ML15268A149

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Fermi 2 - License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process
ML15268A149
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/24/2015
From: Kaminskas V A
DTE Electric Company, DTE Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, NRC-15-0090
Download: ML15268A149 (61)


Text

RHR Shutdown Cooling System-Hot Shutdown B 3.4.8 BASES LCO (continued)

common discharge piping. Thus, to meet the LCO, both pumps

in one loop or one pump in each of the two loops must be

OPERABLE. Since the piping and heat exchangers are passive

components that are assumed not to fail, they are allowed to

be common to both subsystems. Each shutdown cooling

subsystem is considered OPERABLE if it can be manually

aligned (remote or local) in the shutdown cooling mode for

removal of decay heat. In MODE 3, one RHR shutdown cooling

subsystem can provide the required cooling, but two

subsystems are required to be OPERABLE to provide

redundancy. Operation of one subsystem can maintain or

reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate

average reactor coolant temperature monitoring, nearly

continuous operation is required.

Note 1 permits both RHR shutdown cooling subsystems to be

shut down for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period. Note

2 allows one RHR shutdown cooling subsystem to be inoperable

for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillance tests.

These tests may be on the affected RHR System or on some

other plant system or component that necessitates placing

the RHR System in an inoperable status during the

performance. This is permitted because the core heat

generation can be low enough and the heatup rate slow enough

to allow some changes to the RHR subsystems or other

operations requiring RHR flow interruption and loss of

redundancy.

APPLICABILITY In MODE 3 with reactor steam dome pressure below the RHR

cut in permissive pressure (i.e., the actual pressure at

which the interlock resets) the RHR System may be operated

in the shutdown cooling mode to remove decay heat to reduce

or maintain coolant temperature. Otherwise, a recirculation

pump is required to be in operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome

pressure greater than or equal to the RHR cut in permissive

pressure, this LCO is not applicable. Operation of the RHR

System in the shutdown cooling mode is not allowed above

this pressure because the RCS pressure may exceed the design

pressure of the shutdown cooling piping. Decay heat removal

at reactor pressures greater than or equal to the RHR cut in

permissive pressure is typically accomplished by condensing FERMI - UNIT 2 B 3.4.8-2 Revision 0

RHR Shutdown Cooling System-Hot Shutdown B 3.4.8 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance being met (i.e., forced coolant circulation is not required for this initial 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period), which also

allows entry into the Applicability of this Specification in

accordance with SR 3.0.4 since the Surveillance will not be

"not met" at the time of entry into the Applicability. REFERENCES None.

FERMI - UNIT 2 B 3.4.8-6 Revision 0 Insert 1 SR 3.4.8.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam dome pressure is < the RHR cut in permissive pressure. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering the Applicability.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Shutdown Cooling System -

Cold Shutdown B 3.4.9 BASES LCO (continued) in one loop or one pump in each of the two loops must be OPERABLE. Since the piping and heat exchangers are passive

components that are assumed not to fail, they are allowed to

be common to both subsystems. In MODE 4, the RHR cross tie

valve (E1150-F010) may be opened to allow pumps in one loop

to discharge through the opposite recirculation loop to make

a complete subsystem. Additionally, each shutdown cooling

subsystem is considered OPERABLE if it can be manually

aligned (remote or local) in the shutdown cooling mode for

removal of decay heat. In MODE 4, one RHR shutdown cooling

subsystem can provide the required cooling, but two

subsystems are required to be OPERABLE to provide

redundancy. Operation of one subsystem can maintain or

reduce the reactor coolant temperature as required.

However, to ensure adequate core flow to allow for accurate

average reactor coolant temperature monitoring, nearly

continuous operation is required.

Note 1 permits both RHR shutdown cooling subsystems to be

shut down for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

Note 2 allows one RHR shutdown cooling subsystem to be

inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of

Surveillance tests. These tests may be on the affected RHR

System or on some other plant system or component that

necessitates placing the RHR System in an inoperable status

during the performance. This is permitted because the core

heat generation can be low enough and the heatup rate slow

enough to allow some changes to the RHR subsystems or other

operations requiring RHR flow interruption and loss of

redundancy. APPLICABILITY In MODE 4, the RHR Shutdown Cooling System may be operated in the shutdown cooling mode to remove decay heat to

maintain coolant temperature below 200F. Otherwise, a recirculation pump is required to be in operation. However,

when decay losses to ambient are sufficient to maintain

reactor coolant temperature steady at the existing

temperature the requirements for the RHR Shutdown Cooling

System are not necessary to assure continued safe operation.

In MODES 1 and 2, and in MODE 3 with reactor steam dome

pressure greater than or equal to the RHR cut in permissive

pressure, this LCO is not applicable. Operation of the RHR

System in the shutdown cooling mode is not allowed above FERMI - UNIT 2 B 3.4.9-2 Revision 0 RHR Shutdown Cooling System -

Cold Shutdown B 3.4.9 BASES SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This Surveillance verifies that one RHR shutdown cooling subsystem or recirculation pump is in operation and

circulating reactor coolant. The required flow rate is

determined by the flow rate necessary to provide sufficient

decay heat removal capability. The Surveillance Frequency

is controlled under the Surveillance Frequency Control

Program.

REFERENCES None. FERMI - UNIT 2 B 3.4.9-5 Revision 64 Insert 2 SR 3.4.9.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS-Operating B 3.5.1 BASES APPLICABLE SAFETY ANALYSES (continued) b.Maximum cladding oxidation is 0.17 times the total cladding thickness before oxidation;c.Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding surrounding the fuel, excluding the cladding

surrounding the plenum volume, were to react;d.The core is maintained in a coolable geometry; ande.Adequate long term cooling capability is maintained.

The limiting single failures are discussed in Reference 11.

The Design Basis Accident recirculation suction line break

with the failure of the Division II battery results in the

highest nominal peak cladding temperature. One ADS valve

failure is analyzed as a limiting single failure for events

requiring ADS operation. The remaining OPERABLE ECCS

subsystems provide the capability to adequately cool the

core and prevent excessive fuel damage.

The ECCS satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Each ECCS injection/spray subsystem and five ADS valves are

required to be OPERABLE. The ECCS injection/spray

subsystems are defined as the two CS subsystems, the two

LPCI subsystems, and one HPCI System. The low pressure ECCS

injection/spray subsystems are defined as the two CS

subsystems and the two LPCI subsystems.

With less than the required number of ECCS subsystems

OPERABLE, the potential exists that during a limiting design

basis LOCA concurrent with the worst case single failure,

the limits specified in Reference 10 could be exceeded. All

ECCS subsystems must therefore be OPERABLE to satisfy the

single failure criterion required by Reference 10.

LPCI subsystems may be considered OPERABLE during alignment

and operation for decay heat removal when below the actual

RHR cut in permissive pressure in MODE 3, if capable of

being manually realigned (remote or local) to the LPCI mode

and not otherwise inoperable. At these low pressures and

decay heat levels, a reduced complement of ECCS subsystems

should provide the required core cooling, thereby allowing

operation of RHR shutdown cooling when necessary.

FERMI - UNIT 2 B 3.5.1-5 Revision 55 ECCS-Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note to indicate that when this test results in LPCI inoperability solely for performance of

this required Surveillance, or when the LPCI swing bus

automatic throwover scheme is inoperable due to EDG-12 being

paralleled to the bus for required testing, entry into

associated Conditions and Required Actions may be delayed

for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until the required testing is completed.

Upon completion of the Surveillance or expiration of the

12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance the swing bus must be returned to OPERABLE

status or the applicable Condition entered and Required

Actions taken. The LPCI swing bus automatic throwover scheme

is typically not inoperable when EDG-12 is paralleled to the

bus for testing purposes.

SR 3.5.1.3 The flow path piping has the potential to develop voids and

pockets of entrained air. Maintaining the pump discharge

lines of the HPCI System, CS System, and LPCI subsystems

full of water ensures that the ECCS will perform properly,

injecting its full capacity into the RCS upon demand. This

will also prevent a water hammer following an ECCS

initiation signal. One acceptable method of ensuring that

the lines are full is to vent at the high points. The

Surveillance Frequency is controlled under the Surveillance

Frequency Control Program.

SR 3.5.1.4 Verifying the correct alignment for manual, power operated,

and automatic valves in the ECCS flow paths provides

assurance that the proper flow paths will exist for ECCS

operation. This SR does not apply to valves that are

locked, sealed, or otherwise secured in position since these

were verified to be in the correct position prior to

locking, sealing, or securing. A valve that receives an

initiation signal is allowed to be in a non-accident

position provided the valve will automatically reposition in

the proper stroke time. This SR does not require any

testing or valve manipulation; rather, it involves FERMI - UNIT 2 B 3.5.1-13 Revision 64 Insert 3 The ECCS injection/spray subsystem flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystems and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The ECCS injection/spray subsystem is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS injection/spray subsystems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS injection/spray subsystem locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

ECCS-Operating B 3.5.1 BASES SURVEILLANCE REQUIREMENTS (continued) verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not

apply to valves that cannot be inadvertently misaligned,

such as check valves. For the HPCI System, this SR also

includes the steam flow path for the turbine and the flow

controller position.

The Surveillance Frequency is controlled under the

Surveillance Frequency Control Program.

This SR is modified by a Note that allows LPCI subsystems to

be considered OPERABLE during alignment and operation for

decay heat removal with reactor steam dome pressure less

than the RHR cut in permissive pressure in MODE 3, and for 4

hours after exceeding the RHR cut-in permissive pressure in

MODE 3, if capable of being manually realigned (remote or

local) to the LPCI mode and not otherwise inoperable. This

allows operation in the RHR shutdown cooling mode during

MODE 3, if necessary and sufficient time to restore the

system line up to the LPCI mode of operation.

SR 3.5.1.5 Verification that ADS primary containment pneumatic supply

pressure is 75 psig ensures adequate air or nitrogen pressure for reliable ADS operation. The accumulator on

each ADS valve provides pneumatic pressure for valve

actuation. The design pneumatic supply pressure

requirements for the accumulator are such that, following a

failure of the pneumatic supply to the accumulator, at least

five valve actuations can occur with the drywell at the long

term drywell pressure of the design basis small break LOCA

analysis (Ref. 15). The ECCS safety analysis assumes only

one actuation to achieve the depressurization required for

operation of the low pressure ECCS. This minimum required

pressure of 75 psig is provided by the primary pneumatic supply system. The Surveillance Frequency is controlled

under the Surveillance Frequency Control Program.

FERMI - UNIT 2 B 3.5.1-14 Revision 64 ECCS-Shutdown B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 ECCS-Shutdown BASES BACKGROUND A description of the Core Spray (CS) System and the low pressure coolant injection (LPCI) mode of the Residual Heat

Removal (RHR) System is provided in the Bases for LCO 3.5.1, "ECCS-Operating."

APPLICABLE The ECCS performance is evaluated for the entire spectrum of SAFETY ANALYSES break sizes for a postulated loss of coolant accident (LOCA). The long term cooling analysis following a design

basis LOCA (Ref. 1) demonstrates that only one low pressure

ECCS injection/spray subsystem is required, post LOCA, to

maintain adequate reactor vessel water level in the event of

an inadvertent vessel draindown. It is reasonable to

assume, based on engineering judgement, that while in MODES

4 and 5, one low pressure ECCS injection/spray subsystem can

maintain adequate reactor vessel water level. To provide

redundancy, a minimum of two low pressure ECCS

injection/spray subsystems are required to be OPERABLE in

MODES 4 and 5.

The low pressure ECCS subsystems satisfy Criterion 3 of

10 CFR 50.36(c)(2)(ii).

LCO Two low pressure ECCS injection/spray subsystems are

required to be OPERABLE. The low pressure ECCS injection/

spray subsystems consist of two CS subsystems and two LPCI

subsystems. Each CS subsystem consists of two motor driven

pumps, piping, and valves to transfer water from the

suppression pool or condensate storage tank (CST) to the

reactor pressure vessel (RPV). Each LPCI subsystem consists

of two motor driven pumps, piping, and valves to transfer

water from the suppression pool to the RPV. In MODES 4

and 5, the RHR System cross tie valves are not required to

be open provided action is taken to assure that OPERABLE

LPCI subsystems are capable of injection to the reactor

vessel. FERMI - UNIT 2 B 3.5.2-1 Revision 0 ECCS-Shutdown B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.5 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides

assurance that the proper flow paths will exist for ECCS

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 that

receives an initiation signal is allowed to be in a

nonaccident position provided the valve will automatically

reposition in the proper stroke time. This SR does not

require any testing or valve manipulation; rather, it

involves verification that those valves capable of

potentially being mispositioned are in the correct position.

This SR does not apply to valves that cannot be

inadvertently misaligned, such as check valves. The

Surveillance Frequency is controlled under the Surveillance

Frequency Control Program.

In MODES 4 and 5, the RHR System may operate in the shutdown

cooling mode to remove decay heat and sensible heat from the

reactor. Therefore, RHR valves that are required for LPCI

subsystem operation may be aligned for decay heat removal.

Therefore, this SR is modified by a Note that allows one or

both LPCI subsystems of the RHR System to be considered

OPERABLE for the ECCS function if all the required valves in

the LPCI flow path can be manually realigned (remote or

local) to allow injection into the RPV, and the system is

not otherwise inoperable. This will ensure adequate core

cooling if an inadvertent RPV draindown should occur. REFERENCES 1.

UFSAR, Section 6.3.2.

FERMI - UNIT 2 B 3.5.2-6 Revision 64 RCIC System B 3.5.3 BASES BACKGROUND (continued)

The RCIC pump is provided with a minimum flow bypass line, which discharges to the suppression pool. The valve in this

line automatically opens to prevent pump damage due to

overheating when other discharge line valves are closed. To

ensure rapid delivery of water to the RPV and to minimize

water hammer effects, the RCIC System discharge piping is

kept full of water. The RCIC System is normally aligned to

the CST. The height of water in the CST is sufficient to

maintain the piping full of water up to the first isolation

valve. The relative height of the feedwater line connection

for RCIC is such that the water in the feedwater lines keeps

the remaining portion of the RCIC discharge line full of

water. Therefore, RCIC does not require a "keep fill"

system. APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safety Feature System and no

credit is taken in the safety analyses for RCIC System

operation. Based on its contribution to the reduction of

overall plant risk, however, the system is included in the

Technical Specifications, as required by 10 CFR

50.36(c)(2)(ii).

LCO The OPERABILITY of the RCIC System provides adequate core

cooling such that actuation of any of the low pressure ECCS

subsystems is not required in the event of RPV isolation

accompanied by a loss of feedwater flow. The RCIC System

has sufficient capacity for maintaining RPV inventory during

an isolation event. APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure

> 150 psig, since RCIC is the primary non-ECCS water source

for core cooling when the reactor is isolated and

pressurized. In MODES 2 and 3 with reactor steam dome

pressure 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS

injection/spray subsystems can provide sufficient flow to

the RPV.

FERMI - UNIT 2 B 3.5.3-2 Revision 0 RCIC System B 3.5.3 BASES SURVEILLANCE SR 3.5.3.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge

line of the RCIC System full of water ensures that the

system will perform properly, injecting its full capacity

into the Reactor Coolant System upon demand. This will also

prevent a water hammer following an initiation signal. One

acceptable method of ensuring the line is full is to vent at

the high points. The Surveillance Frequency is controlled

under the Surveillance Frequency Control Program.

SR 3.5.3.2 Verifying the correct alignment for manual, power operated,

and automatic valves in the RCIC flow path provides

assurance that the proper flow path will exist for RCIC

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 that receives an

initiation signal is allowed to be in a nonaccident position

provided the valve will automatically reposition in the

proper stroke time. This SR does not require any testing or

valve manipulation; rather, it involves verification that

those valves capable of potentially being mispositioned are

in the correct position. This SR does not apply to valves

that cannot be inadvertently misaligned, such as check

valves. For the RCIC System, this SR also includes the

steam flow path for the turbine and the flow controller

position.

The Surveillance Frequency is controlled under the

Surveillance Frequency Control Program.

FERMI - UNIT 2 B 3.5.3-5 Revision 64 Insert 4 The RCIC System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RCIC System and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RCIC System locations susceptible to gas accumulation is based on a self

-assessment of the piping configuration to identify where gases may accumulate and remain even after the system is filled and vented, and to identify vulnerable potential degassing flow paths. The review is supplemented by verification that installed high

-point vents are actually at the system high points, including field verification to ensure pipe shapes and construction tolerances have not inadvertently created additional high points. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RCIC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RCIC Systems are not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RCIC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub

-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

RHR Suppression Pool Cooling B 3.6.2.3 BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break LOCAs. The intent of the analyses is to

demonstrate that the heat removal capacity of the RHR

Suppression Pool Cooling System is adequate to maintain the

primary containment conditions within design limits. The

suppression pool temperature is calculated to remain below

the design limit.

The RHR Suppression Pool Cooling System satisfies

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

LCO During a DBA, a minimum of one RHR suppression pool cooling

subsystem is required to maintain the primary containment

peak pressure and temperature below design limits (Ref. 1).

To ensure that these requirements are met, two RHR

suppression pool cooling subsystems must be OPERABLE with

power from two safety related independent power supplies.

Therefore, in the event of an accident, at least one

subsystem is OPERABLE assuming the worst case single active

failure. An RHR suppression pool cooling subsystem is

OPERABLE when one of the pumps, the heat exchanger, and

associated piping, valves, instrumentation, and controls are

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

heatup and pressurization of primary containment. 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, the RHR Suppression

Pool Cooling System is not required to be OPERABLE in MODE 4

or 5. ACTIONS A.1 With one RHR suppression pool cooling subsystem inoperable,

the inoperable subsystem must be restored to OPERABLE status

within 7 days. In this Condition, the remaining RHR

suppression pool cooling subsystem is adequate to perform

the primary containment cooling function. However, the FERMI - UNIT 2 B 3.6.2.3-2 Revision 59 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 Surveillance Frequency is controlled under the

Surveillance Frequency Control Program.

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate 9,250 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures

that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance

required by ASME Code,Section XI (Ref. 3). This test

confirms one point on the pump design curve, and the results

are indicative of overall performance. Such inservice

inspections confirm component OPERABILITY, trend

performance, and detect incipient failures by indicating

abnormal performance. The Frequency of this SR is in

accordance with the Inservice Testing Program. REFERENCES 1.UFSAR, Section 6.2.2.NEDC-32988-A, Revision 2, Technical Justification to Support Risk- Informed Modification to Selected

Required End States for BWR Plants, December 2002.

3.ASME, Boiler and Pressure Vessel Code,Section XI.FERMI - UNIT 2 B 3.6.2.3-5 Revision 64 Insert 5 SR 3.6.2.3.3 RHR Suppression Pool Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool cooling subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Suppression Pool Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Suppression Pool Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path w hich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR Suppression Pool Spray B 3.6.2.4

BASES APPLICABLE Reference 1 contains the results of analyses used to predict SAFETY ANALYSES primary containment pressure and temperature following large and small break loss of coolant accidents. The intent of

the analyses is to demonstrate that the pressure reduction

capacity of the RHR Suppression Pool Spray System is

adequate to maintain the primary containment conditions

within design limits. The time history for primary

containment pressure is calculated to demonstrate that the

maximum pressure remains below the design limit.

The RHR Suppression Pool Spray System satisfies Criterion 3

of 10 CFR 50.36(c)(2)(ii).

LCO In the event of a DBA, a minimum of one RHR suppression pool

spray subsystem is required to mitigate potential bypass

leakage paths and maintain the primary containment peak

pressure below the design limits (Ref. 1). To ensure that

these requirements are met, two RHR suppression pool spray

subsystems must be OPERABLE with power from two safety

related independent power supplies. Therefore, in the event

of an accident, at least one subsystem is OPERABLE assuming

the worst case single active failure. An RHR suppression

pool spray subsystem is OPERABLE when one of the RHR pumps,

the heat exchanger, and associated piping, valves,

instrumentation, and controls are OPERABLE.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause pressurization of primary containment. 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,

maintaining RHR suppression pool spray subsystems OPERABLE

is not required in MODE 4 or 5.

ACTIONS A.1

With one RHR suppression pool spray subsystem inoperable,

the inoperable subsystem must be restored to OPERABLE status

within 7 days. In this Condition, the remaining OPERABLE

RHR suppression pool spray subsystem is adequate to perform

the primary containment bypass leakage mitigation function.

However, the overall reliability is reduced because a single FERMI - UNIT 2 B 3.6.2.4-2 Revision 0 RHR Suppression Pool Spray B 3.6.2.4 BASES ACTIONS (continued)

that are required to comply with ACTIONS or that are part of

a shutdown of the unit.

The allowed Completion Time is reasonable, based on

operating experience, to reach the required plant conditions

from full power conditions in an orderly manner and without

challenging plant systems.

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS

Verifying the correct alignment for manual, power operated,

and automatic valves in the RHR suppression pool spray mode

flow path provides assurance that the proper flow paths will

exist for system operation. This SR does not apply to

valves that are locked, sealed, or otherwise secured in

position since these valves were verified to be in the

correct position prior to locking, sealing, or securing. A

valve is also allowed to be in the nonaccident position

provided it can be aligned to the accident position within

the time assumed in the accident analysis. This is

acceptable since the RHR suppression pool cooling mode is

manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that

those valves capable of being mispositioned are in the

correct position. This SR does not apply to valves that

cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the

Surveillance Frequency Control Program.

SR 3.6.2.4.2 Verifying each RHR pump develops a flow rate 500 gpm while operating in the suppression pool spray mode with flow

through the heat exchanger ensures that pump performance has

not degraded during the cycle. Flow is a normal test of

centrifugal pump performance required by Section XI of the

ASME Code (Ref. 3). This test confirms one point on the

pump design curve and is indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, FERMI - UNIT 2 B 3.6.2.4-4 Revision 64 Insert 6 SR 3.6.2.4.3 RHR Suppression Pool Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR suppression pool spray subsystems and may also prevent water hammer and pump cavitation.

Selection of RHR Suppression Pool Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Suppression Pool Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Suppression Pool Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Suppression Pool Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR-High Water Level B 3.9.7 BASES LCO (continued) line may be used to allow pumps in one loop to discharge into the opposite loop's recirculation line to make a

complete subsystem.

Additionally, each RHR shutdown cooling subsystem is

considered OPERABLE if it can be manually aligned (remote or

local) in the shutdown cooling mode for removal of decay

heat. Operation (either continuous or intermittent) of one

subsystem can maintain and reduce the reactor coolant

temperature as required. APPLICABILITY One RHR shutdown cooling subsystem must be OPERABLE in MODE 5, with irradiated fuel in the reactor pressure vessel,

with the water level 20 ft 6 inches above the top of the RPV flange, and heat losses to ambient not greater than or

equal to heat input to the reactor coolant to provide decay

heat removal. RHR System requirements in other MODES are

covered by LCOs in Section 3.4, Reactor Coolant System

(RCS); Section 3.5, Emergency Core Cooling Systems (ECCS)

and Reactor Core Isolation Cooling (RCIC) System; and

Section 3.6, Containment Systems. RHR Shutdown Cooling

System requirements in MODE 5 with irradiated fuel in the

reactor pressure vessel and with the water level < 20 ft

6 inches above the RPV flange are given in LCO 3.9.8. ACTIONS A.1 With no RHR shutdown cooling subsystem OPERABLE, the

availability of an alternate method of decay heat removal

must be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In this condition, the

volume of water above the RPV flange provides adequate

capability to remove decay heat from the reactor core.

However, the overall reliability is reduced because loss of

water level could result in reduced decay heat removal

capability. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is based on decay

heat removal function and the probability of a loss of the

available decay heat removal capabilities. Furthermore, FERMI - UNIT 2 B 3.9.7-2 Revision 0 RHR-High Water Level B 3.9.7 BASES SURVEILLANCE SR 3.9.7.1 REQUIREMENTS This Surveillance demonstrates that the RHR shutdown cooling subsystem is capable of decay heat removal.

The verification includes assuring that the shutdown cooling

subsystem is capable of taking suction from the reactor

vessel and discharging back to the reactor vessel through an

RHR heat exchanger with available cooling water. This SR

does not require any testing or valve manipulation, rather,

it involves verification that those valves not locked,

sealed, or otherwise secured in the correct position, can be

aligned to the correct position for shutdown cooling

operation. The Surveillance Frequency is controlled under

the Surveillance Frequency Control Program. REFERENCES None FERMI - UNIT 2 B 3.9.7-4 Revision 64 Insert 7 SR 3.9.7.2 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR shutdown cooling subsystem(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR-Low Water Level B 3.9.8 BASES LCO (continued) opposite loop's recirculation line to make a complete subsystem.

Additionally, each RHR shutdown cooling subsystem is

considered OPERABLE if it can be manually aligned (remote or

local) in the shutdown cooling mode for removal of decay

heat. Operation (either continuous or intermittent) of one

subsystem can maintain and reduce the reactor coolant

temperature as required. However, to ensure adequate core

flow to allow for accurate average reactor coolant

temperature monitoring, nearly continuous operation of

either an RHR pump or a recirculation pump is required.

Note 1 is provided to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exception to shut down

the operating subsystem every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Note 2 is provided to allow a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exception for a single

subsystem inoperability due to surveillance testing. APPLICABILITY Two RHR shutdown cooling subsystems are required to be OPERABLE, and one RHR pump or recirculation pump must be in

operation in MODE 5, with irradiated fuel in the RPV, with

the water level < 20 ft 6 inches above the top of the RPV

flange, and heat losses to ambient not greater than or equal

to heat input to the reactor coolant to provide decay heat

removal. RHR System requirements in other MODES are covered

by LCOs in Section 3.4, Reactor Coolant System (RCS);

Section 3.5, Emergency Core Cooling Systems (ECCS) and

Reactor Core Isolation Cooling (RCIC) System; and

Section 3.6, Containment Systems. RHR Shutdown Cooling

System requirements in MODE 5 with irradiated fuel in the

RPV and with the water level 20 ft 6 inches above the RPV flange are given in LCO 3.9.7, "Residual Heat Removal (RHR-High Water Level."

FERMI - UNIT 2 B 3.9.8-2 Revision 0 RHR-Low Water Level B 3.9.8 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.9.8.2 This Surveillance demonstrates that the RHR shutdown cooling subsystem is capable of decay heat removal. The

verification includes assuring that the shutdown cooling

subsystem is capable of taking suction from the reactor

vessel and discharging back to the reactor vessel through an

RHR heat exchanger with available cooling water. 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.

The Surveillance Frequency is controlled under the

Surveillance Frequency Control Program. REFERENCES None FERMI - UNIT 2 B 3.9.8-5 Revision 64 Insert 8 SR 3.9.8.3 RHR Shutdown Cooling System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR shutdown cooling subsystems and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR Shutdown Cooling System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand

-by versus operating conditions.

The RHR Shutdown Cooling System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR Shutdown Cooling System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR Shutdown Cooling System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub

- set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.