secured that is required to be closed during accident conditions is closed. SR 3.6.4.2.2 Verify the isolation time of each power In accordance Ogl operated automatic SCIV is within limits. with the Inservice Testing Program SR 3.6.4.2.3 Verify each automatic SCIV actuates to 18 months the isolation position on an actual or simulated actuation signal. 1 FERMI UNIT 2 3.6 39 Revision 5. 04/30/99

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l C. (continued) C.2.1 Suspend movement of Immediately l irradiated fuel i assemblies in l ! secondary I containment. E i i l C.2.2 Suspend CORE Immediately I ALTERATIONS. M , 1 C.2.3 Initiate action to Immediately suspend OPDRVs. D. Two SGT subsystems D.1 Enter LC0 3.0.3 Immediately , inoperable in MODE 1

2. or 3.

1 i E. Two SGT subsystems - - -- NOTE- - --- inoperable during LC0 3.0.3 is not applicable.

 $          movement of irradiated       - - --              -- -- --       -
 '3 fuel assemblies in the secondary              E.1       Suspend movement of               Immediately I

k containment. during CORE ALTERATIONS. or irradiated fuel assemblies in during OPDRVs. secondary containment. (continued) l FERMI - UNIT 2 3.6 41 Revision 5 04/30/99 1 ( l

l l l INSERT THIS PAGE IN FRONT OF VOLUME 13 Jf sVolume 13:! IMPROVED TECHNICAL SPECIFICATIONS BASES Remove Replace B 3.6.1.1 ITS pg B 3.6.1.1-2 Rev 0 B 3.6.1.1 ITS pg B 3.6.1.1-2 Rev 5 B 3.6.1.1 ITS pg B 3.6.1.1-4 Rev 0 B 3.6.1.1 ITS pg B 3.6.1.1-4 Rev 5 B 3.6.1.2 ITS pg B 3.6.1.2 3 Rev 0 B 3.6.1.2 ITS pg B 3.6.1.2-3 Rev 5 B 3.6.1.2 ITS pg B 3.6.1.2 4 Rev 0 B 3.6.1.2 ITS pg B 3.6.1.2-4 Rev 5 B 3.6.1.2 ITS pg B 3.6.1.2-5 Rev 0 B 3.6.l.2 ITS pg B 3.6.1.2-5 Rev 5 B 3.6.1.2 ITS pg B 3.6.1.2-7 Rev 0 B 3.6.1.2 ITS pg B 3.6.1.2-7 Rev 5 B 3.6.1.2 ITS pg B 3.6.1.2-8 Rev 0 B 3.6.1.2 ITS pg B 3.6.1.2-8 Rev 5 B 3.6.1.4 ITS pg B 3.6.1.4 2 Rev 0 B 3.6.1.4 ITS pg B 3.6.1.4-2 Rev 5 B 3.6.1.6 ITS pg B 3.6.1.6-3 Rev 0 B 3.6.1.6 ITS pg B 3.6.1.6-3 Rev 5 B 3.6.1.6 ITS pg B 3.6.1.6-4 Rev 0 B 3.6.1.6 ITS pg B 3.6.1.6-4 Rev 5 B 3.6.1.7 ITS pg B 3.6.1.7-1 Rev 0 B 3.6.1.7 ITS pg B 3.6.1.7-1 Rev 5 B 3.6.l.7 ITS pg B 3.6.1.7-3 Rev 0 B 3.6.l.7 ITS pg B 3.6.1.7-3 Rev 5 B 3.6.1.7 ITS pg B 3.6.1.7-4 Rev 0 B 3.6.1.7 ITS pg B 3.6.1.7-4 Rev 5 B 3.6.1.7 ITS pg B 3.6.1.7-5 Rev 0 B 3.6.1.7 ITS pg B 3.6.1.7-5 Rev 5 B 3.6.1.8 ITS pg B 3.6.1.8-4 Rev 0 B 3.6.1.8 ITS pg B 3.6.1.8-4 Rev 5 B 3.6.1.8 ITS pg B 3.6.1.8-5 Rev 0 B 3.6.1.8 ITS pg B 3.6.1.5-5 Rev 5 B 3.6.2.1 ITS pg B 3.6.2.1-2 Rev 0 B 3.6.2.1 ITS pg B 3.6.2.1-2 Rev 5 B 3.6.2.1 ITS pg B 3.6.2.1-5 Rev 0 B 3.6.2.1 ITS pg B 3.6.2.1-5 Rev 5 B 3.6.2.3 ITS pg B 3.6.2.3-3 Rev 0 B 3.6.2.3 ITS pg B 3.6.2.3-3 Rev 5 B 3.6.2.3 ITS pg B 3.6.2.3-4 Rev 0 B 3.6.2.3 ITS pg B 3.6.2.3-4 Rev 5 B 3.6.3.1 ITS pg B 3.6.3.1-1 Rev 0 B 3.6.3.1 ITS pg B 3.6.3.1-1 Rev 5 B 3.6.3.1 ITS pg B 3.6.3.1-2 Rev 0 B 3.6.3.1 ITS pg B 3.6.3.1-2 Rev 5 B 3.6.3.1 ITS pg B 3.6.3.1-3 Rev 0 B 3.6.3.1 ITS pg B 3.6.3.1-3 Rev 5 l B 3.6.3.1 ITS pg B 3.6.3.1-4 Rev 0 B 3.6.3.1 ITS pg B 3.6.3.1-4 Rev 5 B 3.6.4.1 ITS pg B 3.6.4.1-3 Rev 0 B 3.6.4.1 ITS pg B 3.6.4.1-3 Rev 5 B 3.6.4.1 ITS pg B 3.6.4.1-4 Rev 0 B 3.6.4.1 ITS pg B 3.6.4.1-4 Rev 5 B 3.6.4.1 ITS pg B 3.6.4.1-5 Rev 0 B 3.6.4.1 ITS pg B 3.6.4.1-5 Rev 5 B 3.6.4.1 ITS pg B 3.6.4.1-6 Rev 0 B 3.6.4.1 ITS pg B 3.6.4.1-6 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2 2 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-2 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-4 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-4 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-5 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-5 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-6 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-6 Rev 5 B 3.6.4.2 ITS pg B 3.6.4.2-7 Rev 0 B 3.6.4.2 ITS pg B 3.6.4.2-7 Rev 5 Rev 5 04/30/99

INSERT THIS PAGE IN FRONT OF VOLUME 13

      -     I Voldme 13:' IMPROVED TECHNICAL' SPECIFICATIONS BASES (cont'd) '

l t [ Remove Replace l ( B 3.6.4.3 ITS pg B 3.6.4.31 Rev 0 B 3.6.4.3 ITS pg B 3.6.4.3-1 Rev 5 B 3.6.4.3 ITS pg B 3.6.4.3-5 Rev 0 B 3.6.4.3 ITS pg B 3.6.4.3-5 Rev 5 1 l l l l l l l l l l l l l l l l l l l l Rev 5 04/30/99

Primary Containment ! B 3.6.1.1 BASES j l APPLICABLE The safety design basis for the primary containment is that ) SAFETY ANALYSES it must withstand the pressures and temperatures of the ! limiting DBA without exceeding the design leakage rate. l The DBA that postulates the maximum release of radioactive i material within primary containment is a LOCA. In the , analysis of this accident, it is assumed that primary containment is OPERABLE such that release of fission i products to the environment is controlled by the rate of primary containment leakage. Analytical methods and assumptions involving the primary j containment are presented in References 1 and 2. The safety j analyses assume a nonmechanistic fission product release ' following a DBA, which forms the basis for determination of offsite doses. The fission product release is, in turn. ! based on an assumed leakage rate from the primary ; containment. OPERABILITY of the primary containment ensures 1 that the leakage rate assumed in the safety analyses is not ! exceeded. { 1 The maximum allowable leakage rate for the primary h containment (L ) is 0.5% by weight of the containment air d per24hoursalthedesignbasisLOCAmaximumpeak l @l containment pressure (P.) of 56.5 psig (Ref.1). ! Primary containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 Primary containment OPERABILITY is maintained by limiting leakage to 51.0 L , except prior to the first startup after . performing a required Primary Containment Leakage Rate ! Testing Program leakage test. At this time, the applicable i leakage limits must be met. Compliance with this LCO will - ensure a primary containment configuration, including ) equipment hatches, that is structurally sound and that will ! limit leakage to those leakage rates assumed in the safety l analyses, j Individual leakage rates specified for the primary containment air lock are addressed in LC0 3.6.1.2. i l l FERMI - UNIT 2 B 3.6.1.1 - 2 Revision 5. 04/30/99 i l 3

l l Primary Containment B 3.6.1.1 i BASES SURVEILLANCE REQUIREMENTS (continued) Failure to meet air lock leakage testing (SR 3.6.1.2.1), %l w secondary containment bypass leakage (SR 3.6.1.3.11). resilient-seal primary containment purge valve leakage % testing (SR 3.6.1.3.6), main steam isolation valve leakage (SR 3.6.1.3.12), or hydrostatically tested lines valve leakage (SR 3.6.1.3.13) does not necessarily result in a failure of this SR. The impact of the failure to meet these SRs must be evaluated against the Type A. B. and C acceptance criteria of the Primary Containment Leakage Rate l Testing Program. As left leakage prior to the first startup i after performing a required Primary Containment Leakage Rate Testing Program leakage test is required to be s 0.6 L for b combined Type B and C leakage and s 0.75 L, for overalf

d. Type A leakage. At all other times between required leakage )

rate tests, the acceptance criteria is based on an overall { At s 1.0 L,, the offsite i Type A leakage limit dose consequences areofbounded s 1.0 L'y. b the assumptions of the safety analysis. The Frequency is required by the Primary Containment Leakage Rate Testing Program. SR 3.6.1.1.2 Maintaining the pressure suppression function of primary containment requires limiting the leakage from the drywell to the suppression chamber. Thus, if an event were to occur that pressurized the drywell, the steam would be directed through the downcomers into the suppression pool. This SR measures drywell to suppression chamber differential pressure during a 10 minute period to ensure that the leakage paths that would bypass the suppression pool are within allowable limits. Satisfactory performance of this SR can be achieved by establishing a known differential pressure between the drywell and the suppression chamber and verifying that the pressure between the suppression chamber and the drywell does not change by more than 0.2 inch of water per minute over a 10 minute period. This leakage is equivalent to that through a 1 inch diameter orifice at a differential pressure of approximately 1 psid. The leakage test is performed every 18 months. The 18 month Frequency was developed considering it is prudent-that this Surveillance be performed during a unit outage and also in view of the fact that component failures that might have affected this test l FERMI UNIT 2 B 3.6.1.1 - 4 Revision 5. 04/30/99

Prieary Containment Air Lock B 3.6.1.2 BASES APPLICABILITY In MODES 1. 2. and 3. a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the primary containment air lock is not required to be OPERABLE in MODES 4 and 5 to prevent leakage of radioactive material from primary containment. ACTIONS The ACTIONS are modified by Note 1, which allows entry and I exit to perform repairs of the affected air lock component. I If the outer door is inoperable, then it may be easily 1 accessed to repair. If the inner door is the one that is inoperable, however, then a short time exists when the containment boundary is not intact (during access through , the outer door). The ability to open the OPERABLE door, l even if it means the primary containment boundary is tem)orarily not intact, is acceptable due to the low pro) ability of an event that could pressurize the primary containment during the short time in which the OPERABLE door ':>. is expected to be open. The OPERABLE door must be 2l immediately closed after each entry and exit. The ACTIONS are modified by a second Note, which ensures appropriate remedial measures are taken when necessary. Pursuant to LC0 3.0.6. actions are not required. even if primary containment is exceeding its leakage limit. Therefore, the Note is added to require ACTIONS for LC0 3.6.1.1 " Primary Containment." to be taken in this event. A.1. A.2. and A.3 With one primary containment air lock door inoperable, the OPERABLE door must be verified closed (Required Action A.1) in the air lock. This ensures that a leak tight primary containment barrier is maintained by the use of an OPERABLE air lock door. This action must be completed within 1 hour. The 1 hour Com)letion Time is consistent with the ACTIONS of LC0 3.6.1.1. w11ch requires that primary containment be restored to OPERABLE status within 1 hour. l FERMI UNIT 2 B 3.6.1.2 -3 Revision 5. 04/30/99

Primary Containment Air Lock B 3.6.1.2 BASES ACTIONS (continued) In addition, the air lock penetration must be isolated by locking closed the OPERABLE air lock door within the 24 hour Completion Time. The 24 hour Com)letion Time is considered reasonable for locking the OPERAB l air lock door, considering that the OPERABLE door is being maintained closed. Required Action A.3 ensures that the air lock with an inoperable door has been isolated by the use of a locked closed OPERABLE air lock door. This ensures that an acceptable primary containment leakage boundary is maintained. The Completion Time of once per 31 days is based on engineering judgment and is considered adequate in view of the low likelihood of a locked door being mispositioned and other administrative controls. Required Action A.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and allows these doors to be verified locked closed by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of the door, once it has been verified to be in the proper position, is small. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the air lock are inoperable. With both doors in the air lock inoperable, an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate remedial actions. The exception of Note 1 does not affect tracking the Completion Time from the initial entry into Condition A: only the requirement to comply with the Required Actions. Note 2 allows use of the air lock for entry and exit for 7 days under administrative controls. Primary containment entry may be required to perform Technical Specifications (TS) Surveillances and Required Actions. as well as other activities on equipment inside primary containment that are required by TS, activities on equipment that support TS required equipment. This Note is > not intended to preclude performing other activities (i.e.. J. non TS related activities) if the primary containment was g entered, using the inoperable air lock, to perform an allowed activity listed above. This allowance is acceptable due to the low probability of an event that could pressurize l FERMI UNIT 2 83.6.1.2-4 Revision 5. 04/30/99 l

Primary Containment Air Lock B 3.6.1.2 i BASES ACTIONS (continued) the primary containment during the short time that the OPERABLE door is expected to be open. B.1. B.2. and B.3 With an air lock interlock mechanism inoperable. the Required Actions and associated Completion Times are consistent with those specified in Condition A. The Required Actions have been modified by two Notes. Note 1 ensures that only the Required Actions and associated Completion Times of Condition C are required if both doors in the air lock are inoperable. With both doors in the air lock inoperable an OPERABLE door is not available to be closed. Required Actions C.1 and C.2 are the appropriate 1 remedial actions. Note 2 allows entry into and exit from the primary containment under the control of a dedicated individual stationed at the air lock to ensure that only one door is opened at a time (i.e. the individual performs the ' function of the interlock). The dedicated individual must ensure the OPERABLE door is locked prior to leaving the air lock. Required Action B.3 is modified by a Note that applies to air lock doors located in high radiation areas or areas with limited access due to inerting and that allows these doors to be verified locked closed by use of administrative controls. Allowing verification by administrative controls is considered acceptable, since access to these areas is typically restricted. Therefore, the 3robability of misalignment of the door, once it has )een verified to be in the proper position. is small. C.1. C.2. and C.3 If the air lock is inoperable for reasons other than those described in Condition A or B. Recuired Action C.1 requires action to be immediately initiatec to evaluate containment overall leakage rates using current air lock leakage test results. An evaluation is acceptable since it is overly conservative to immediately declare the )rimary containment inoperable if both doors in an air lock lave failed a seal test or if the overall air lock leakage is not within A l FEP.MI - UNIT 2 B 3.6.1.2 - 5 Revision 5. 04/30/99 l

Prizary Containment Air Lock B 3.6.1.2 BASES SURVEILLANCE REQUIREMENTS (continued) primary containment leakage rate. The Frequency is required by the Primary Containment Leakage Rate Testing Program. pl The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous d successful performance of the overall air lock leakage test. g This is considered reasonable since either air lock door is - capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR. requiring the Q results to be evaluated against the acceptance criteria b which is applicable to SR 3.6.1.1.1. This ensures that air lock leakage is properly accounted for in determining the combined Type B and C primary containment leakage rate. SR 3.6.1.2.2 l The air lock interlock mechanism is designed to prevent simultaneous opening of both doors in the air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident primary containment pressure, closure of either door will su) port primary containment OPERABILITY. Thus, the interloc( feature supports primary containment OPERABILITY while the I air lock is being used for personnel transit in.and out of l the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous inner and outer door opening will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is ; not normally challenged when primary containment is used for entry and exit (procedures require strict adherence to l single door opening) this test is only required to be i performed every 24 months. The 24 month Frequency is based ! on the desire to perform this SR under the conditions that l apply during a plant outage, and the potential for loss of i (i primary containment OPERABILITY if the Surveillance were ! performed with the reactor at power. The 24 month Frequency ns is justified based on generic operating experience. Tha 24 month Frecuency is based on engineering judgment and is considerec adequate given that the interlock is not acrmally challenged during use of the air lock. i l FERMI UNIT 2 B 3.6.1.2 - 7 Revision 5. 04/30/99 l l, l

i I Prizary Containment Air Lock B 3.6.1.2 BASES REFERENCES 1. UFSAR. Section 3.8.2.1.3.4.

2. 10 CFR 50. Appendix J. Option B.

3. UFSAR. Section 6.2.

i f i 1 l l i l l l l l FERMI UNIT 2 B 3.6.1.2 - 8 Revision 5 04/30/99 I

PriGary Containment Pressure B 3.6.1.4 l BASES l APPLICABLE SAFETY ANALYSES (continued) The bounding accident events involve actuation of the drywell spray following a steam leak in the drywell (small break accident) and following a DBA. All intermediate line break events are enveloped by these cases. The limiting plant transient case is the inadvertent drywell spray actuation during plant operation which assumes an initial condition of 0.10 psig (Ref. 1). 1 Primary containment pressure satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). LCO In the event of a DBA with an initial 3rimary containment ! pressure s +2.0 psig. the resultant pea ( primary containment accident pressure will be maintained below the primary containment design pressure. In the event of an inadvertent drywell spray actuation, with an initial primary containment 1l pressure a: 0.10 psig. the resultant negative primary Q containment pressure will be above the external primary containment design pressure. APPLICABILITY In MODES 1. 2. and 3. a DBA could cause a release of radioactive material to primary containment. In MODES 4 and 5. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining primary containment l pressure within limits is not required in MODE 4 or 5. I ACTIONS A_l With primary containment pressure not within the limit of the LCO. Jrimary containment pressure must be restored within 1 lour. The Required Action is necessary to return , operation to within the bounds of the primary containment l analysis. The 1 hour Completion Time is consistent with the l ACTIONS of LC0 3.6.1.1. " Primary Containment." which i requires that primary containment be restored to OPERABLE l status within 1 hour. i l FERMI - UNIT'2 B 3.6.1.4 - 2 Revision 5. 04/30/99 l .

LLS Valves B 3.6.1.6 BASES

        ' ACTIONS (continued)

B.1 and B.2 If both LLS valves are inoperable or if the inoperable LLS valve cannot be restored to OPERABLE status within the required Com)letion Time, the plant must be brought to a i MODE in whic1 the LC0 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 3.6.1.6.1 REQUIREMENTS A manual actuation of each LLS valve is performed to verify that the valvo 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 y perform this test to avoid damaging the valve. Adequate _ pressure at which this test is to be performed is = 850 psig g (the pressure recommended by the valve manufacturer). Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to coatinue to control reactor pressure when the LLS valves divert steam flow upon opening. Adequate steam flow is represented by turbine bypass valves l 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. 2). Operating experience has shown that these com)onents usually pass the Surveillance when aerformed at tle 18 month Frequency. Therefore, the requency was concluded to be acceptable fr'om a reliability standpoint. Since steam pressure is required to perform the I Surveillance. however, and steam may not be available during

a unit outage, the Surveillance may be performed during the I

startup following a unit outage. Unit startup is allowed l FERMI UNIT 2 B 3.6.1.6 - 3 Revision 5. 04/30/99 \ l l i 1 E j

l LLS Valves B 3.6.1.6 BASES SURVEILLANCE REQUIREMENTS (continued) prior to performing the test because valve OPERABILITY and the setpoints for overpressure protection are verified by Reference 2 prior to valve installation. After adequate j reactor steam dome pressure and flow are reached.12 hours is allowed to prepare for and perform the test. 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 un)lanned transient if the Surveillance were performed with t1e reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore. the Frecuency was concluded to be acceptable from ' a reliability stancpoint. d This SR is modified by a Note that excludes valve actuation. ,1 g This prevents a reactor pressure vessel pressure blowdown. j REFERENCES 1. UFSAR. Section 5.2.2.5. l

2. ASME. Boiler and Pressure Vessel Code. Section XI.

I FERMI - UNIT 2 B 3.6.1.6 - 4 Revision 5. 04/30/99

Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7 8 3.6 CONTAINMENT SYSTEMS B 3.6.1.7 Reactor Building to Suppression Chamber Vacuum Breakers i BASES BACKGROUND The function of de reactor building to suppression chamber vacuum breakers is to relieve vacuum when primary containment depressurizes below reactor building pressure. If the drywell depressurizes below reactor building pressure, the negative differential pressure is mitigated by flow through the reactor building to suppression chamber vacuum breakers and through the suppression chamber-to-drywell vacuum breakers. The design of the external (reactor building to suppression chamber) vacuum relief provisions consists of two vacuum breakers (a vacuum breaker p and an air operated butterfly isolation valve), located in , series in each of two lines from the reactor building to the 1 i suppression chamber airspace. The butterfly valve is l p actuated by differential pressure sensors which result in ! q air operated actuators opening the isolation valve. The vacuum breaker is self actuating and can be remotely bl operated for testing purposes. The two vacuum breakers in i series must be closed to maintain a leak tight primary j containment boundary. A negative differential pressure across the drywell wall is caused by ra)1d depressurization of the drywell. Events that cause t11s rapid depressurization are cooling cycles, inadvertent primary containment spray actuation, and steam condensation in the event of a primary system rupture. Reactor building to suppression chamber vacuum breakers prevent an excessive negative differential pressure across i the primary containment boundary. Cooling cycles result in i minor pressure transients in the drywell, which occur slowly ; and are normally controlled by heating and ventilation 1 equipment. Steam condensation results in a more significant ! pressure transient and becomes important in sizing the ! external (reactor building to suppression chamber) vacuum l breakers. ! l FERMI UNIT 2 B 3.6.1.7 - 1 Revision 5 04/30/99 l

Reactor Building to Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES l APPLICABLE SAFETY ANALYSES (continued) The results of these two cases show that the external vacuum breakers, with an opening setpoint of 0.5 psid, are capable of maintaining the differential pressure within design limits. ! The reactor building to suppression chamber vacuum breakers i l satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). l LC0 All reactor building to suppression chamber vacuum breakers, j l 4 two on each line, are required to be OPERABLE to satisfy the i l q assumptions used in the safety analyses. The requirement j ensures that the two vacuum breakers (vacuum breaker and air 4 i operated butterfly isolation valve) in each of the two lines i from the reactor building to the suppression chamber i q airspace are closed (except during testing or when performing their intended function). Also, the requirement l ( ensures both vacuum breakers in each line will open to relieve a negative pressure in the suppression chamber. APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. In MODES 1, 2. and 3, the Primary Containment is required to be OPERABLE to mitigate the effects of a DBA. Excessive negative pressure inside primary containment could occur due to inadvertent initiation of the Suppression Pool Saray System. Therefore, the vacuum breakers are required to )e OPERABLE in MODES 1, 2, and 3, when the Primary Containment is required to be l OPERABLE, to mitigate the effects of inadvertent actuation of the Suppression Pool Spray System. ! I Also, in MODES 1, 2, and 3 a DBA could result in excessive j negative differential pressure across the drywell wall i caused by the rapid depressurization of the drywell. The I event that results in the limiting rapid depressurization of the drywell is the primary system rupture, which purges the drywell of air and fills the drywell free airspace with steam. Subsequent condensation of the steam would result in depressurization of the drywell. The limiting pressure and temperature of the primary system prior to a DBA occur in l MODES 1, 2, and 3. i l l FERMI - UNIT 2 B 3.6.1.7 - 3 Revision 5, 04/30/99 l i l l

i Reactor Building to Suppression Chamber Vacuum Breakers 1 B 3.6.1.7 i BASES i APPLICABILITY (continued) In H0 DES 4 and 5, the probability and consequences of these i events are reduced due to the pressure and temperature l l limitations in these MODES. Therefore, maintaining reactor l building to suppression chamber vacuum breakers OPERABLE is not required in MODE 4 or 5. ba ACTIONS A Note has been added to provide clarification that, for the t purmse of this LCO, separate Condition entry is allowed for T eac1 penetration flow path. M ! 4' With one or more vacuum breakers not closed, the leak tight i primary containment boundary may be threatened. Therefore, l E the inoperable vacuum breakers must be restored to OPERABLE ! T status (i.e. closed) within 72 hours. The 72 hour l Completion Time is consistent with requirements for inoperable suppression chamber to drywell vacuum breakers in LC0 3.6.1.8, " Suppression Chamber to Drywell Vacuum Breakers." The 72 hour Completion Time takes into account the redundancy capability afforded by the remaining breakers, the fact that the OPERABLE breaker in each of the lines is closed, and the low probability of an event i occurring that would require the vacuum breakers to be OPERABLE during this period. l l M With one or more lines with two vacuum breakers not closed, primary containment integrity is not maintained. Therefore, one open vacuum breaker must be closed within 2 hours. This i Completion Timo is reasonable based on engineering ' W judgement. I

  ~l                       M
 <d l With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary is intact. The ability to mitigate an event that causes a
  ',                       containment depressurization is threatened, however, if both vacuum breakers in at least one vacuum breaker penetration are not OPERABLE. Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours. This is consistent with the Completion Time for Condition A and l FERMI    UNIT 2                     83.6.1.7-4              Revision 5. 04/30/99 l

l l

Reactor Building-to Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES ACTIONS (continued) the fact that the leak tight primary containment boundary is being maintained. O gl D.1 and D.2 i If all the vacuum breakers in one line cannot be closed or E' l restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 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 recuired plant conditions from full power conditions in an orcerly 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 3ressure of 0.5 psid is maintained between the reactor )uilding 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 actual differential pressure are not considered as failing this SR. l FERMI UNIT 2 B 3.6.1.7 - 5 Revision 5. 04/30/99

l Suppression Chamber-to Orywell Vacuum Breakers B 3.6.1.8 BASES ACTIONS (continued) IL1 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 y to occur. Therefore, the open vacuum breaker must be closed 4 (confirmation of the closed status would follow procedures as outlined in the Bases for SR 3.6.1.8.1). The 2 hour k completion time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment. C.1 and C.2 If the inoperable suppression chamber to drywell vacuum breaker cannot be closed or restored to OPERABLE status within the required Completion Time the plant must be brought to a MODE in which the LC0 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 Com experience,pletion to reachTimes are reasonable, the required based from plant conditions on operating full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.1.8.1 l REQUIREMENTS. ! Each vacuum breaker is verified closed to ensure that this l 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 i torus to drywell differential )ressure, alternate methods of verifying that the vacuum brea(er is closed are detailed in Technical Requirements Manual (TRM).

l FERMI UNIT 2 B 3.6.1.8 - 4 Revision 5 04/30/99

Suppression Chamber to Drywell Vacuum Breakers l B 3.6.1.8 i i BASES SURVEILLANCE REQUIREMENTS (continued) If position indication appears reliable (dual or open indication while torus to drywell differential pressure is steady at 0 psid), and indicates open, the alternate methods outlined in the TRM can prove the indication to be in error and the vacuum breaker closed. However, in this case the vacuum breaker is assumed open until otherwise proved to l satisfy the leakage test, and this confirmation must be serformed within the Technical Specification 3.6.1.8 lequired Action B.1 Completion Time of 2 hours. The 7 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. Notes 1 and 2 are added to this SR which allows suppression l chamber-to drywell vacuum breakers opened in conjunction l with the performance of a Surveillance or open while l performing their intended function to not be considered as l failing this SR. These periods do not represent inoperable vacuum breakers. SR 3.6.1.8.2 l Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fuily closed position. This ensures that the i safety analysis assumptions are valid. The Frequency of

                     " prior to entering MODE 2 or 3 from MODE 4 if not performed in the previous 92 days" is based upon the demonstrated reliability of the vacuum breakers and the potential for the I

test to result in a stuck open vacuum breaker, which could be caused by a failure of the pneumatically operated test mechanism. Since the vacuum breaker is inaccessible in MODES 1, 2, and 3, test induced inoperability would result in a forced shutdown of the unit. In addition, there exists substantial redundancy in that 4 vacuum breakers must fail to open before the safety function is lost. In addition, this functional test is required within 12 hours after a discharge of steam to the suppression chamber from the safety / relief valves. l l FERMI - UNIT 2 B 3.6.1.8 - 5 Revision 5. 04/30/99

Suppression Pool Average Temperature B 3.6.2.1 BASES APPLICABLE SAFETY ANALYSES (continued) assumed for the Reference 1 and Reference 2 analyses. Reactor shutdown at a pool temperature of 110*F and vessel depressurization at a pool temperature of 120*F are assumed for the Reference 2 analyses. The limit of 105'F, at which testing is terminated, is not used in the safety analyses because DBAs-are assumed to not initiate during unit testing. Suppression pool average temperature satisfies Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii). l LCO A limitation on the suppression pool average temperature is ' required to provide assurance that the containment conditions assumed for the safety analyses are met. This limitation subsequently ensures that peak primary containment pressures and temperatures do not exceed maximum l allowable values during a postulated DBA or any transient resulting in heatup of the suppression pool. The LC0 requirements are: l l

a. Average temperature s 95'F with THERMAL POWER > lt )

RATED THERMAL POWER (RTP) and no testing that adds heat ' g to the suppression pool is being performed. This i

   ,                           requirement ensures that licensing bases initial           '

conditions are met. l Y l l b. Average temperature s 105'F with THERMAL POWER > 11 RTP and testing that adds heat to the suppression pool is being performed. This required value ensures that the unit has testing flexibility, and was selected to ! provide margin below the 110*F limit at which reactor l shutdown is required. When testing ends, temperature l l must be restored to s 95*F within 24 hours according to Required Action A.2. Therefore, the time period that l the temperature is > 95*F is short enough not to cause g a significant increase in unit risk. l

c. Average temperature s 110*F with THERMAL POWER s it k l RTP. This requirement ensures that the unit will be shut down at > 110 F. The pool is designed to absorb decay heat and sensible heat but could be heated beyond design limits by the steam generated if the reactor is not shut down.

j FERMI - UNIT 2 B 3.6.2.1 - 2 Revision 5. 04/30/99 1

l l Suppression Pool Average Temperature ) B 3.6.2.1 : l l BASES i ACTIONS (continued) E.1 and E.2 If suppression pool average temperature cannot be maintained j at s 120*F. the plant must be brought to a MODE in which the j LC0 does not a) ply. To achieve this status, the reactor I pressure must >e reduced to < 200 psig within 12 hours and : g the plant must be brought to at least MODE 4 within ! i 36 hours. The allowed Completion Times are reasonable. t based on operating experience, to reach the recuired plant l conditions from full power conditions in an orcerly manner and without challenging plant systems. j i Continued addition of heat to the suppression pool with ) suppression pool temperature > 120*F could result in 1 exceeding the design basis maximum allowable values for j primary containment temperature or pressure. Furthermore, j if a blowdown were to occur when the temperature was :

                        > 120*F. the maximum allowable bulk and local temperatures      . l could be exceeded very quickly.
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SURVEILLANCE SR 3.6.2.1.1 I REQUIREMENTS l The suppression pool average temperature is regularly monitored to ensure that the required limits are satisfied. The average temperature is determined by taking an arithmetic average of OPERABLE suppression pool water temperature channels. The 24 hour Frequency has been shown, based on operating experience, to be acceptable. When heat is being added to the suppression pool by testing, however. it is necessary to monitor suppression pool temperature more frequently. The 5 minute Frequency during testing is justified by the rates at which tests will heat up the , suppression pool, has been shown to be acceptable based on operating experience, and provides assurance that allowable pool temperatures are not exceeded. The Frequencies are further justified in view of other indications available in the control room. including alarms, to alert the operator to an abnormal suppression pool average temperature condition. REFERENCES 1. UFSAR. Section 6.2.

2. UFSAR. Section 15.1.4.

I FERMI UNIT 2 B 3.6.2.1 - 5 Revision 5 04/30/99

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. . l l With two RHR suppression pool cooling subsystems inoperable. . one subsystem must be restored to OPERABLE status within l 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 N of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant N shutdown transient that could result in the need for the RHR I suppression pool cooling subsystem to operate. C.1 and C.2 If the Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LC0 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 sup)ression pool cooling mode flow path provides assurance tlat the proper flow path exists for system o)eration. This SR does not apply to valves that are loc (ed, 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 l FERMI UNIT 2 83.6.2.3-3 Revision 5, 04/30/99

r Rift 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 Frecuency of 31 days is justified because the valves are operatec 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. S.R 3.6.2.3.2 Verifying that each RHR pump develops a flow rate

                      = 10,000 gpm while operating in the su)pression pool cooling mode with flow through the associated leat exchanger ensures that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance T required by ASME Code, Section XI (Ref. 2). This test confirms one point on the pump design curve, and the results 4 ( 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. ASME, Boiler and Pressure Vessel Code, Section XI.

l l FERMI - UNIT 2 B 3.6.2.3 - 4 Revision 5 04/30/99

i PriCary Containment Hydrogen Recombiners B 3.6.3.1 B 3.6 CONTAINNENT SYSTEMS B 3.6.3.1 Primary Containment Hydrogen Recombiners BASES F BACKGROUND The primary containment hydrogen recombiner eliminates the l potential breach of primary containment due to a hydrogen oxygen reaction and is part of combustible gas control . required by 10 CFR 50.44, " Standards for Combustible Gas Control Systems in Light Water Cooled Reactors" (Ref.1), and GDC 41, " Containment Atmosphere Cleanup" (Ref. 2). The primary containment hydrogen recombiner is required to-gj reduce the hydrogen concentration in the primary containment following a loss of coolant accident (LOCA). The primary containment hydrogen recombiner accomplishes this by recombining hydrogen and oxygen to form water vapor. The vapor remains in the primary containment, thus eliminating any discharge to the environment. The primary containment 4l hydrogen recombiner is manually initiated since flammability limits would not be reached until several days after a s Design Basis Accident (DBA).

The primary containment hydrogen recombiner functions to kl maintain the hydrogen gas concentration within the containment (both drywell and suppression chamber) at or Sl below the flammability limit of 6.0 volume percent (v/o) : following a postulated LOCA. It is fully redundant and j consists of two 100t capacity subsystems. Each primary j containment hydrogen recombiner consists of an enclosed blower assembly, heater section, reaction chamber, direct contact water spray gas cooler, water separator, and associated piping, valves, and instruments. The primary containment hydrogen recombiner will be manually initiated s from the main control room when the hydrogen gas concentration in the primary containment reaches 1.0 v/o. When the primary containment is inerted (oxygen concentration < 4.0 v/0), the primary containment hydrogen recombiner will only function until the oxygen is used up (2.0 v/o hydrogen combines with 1.0 v/o oxygen). Two recombiners are provided to meet the requirement for redundancy and independence. Each recombiner is powered from a separate Engineered Safety Feature bus and is provided with separate power panel and control panel. l FERMI - UNIT 2 B 3.6.3.1 - 1 Revision 5. 04/30/99

Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES BACKGROUND (continued) The process gas circulating through the heater, the reaction i cham)er, and the cooler is automatically regulated to 150 scfm. The process gas is heated to 1300*F. The hydrogen and oxygen gases are recombined into water va)or, which is then condensed in the water spray gas cooler Jy the associated residual heat removal subsystem and discharged with some of the effluent process gas to the suppression chamber. The majority of the cooled, effluent process gas is mixed with the incoming process gas to dilute the incoming gas prior to the mixture entering the heater , section. ! l l APPLICABLE The primary containment hydrogen recombiner provides 1 - l SAFETY ANALYSES the capability of controlling the bulk hydrogen I 1 concentration in primary containment to less than the lower j gl flammable concentration of 6.0 v/o following a DBA. This I control would prevent a primary containment wide hydrogen burn, thus ensuring that pressure and temperature conditions assumed in the analysis are not exceeded. The limiting DBA relative to hydrogen generation is a LOCA. Hydrogen may accumulate in primary containment following a LOCA as a result of:

a. A metal steam reaction between the zirconium fuel rod cladding and the reactor coolant: or I

b. Hydrogen contained in the water in the Reactor Coolant System from radiolytic decomposition and the hydrogen water chemistry contro'l program.

To evaluate the potential for hydrogen accumulation in primary containment following a LOCA, the hydrogen generation is calculated as a function of time following the initiation of the accident. Assum)tions recommended by Reference 3 are used to maximize t1e amount of hydrogen l calculated. The calculation (Ref. 4) confirms that hydrogen and oxygen can be safely and effectively controlled to the limits of Table 1 of Reference 5. l l FERMI - UNIT 2 B 3.6.3.1 - 2 Revision 5 04/30/99

Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES APPLICABLE SAFETY ANALYSES (continued) The primary containment hydrogen recombiners satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). l LC0 Two primary containment hydrogen recombiners must be OPERABLE. This ensures operation of at least one primary containment hydrogen recombiner subsystem in the event of a l worst case single active failure. 1 Operation with at least one primary containment hydrogen W recombiner subsystem ensures that the post LOCA hydrogen i concentration can be prevented from exceeding the l Nj flammability limit. l

 -                                                                                        l t

In MODES 1 and 2, the two primary containment hydrogen f APPLICABILITY j recombiners are required to control the hydrogen 1 concentration within primary containment below its l gl flammability limit of 6.0 v/o following a LOCA assuming a l worst case single failure. In MODE 3. both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the DBA LOCA. Also, because of the limited time in this MODE the probability of an accident requiring the primary containment hydrogen recombiner is low. , Therefore, the primary containment hydrogen recombiner is not required in MODE 3. In MODES 4 and 5. the probability and consequences of a LOCA are low due to the pressure and temperature limitations in these MODES. Therefore, the primary containment hydrogen recombiner is not required in these MODES. ACTIONS Ad With one primary containment hydrogen recombiner incoerable. the inoperable recombiner must be restored to OPERABLE status within 30 days. In this Condition. the remaining OPERABLE recombiner is adequate to perform the hydroger, control function. However, the overall reliability is reduced because a single. failure in the OPERABLE recomt'iner l FERMI UNIT 2 B 3.6.3.1 - 3 Revision 5 04/30/99

i Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES ACTIONS (continued) could result in reduced hydrogen control capability. The i 30 day Completion Time is based on the low probability of ! the occurrence of a LOCA that would generate hydrogen in Nl amounts capable of exceeding the flamability limit. the amount of time available after the event for operator action to prevent exceeding this limit and the low probability of failure of the OPERABLE primary containment hydrogen recombiner. Required Action A.1 has been modified by a Note indicating that the provisions of LC0 3.0.4 are not applicable. As a result, a MODE change is allowed when one recombiner is ino >erable. This allowance is provided because of the low N 3ro) ability of the occurrence of a LOCA that would generate lydrogen in amounts capable of exceeding the flamability limit. the low probability of the failure of the OPERABLE . subsystem. and the amount of time availa' ole after a l postulated LOCA for operator action'to prevent exceeding the flamability limit. B.1 and B.2 l

i With two primary containment hydrogen recombiners Ql inoperable. the ability to )erform the hydrogen control function via alternate capa)ilities must be verified by yl ~, administrative means within 1 hour. The alternate hydrogen control capabilities are provided by the Primary Containment Inerting System. The 1 hour Completion Time allows a il reasonable period of time to verify that a loss of hydrogen control function does not exist. In addition, the alternate W hydrogen control system capability must be verified once per 12 hours thereafter to ensure its continued availability. Both the initial verification and all subsequent verifications may be performed as an administrative check by examining logs or other information to determine the availability of the Primary Containment Inerting System. It does not mean to perform the Surveillances needed to " demonstrate OPERABILITY of the Primary Containment Inerting System. If the ability to perform the hydrogen control function is maintained. continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Seven days is a reasonable time to allow two hydrogen 9 recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of ( the occurrence of a LOCA that would generate hydrogen in amounts capable of exceeding the flamability limits. j FERMI UNIT 2 B 3.6.3.1 - 4 Revision 5. 04/30/99

l , Secondary Containment l B 3.6.4.1 BASES l g l ACTIONS M i With a Secondary Containment railroad bay access door i inoperable there remains a redundant access door in an l 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 a) the problem given the availability of the other access door 4 and the low probability of an event occurring that will challenge the Secondary Containment during this time period. bl M i If secondary containment is inoperable for reasons other 4l 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. l C.1 and C.2 If secondary containment cannot be restored to OPEPABLE status within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least i MODE 3 within 12 hours and to MODE 4 within 36 hours. The I 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. i l FERMI UNIT 2 B 3.6.4.1 - 3 Revision 5. 04/30/99

i Secondary Containment l B 3.6.4.1 BASES ACTIONS (continued) D.1. D.2. and D.3 Movement of irradiated fuel assemblies in the secondary j containment, CORE ALTERATIONS, and OPDRVs can be postulated l to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the ; environment. CORE ALTERATIONS and movement of irradiated ; fuel assemblies must be immediately suspended if the i secondary containment is inoperable. l Suspension of these activities shall not preclude completing an action that involves moving a component to a safe position. Also, action must be immediately initiated to , l suspend OPDRVs to minimize the probability of a vessel ' draindown and subsequent potential for fission product F release. Actions must continue until OPDRVs are suspended. i TEl l The Required Actions have been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5. LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2 or 3, the fuel movement is independent of reactor i operations. Therefore, in either case, inability to suspend ! movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. SURVEILLANCE SR 3.6.4.1.1 REQUIREMENTS l This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions. The 24 hour Frequency of this SR was developed basti on operating experience related to secondary containment vacuum variations during the applicable MODES and the low probability of a DBA occurring between surveillances. Furthermore, the 24 hour Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal secondary containment vacuum condition. l FERMI UNIT 2 B 3.6.4.1 - 4 Revision 5, 04/30/99

Secondary Containment B 3.6.4.1 l BASES SURVEILLANCE REQUIREENTS (continued) I 1 SR 3.6.4.1.2 and SR 3.6.4.1.3 Verifying that secondary containment equipment hatches. pressure relief doors, railroad bay access doors, and one access door in each access opening are closed ensures that the infiltration of outside air of such a magnitude as to l prevent maintaining the desired negative pressure ooes not ' occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary a containment will not occur. In this ap)1ication the term

                      " sealed" has no connotation of leak tig1tness. Maintaining secondary containment OPERABILITY recuires verifying one door in each access opening is closec. An access opening       1 contains one inner and one outer door. In some cases, secondary containment access openings are shared such that a   f J

secondary containment barrier may have multiple inner or l multiple outer doors. The intent is not to breach the I secondary containment at any time when secondary containment ! is required. This is achieved by maintaining the inner or outer portion of the barrier closed at all times. However, all secondary containment access doors are normally kept i closed. except when the access opening is being used for entry and exit or when maintenance is being performed on an e access opening. The 31 day Frequency for these SRs has been shown to be adequate. based on o)erating experience, and is [ considered adequate in view of t1e other indications of door l and hatch status that are available to the operator. j A Note is added to SR 3.6.4.1.2 to allow a secondary containment railroad bay access door to be open for up g to 4 hours for entry. exit or testing. and up to 12 hours for new fuel receipt activities. These activities do not indicate a problem with a railroad bay access door and the ! door should not be considered inoperable. Also, with one l @ railroad bay door remaining closed, secondary containment OPERABILITY is maintained. The times allowed are reasonable for the activities being performed considering the availability of the redundant door. l 1 l l l 4 l FERMI UNIT 2 B 3.6.4.1 - 5 Revision 5. 04/30/99

F l Secondary Containment B 3.6.4.1 BASES l l _ SURVEILLANCE REQUIREENTS (continued) 3 SR 3.6.4.1.4 If the steam tunnel blowout panels are open the integrity of l the Secondary Containment is lost. Since the steam tunnel blowout panels are inaccessible during plant operation, this SR is only required to be performed during MODE 4. but only ! l if it has been greater than 31 days since the last I verification. This frequency has been shown to be adequate I based on operating experience, and in view of other ! indications of the status of the steam tunnel blowout panels available to the operator. SR 3.6.4.1.5 and SR 3.6.4.1.6 The SGT System exhausts the secondary containment atmosphere to the environment through appropriate trutment equipment. To ensure that all fission products are treated. SR 3.6.4.1.5 verifies that the SGT System will rapidly establish and maintain a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary. This is ! confirmed by demonstrating that one SGT subsystem will draw l down the secondary containment to = 0.25 inches of vacuum { water gauge in a 567 seconds. This cannot be accomplished if the secondary containment boundary is not intact. I' SR 3.6.4.1.6 demonstrates that one SGT subsystem can maintain = 0.25 inches of vacuum water gauge for 1 hour at a flow rate s 3000 cfm. The 1 hour test period allows secondary containment to be in thermal equilibrium at steady state conditions. Therefore, these two tests are used to

ensure secondary containment boundary integrity. Since these SRs are secondary containment tests, they need not be performed with each SGT subsystem. The SGT subsystems are tested on a STAGGERED TEST BASIS however, to ensure that in addition to the requirements of LC0 3.6.4.3. either SGT subsystem will perform this test. Operating experience has shown these~ components usually pass the Surveillance when , performed at the 18 month Frequency. Therefore, the 1 Frequency was concluded to be acceptable from a reliability 1 standpoint. a REFERENCES 1. UFSAR. Section 15.6.5. !

2. UFSAR. Section 15.7.4. I 4 l FERMI UNIT 2 B 3.6.4.1 - 6 Revision 5. 04/30/99 i

I

SCIVs B 3.6.4.2 BASES APPLICABLE SAFETY ANALYSES (continued) l containment performs no active function in response to either of these limiting events, but the boundary established by SCIVs is required to ensure that leakage from the primary containment is processed by the Standby Gas Treatment (SGT) System before being released to the environment. Maintaining SCIVs OPERABLE with isolation times within limits ensures that fission products will remain trapped inside secondary containment so that they can be treated by. the SGT System prior to discharge to the environment. SCIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). LC0 SCIVs form a part of the secondary containment boundary. The SCIV safety function is related to control of offsite radiation releases resulting from OBAs. hl The power operated automatic isolation talves are considered OPERABLE when their isolation times are within limits and the valves actuate on an automatic isolation signal. The valves covered by this LCO, along with their associated stroke times, are listed in Reference 3. APPLICABILITY In MODES 1, 2,. and 3. a DBA could lead to a fission product release to the primary containment that leaks to the secondary containment. Therefore, the OPERABILITY of SCIVs is required. In MODES 4 and 5. the probability and consequences of these events are reduced due to pressure and temperature limitations in these MODES. Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for other situations under which significant radioactive releases can be postulated, such as during operations with a potential , for draining the reactor vessel (0PDRVs), during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment. Moving irradiated fuel assemblies in the secondary containment may also occur in MODES 1, 2 and 3. l FERMI UNIT 2 B 3.6.4.2 - 2 Revision 5, 04/30/99 l

r SCIVs B 3.6.4.2 BASES ACTIONS (continued) containment penetrations required to be isolated following an accident, but no longer capable of being automatically , isolated, will be in the isolation position should an event I occur. The Completion Time of once per 31 days is appropriate because the valves are operated under administrative controls and the probability of their , misalignment is low. This Required Action does not require I any testing or device manipulation. Rather, it involves ; verification that the affected penetration remains isolated. l l Required Action A.2 is modified by two Notes. Note 1 a plies to devices located in high radiation areas and i a lows them to be verified closed by use of administrative l controls. Allowing verification by administrative controls I is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment, once they have been verified to be in the proper position, is low. Note 2 applies to isolation i devices that are locked, sealed, or otherwise secured in ' position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to l ensure that these devices are not inadvertently repositioned. ill With two SCIVs in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 4 hours. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic valve, a closed manual valve, and a blind flange. The 4 hour Completion Time is reasonable considring the time required to isolate the penetration and the prxebility of a DBA, which requires the SCIVs to close, occurrim; during this short time, is very low. The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of two penetrations. I FERMI UNIT 2 B 3.6.4.2 -4 Revision 5 04/30/99

SCIVs B 3.6.4.2 BASES ACTIONS (continued) C.1 and C l - If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 I within 36 hours. The allowed Completion Times are ] reasonable, based on operating experience, to reach the ; recuired plant conditions from full power conditions in an 1 orcerly manner- and without challenging plant systems. 1 D.I. D.2. and 0.3 j 1 If any Required Action and associated Completion Time are { not met, the plant must be placed in a condition in which . the LC0 does not apply. If applicable. CORE ALTERATIONS and I the movement of irradiated fuel assemblies in the secondary ! containment must be immediately suspended. Suspension of I these activities shall not preclude completion of movement i of a component to a safe position. Also, if applicable, l actions must be immediately initiated to suspend OPDRVs in ! order to minimize the probability of a vessel draindown and : the subsequent potential for fission product release. l Actions must continue until OPDRVs are suspended. I h 1l The Required Actions have been modified by a Note stating 4 that LC0 3.0.3 is not applicable. If moving irradiated fuel A assemblies while in MODE 4 or 5. LC0 3.0.3 would not specify any action. If moving fuel while in MODE 1, 2, or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. l FCRMI UNIT 2 83.6.4.2-5 Revision 5. 04/30/99

l SCIVs B 3.6.4.2 BASES SURVEILLANCE SR 3.6.4.2.1 ' REQUIREMENTS This SR verifies that each secondary containment manual isolation valve and blind flange that is not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside of the secondary containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification that those SCIVs in secondary containment that are capable of being mispositioned are in the correct position. i Since these SCIVs are readily accessible to personnel during l normal operation and verification of their )osition is relatively easy, the 31 day Frequency was closen to provide added assurance that the SCIVs are in the correct positions. Two Notes have been added to this SR. The first Note applies to valves and blind flanges located in high radiation areas and allows them to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable. since l access to these areas is typically restricted during MODES 1. 2, and 3 for ALARA reasons. Therefore, the i probability of misalignment of these SCIVs. once they have ; been verified to be in the proper position, is low. i l A second Note has been included to clarify that SCIVs that j are open under administrative controls are not required to l meet the SR during the time the SCIVs are open. i SR 3.6.4.2_2 Verifying that the isolation time of each power operated automatic SCIV is within limits is required to demonstrate OPERABILITY. The isolation time test ensures that the SCIV will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. l j FERMI - UNIT 2 B 3.6.4.2 - 6 Revision 5. 04/30/99 l l

SCIVs B 3.6.4.2 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.6.4.2.3 Verifying that each automatic SCIV closes on a secondary containment isolation signal is recuired to prevent leakage of radioactive material from seconcary containment following a DBA or other accidents. This SR ensures that each automatic SCIV will actuate to the isolation position on a secondary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function. The 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 Frecuency was concluded to be acceptable from a reliability stancpoint. REFERENCES 1. UFSAR. Section 15.6.5.

2. UFSAR. Section 15.7.4.

3. Technical Requirements Manual.

I FERMI UNIT 2 B 3.6.4.2- 7 Revision 5 04/30/99

1 SGT System B 3.6.4.3 B 3.6 CONTAINHENT SYSTEMS B 3.6.4.3 Standby Gas Treatment (SGT) System BASES BACKGROUND The SGT System is required by 10 CFR 50. Appendix A. GDC 41

                          " Containment Atmosphere Cleanup" (Ref. 1). The function of the SGT System is to ensure that radioactive materials that leak from the primary containment into the secondary containment following a Design Basis Accident (DBA) are filtered and adsorbed prior to exhausting to the environment.

bl 3 The SGT System consists of two independent fully redundant subsystems, each with its own set of ductwork, dampers, k charcoal filter train, and controls. Each charcoal filter train consists of (components listed in order of the direction of the air flow):

a. A moisture separator;

b. A prefilter;

c. An electric heater:

d. A high efficiency particulate air (HEPA) filter;

e. A charcoal adsorber:

f. A second HEPA filter:

g. An exhaust fan: and

h. A cooling air fan installed in parallel with the exhaust fan.

The sizing of the SGT System equipment and components is based on the results of an infiltration analysis, as well as an exfiltration analysis of the secondary containment. The internal pressure of the SGT System boundary region is maintained at a negative pressure of 0.25 inches water gauge when the system is in operation, which maintains a negative pressure that precludes direct leakage out of the secondary containment. l FERMI UNIT 2 B 3.6.4.3 - 1 Revision 5. 04/30/99

l SGT System l B 3.6.4.3 BASES , ACTIONS (continued) i E.1. E.2. and E.3 When two SGT subsystems are inoperable, if applicable. CORE ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of these activities shall not preclude completion l of movement of a component to a safe position. Also, if applicable actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until 0PDRVs are suspended. Ql The Required Actions have been modified by a Note stating that LC0 3.0.3 is not applicable. If moving irradiated fuel 4 assemblies while in MODE 4 or 5. LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in l H00E 1. 2. or 3. the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown. SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Omrating each SGT subsystem from the control room with flow t1 rough the HEPA filters and charcoal adsorbers for = 10 i continuous hours ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for a 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in l consideration of the known reliability of fan motors and controls and the redundancy available in the system. 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. 3). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical l l FERMI UNIT 2 B 3.6.4.3 - 5 Revision 5. 04/30/99 l i}}

ML20206H552

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