Text

Amergen, Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process
	ML041280522
Person / Time
Site:	Dresden, Peach Bottom, Byron, Braidwood, Clinton, Quad Cities, LaSalle
Issue date:	04/30/2004
From:	Jury K; AmerGen Energy Co, Exelon Generation Co, Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-04-067
	Download: ML041280522 (436)
	v • d • e

{{#Wiki_filter:Amermanim Exelkn. An Exelon Company www.exeloncorp.com Nuclear ArnerGen Energy Company, LLC 4300 Winfield Road Exelon Generation Warrenville, IL 60555 4300 Winfield Road Warrenville, IL 60555 10 CFR 50.90 RS-04-067 April 30, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units I and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units I and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374 Peach Bottom Atomic Power Station, Units 2 and 3 Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) propose changes to Appendix A, Technical Specifications (TS), of the Facility Operating Licenses listed above. The proposed changes would modify TS requirements for mode change limitations in Limiting Condition for Operation 3.0.4 and Surveillance Requirement 3.0.4. The proposed changes are consistent with NRC-approved Technical Specification Task Force > I

April 30, 2004 U. S. Nuclear Regulatory Commission Page 2 (TSTF) Standard Technical Specifications change TSTF-359, Revision 9, which has been endorsed by the NRC as essentially equivalent to TSTF-359, Revision 8, as modified by the notice in the Federal Register published on April 4, 2003. The proposed change is being submitted as a consolidated line item improvement process (CLIIP) amendment. The availability of this TS improvement was published in the Federal Register on April 4, 2003 (i.e., 68FR16579). This request is subdivided as follows.

Attachment 1 provides a description of the proposed changes, including a table of affected TS with a brief description of the changes, the requested confirmation of applicability, and requested verifications.
Attachment 2 provides the marked-up TS pages with the proposed changes indicated.
Attachment 3 provides retyped TS pages with the proposed changes incorporated.
Attachment 4 provides a summary of the regulatory commitments made in this submittal.
Attachment 5 provides the marked-up TS Bases pages with the proposed changes indicated. The TS Bases pages are provided for information only, and do not require NRC approval.
Attachment 6 provides a justification for additional flexibility regarding the opposite unit emergency diesel generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station.

EGC requests approval of the proposed changes by August 30, 2004, with the amendment being implemented within 180 days of issuance. The proposed changes have been reviewed by the Plant Operations Review Committees at each of the stations and approved by the Nuclear Safety Review Boards in accordance with the requirements of the EGC Quality Assurance Program. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the States of Illinois and Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official. If you have any questions or require additional information, please contact Mr. Allan R. Haeger at (630) 657-2807.

April 30, 2004 U. S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of April 2004. Respectfully, ti Keith R. Jury Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC Attachments: Attachment 1: Description and Assessment Attachment 2: Markup of Technical Specification Pages Attachment 3: Retyped Technical Specification Pages Attachment 4: Regulatory Commitments Attachment 5: Markup of Technical Specification Bases Pages Attachment 6: Justification for Additional Flexibility Regarding Opposite Unit Emergency Diesel Generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector- Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector- LaSalle County Station NRC Senior Resident Inspector- Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources

ATTACHMENT I Description and Assessment

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) propose changes to Appendix A, Technical Specifications (TS), for the following operating licenses.

                                                            . , ,' !'Facility Operating

Plant< License Nos.

Braidwood Station, Units 1 and 2 NPF-72 and NPF-77 Byron Station, Units 1 and 2 NPF-37 and NPF-66 Clinton Power Station, Unit 1 NPF-62 Dresden Nuclear Power Station, Units 2 and 3 DPR-19 and DPR-25 LaSalle County Station, Units 1 and 2 NPF-1 I and NPF-1 8 Peach Bottom Atomic Power Station, Units 2 and 3 DPR-44 and DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2 DPR-29 and DPR-30 The proposed changes would modify TS requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4. The proposed changes for each facility are listed in the tables at the end of this attachment. The changes are consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications change TSTF-359, Revision 9 (i.e., Reference 1), which has been endorsed by the NRC as essentially equivalent to TSTF-359, Revision 8, as modified by the notice in the Federal Register published on April 4, 2003 (i.e., Reference 2). That Federal Register notice announced the availability of this TS improvement through the consolidated line item improvement process (CLIIP). 2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation EGC and AmerGen have reviewed the NRC's model safety evaluation dated April 4, 2003, as part of the CLIIP. This review included the NRC's evaluation, as well as the information provided to support TSTF-359 Revision 9. EGC and AmerGen have concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC are applicable to the subject plants and justify the incorporation of the changes to the subject plants' TS. 2.2 Optional Changes and Variations EGC is proposing three differences from the TS changes described in the modified TSTF-359, Revision 9 and the NRC's model safety evaluation dated April 4, 2003. These differences are necessary to reflect plant-specific design or provide needed clarification to the changes Page 1 of 7

ATTACHMENT I Description and Assessment described in TSTF-359. One proposed difference concerns the opposite unit emergency diesel generator at Dresden Nuclear Power Station and Quad Cities Nuclear Power Station. Supporting information for this proposed difference is provided in Attachment 6. A second difference is a proposed addition to the TSTF-359 changes for DNPS, Units 2 and 3. DNPS uses an isolation condenser (IC) system for decay heat removal following reactor pressure vessel isolation, rather than the more standard reactor core isolation cooling (RCIC) system found on Boiling Water Reactor (BWR) 3 and 4 plants. The IC system is not addressed in the improved standard technical specifications for BWR 4 plants, and thus is not addressed in TSTF-359. Following the model established in TSTF-359 for the RCIC system, a note has been inserted into the proposed DNPS changes preventing the use of LCO 3.0.4.b for an inoperable IC system. The IC system is listed in the model safety evaluation published in the Federal Register (Reference 2) as a higher risk system when the plant is entering a new mode. The third difference is a proposed addition to the TSTF-359 changes for all of the facilities listed in the license amendment request. TS Section 1.4, "Frequency," provides examples of the usage of SR 3.0.4. These examples were not modified in TSTF-359 to reflect the potential use of LCO 3.0.4.b to change modes with inoperable equipment resulting from a SR not being met. EGC has added a statement to the introduction section to TS Section 1.4 that states the examples do not reflect the potential application of LCO 3.0.4.b.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination EGC and AmerGen have reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. EGC and AmerGen have concluded that the proposed NSHCD is applicable to the subject plants and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91, "Notice for public comment," paragraph (a). 3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003, for this TS improvement, plant-specific verifications were performed as follows. EGC and AmerGen have established TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before entering an associated mode or other specified condition in the TS Applicability. The modification also includes changes to the bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The bases changes provide guidance for changing modes or other specified conditions in the Applicability when an LCO is not met. The bases changes describe in detail how: LCO 3.0.4.a allows entry into a mode or other specified condition in the Applicability with the LCO not met when the associated Actions to be entered permit continued operation in the mode or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4.b allows entry into a mode or other specified condition in the Page 2 of 7

ATTACHMENT I Description and Assessment Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the mode or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and LCO 3.0.4.c allows entry into a mode or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., Containment Air Temperature, Containment Pressure, Minimum Critical Power Ratio, Moderator Temperature Coefficient), though it may be applied to other Specifications based on NRC plant-specific approval. The bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the mode or other specified condition in the Applicability, and any corresponding risk management actions. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry in to the applicable Conditions and Required Actions for no more than the duration of the applicable Completion Time or until the LCO is met or the unit is not within the Applicability of the TS. The bases also state that SR 3.0.4 does not restrict changing modes or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. Finally, a bases control program consistent with Section 5.5 of the standard technical specifications (STS), and the equivalent of STS SR 3.0.1 and associated bases, will be maintained. 4.0 ENVIRONMENTAL EVALUATION EGC and AmerGen have reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003, as part of the CLIIP. EGC and AmerGen have concluded that the NRC's findings presented in that evaluation are applicable to the subject stations and the evaluation is hereby incorporated by reference for this application. 5.0 IMPACT ON PREVIOUS SUBMITTALS EGC and AmerGen have reviewed the impact of these proposed changes on other license amendment requests currently under review by the NRC. These proposed changes do not affect the technical or regulatory bases for any other license amendment requests currently under review by the NRC. Reference 3 describes a license amendment request for Braidwood Station and Byron Station currently under review that contains TS pages affected by these proposed changes. The proposed changes in Attachments 2A, 2B, 3A, and 3B do not include the changes proposed in Reference 3.

6.0 REFERENCES

1. Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-359, Revision 9, "Increase Flexibility in MODE Restraints" Page 3 of 7

ATTACHMENT I Description and Assessment

2. Federal Register, Volume 68, Number 65, "Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process,"

dated April 4, 2003 3 Letter from K. A. Ainger (Exelon Generation Company, LLC) to U. S. NRC, "Request for Technical Specifications Change, Revision to Technical Specification 3.4.15, 'RCS Leakage Detection Instrumentation,"' dated August 15, 2003 Page 4 of 7

I ATTACHMENT ATTACHMENT I Description and Assessment Proposed TS Changes for Braidwood Station and Byron Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3 Removed note stating that LCO 3.0.4 is not applicable LCO 3.3.4 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.11 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.12 Revised note to state that LCO 3.0.4.b is not applicable when entering MODE 4 LCO 3.4.15 Removed notes (two) stating that LCO 3.0.4 is not applicable LCO 3.4.16 Revised note to state that LCO 3.0.4.c is applicable LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to ECCS high head subsystem LCO 3.6.8 Removed note stating that LCO 3.0.4 is not applicable LCO 3.7.4 Removed note stating that LCO 3.0.4 is not applicable LCO 3.7.5 Inserted note to state that LCO 3.0.4.b is not applicable when entering MODE 1 LCO 3.7.8 Removed note stating that LCO 3.0.4 is not applicable LCO 3.7.9 Removed notes stating that LCO 3.0.4 is not applicable (Byron only) LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to DGs Proposed TS Changes for Clinton Power Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.3.3.2 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.7 Removed notes (two) stating that LCO 3.0.4 is not applicable LCO 3.4.8 Revised note to state that LCO 3.0.4.c is applicable LCO 3.4.9 Removed note stating that LCO 3.0.4 is not applicable LCO 3.5.1 Inserted note to state that LCO 3.0.4.b is not applicable to HPCS LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to RCIC LCO 3.6.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.6.3.2 Removed note stating that LCO 3.0.4 is not applicable LCO 3.6.3.3 Removed note stating that LCO 3.0.4 is not applicable LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to DGs LCO 3.8.11 Removed note stating that LCO 3.0.4 is not applicable Page 5 of 7

ATTACMENT ATTACHMENT I Description and Assessment Proposed TS Changes for Dresden Nuclear Power Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.6 Revised note to state that LCO 3.0.4.c is applicable LCO 3.4.7 Removed note stating that LCO 3.0.4 is not applicable LCO 3.5.1 Inserted note to state that LCO 3.0.4.b is not applicable to HPCI LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to IC LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG Proposed TS Changes for LaSalle County Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.3.3.2 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.7 Removed notes (two) stating that LCO 3.0.4 is not applicable LCO 3.4.8 Revised note to state that LCO 3.0.4.c is applicable LCO 3.4.9 Removed note stating that LCO 3.0.4 is not applicable LCO 3.5.1 Inserted note to state that LCO 3.0.4.b is not applicable to HPCS LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to RCIC LCO 3.6.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to DGs Proposed TS Changes for Peach Bottom Atomic Power Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.3.3.2 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.5 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.6 Revised note to state that LCO 3.0.4.c is applicable LCO 3.4.7 Removed note stating that LCO 3.0.4 is not applicable LCO 3.5.1 Inserted note to state that LCO 3.0.4.b is not applicable to HPCI LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to RCIC LCO 3.6.3.1 Removed note stating that LCO 3.0.4. is not applicable LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to DGs Page 6 of 7

I ATTACHMENT ATTACHMENT 1 Description and Assessment Proposed TS Changes for Quad Cities Nuclear Power Station TS Section Proposed Change 1.4 Added statement that examples do not reflect the potential application of LCO 3.0.4.b. LCO 3.0.4 Revised consistent with TSTF-359 SR 3.0.4 Revised consistent with TSTF-359 LCO 3.3.3.1 Removed note stating that LCO 3.0.4 is not applicable LCO 3.4.5 Removed notes (two) stating that LCO 3.0.4 is not applicable LCO 3.4.6 Revised note to state that LCO 3.0.4.c is applicable LCO 3.4.7 Removed note stating that LCO 3.0.4 is not applicable LCO 3.5.1 Inserted note to state that LCO 3.0.4.b is not applicable to HPCI LCO 3.5.3 Inserted note to state that LCO 3.0.4.b is not applicable to RCIC LCO 3.8.1 Inserted note to state that LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG Page 7 of 7

ATTACHMENT 2A Markup of Technical Specification Pages BRAIDWOOD STATION, UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-2 3.0-6 3.3.3-1 3.3.4-1 3.4.11-1 3.4.12-2 3.4.15-1 3.4.15-2 3.4.16-1 3.5.3-1 3.6.8-1 3.7.4-1 3.7.5-1 3.7.8-2 3.8.1-1

Frequency 1.4 1.4 Frequency DESCRIPTION (continued) The use of "met" or "performed" in these instances conveys specific meaning. A surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria. SR 3.0.4 restrictions would not apply if both the following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. t BRAIDWOOD - UNITS 1 & 2 1.4 - 2 Amendment

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 hen an LCO is not met, entry into a MODE or other specified condition in the Applicability sha not be made except when the ass cated ACTIONS to be ent e.e permit continued opera hn in the MODE or oth r pecified condition in the Appl 'cability for an unlimit period of time. This F Sp cification shall not pr ent changes in MODES or oth ecified conditions in t Applicability that are re ired o comply with ACTIONS that are part of a shutdow of the unit. Exceptions to this pecification are stated in e individual Speci cations. LCO 3.0.4 is o y applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, an_4 LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the required testing to demonstrate OPERABILITY. BRAIDWOOD - UNITS 1 & 2 3.0 - 2 Amendmen i)

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk I impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry i to a MODE or other s e fied condition in the Appli bility of an LCO shal not be made unless the LO's Surv illances have been met ithin their specified Fr uency. This provisio shall not prevent entry to M S or other specifie conditions in the Applica lity at are required to oply with ACTIONS or that re part of a shutdown of the un SR 3.0.4 is only plicable for entry into a ODE or other specified conditpn inthe Applicability i ODES 1, 2, 3, and 4. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. BRAIDWOOD - UNITS 1 & 2 3.0 - 6 Amendment,)

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.3-1. ACTIONS

                        ---          NOTJ ------------------------------------

eparate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in required channels Table 3.3.3-1 for the inoperable. channel. B. As required by B.1 Restore required 30 days Required Action A.1 channel to OPERABLE and referenced in status. Table 3.3.3-1. C. Required Action and C.1 Initiate action in Immediately associated Completion accordance with Time of Condition B Specification 5.6.7. not met. (continued) BRAIDWOOD - UNITS 1 & 2 3.3.3 - 1 Amendment e

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

----                                     NOTi -----------------------------------

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One-or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours BRAIDWOOD - UNITS 1 & 2 . 3.3.4 - 1 Amendmen

                                                                                 /`11

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

   ----------------------------------NOT -

>iSeparate Condition entry is allowed fOr each PORV and each block valve. 2.. O 3.0.4 i/not CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain 1 hour inoperable and capable power to associated of being manually block valve. cycled. B. One PORV inoperable B.1 Close associated 1 hour and not capable of block valve. being manually cycled. AND B.2 Remove power from 1 hour associated block valve. AND B.3 Restore PORV to 72 hours OPERABLE status. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.11 - 1 Amendment

LTOP System 3.4.12 ACTI ONS n- pl-cbra--------------- al---e------------------------ LCOb>054is not applicable~t b fSErtUre reltfcpb CONDITION REQUIRED ACTION COMPLETION TIME A. Two charging pumps A.1 ---------NOTE-------- (centrifugal) capable Two charging pumps of injecting into the may be capable of RCS. injecting into the RCS during pump swap OR operation for

                                    < 15 minutes.

One charging pump (positive displacement) capable Initiate action to Immediately of injecting into the verify a maximum of RCS. one charging pump (centrifugal) is capable of injecting into the RCS. B. One or more SI pumps B.1 Initiate action to Immediately capable of injecting verify no SI pumps into the RCS. are capable of injecting into the RCS. C. An accumulator not C.1 Isolate affected 1 hour isolated when the accumulator. accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.12 - 2 Amnendment tF

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and

b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment / sump monitor LC/ 3*0-4iyA tapplicable. inoperable. / A.1 ---------NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND A.2 Restore required 30 days containment sump monitor to OPERABLE status. (continued) BRAIDWOOD - UNITS 1 & 2 -3.4.15 - I Amendmen

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment N- E-atmosphere LCO .0.4 is2 t applic le. radioactivity monitor /- - inoperable._ _ B.1.1 Analyze grab samples Once per of the containment 24 hours atmosphere. OR B.1.2 ---------NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required monitors D.1 Enter LCO 3.0.3. Immediately inoperable. BRAIDWOOD - UNITS 1 & 2 3.4.15 - 2 Amendmen

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within the following limits:

a. Dose Equivalent I-131 specific activity < 1.0 pCi/gm; and

b. Gross specific activity < 1001/E pCi/gm.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (Tam) Ž 500 0F. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 -NOTE------------ specific activity LCOT iis applicable.

    > 1.0 pCi/gm.

A.1 Verify DOSE Once per 4 hours EQUIVALENT 1-131 specific activity within the acceptable region of Figure 3.4.16-1. AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 specific activity to within limit. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.16 - 1 Arnendmend

ECCS-Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS-Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

A Residual Heat Removal (RHR) train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation. APPLICABILITY: MODE 4. ACTIONSS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS RHR A.1 Initiate action to Immediately subsystem inoperable. restore required ECCS RHR subsystem to OPERABLE status. B. Required ECCS B.1 Restore required ECCS 1 hour centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 5. 24 hours associated Completion Time of Condition B not met. BRAIDWOOD - UNITS 1 & 2 3.5.3 - I Amendment(

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Recombiners LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen A.1 recombiner inoperable. Restore hydrogen 30 days recombiner to OPERABLE status. 4 t B. Two hydrogen B.1 Verify by 1 hour recombiners administrative means inoperable. that the hydrogen AND control function is maintained. Once per 12 hours thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. BRAIDWOOD - UNITS 1 & 2 3.6.8 - I AmendmenIX

SG PORVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Steam Generator (SG) Power Operated Relief Valves (PORVs) LCO 3.7.4 Four SG PORV lines shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SG PORV line A.1 NOTE-inoperable. LCO

0.4 is no ap icable.

Restore SG PORV line 30 days to OPERABLE status. B. Two or more SG PORV B.1 Restore all but one 24 hours lines inoperable. SG PORV line to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours BRAIDWOOD - UNITS 1 & 2 -3.7.4 - I Amendment@

AF System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AF) System LCO 3.7.5 Two AF trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS r'- CONDITION REQUIRED ACTION COMPLETION TIME A. One AF train A.1 Restore AF train to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 12 hours C. Two AF trains C.1 ---------NOTE-------- inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AF train is restored to OPERABLE status. Initiate action to Immediately restore one AF train to OPERABLE status. BRAIDWOOD - UNITS 1 & 2 .3.7.5 - 1 Amendmene

SX System 3.7.8 ACTIONS (continued)* CONDITION REQUIRED ACTION COMPLETION TIME B. Opposite-unit SX train B.1 --NOTE-- - inoperable. l [CO .0.4 is n Y

                                       \ apicble.

Restore opposite-unit 7 days SX train to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS 1,. SURVEILLANCE FREQUENCY SR 3.7.8.1 ------------------- NOTE-------------------- Isolation of SX flow to individual components does not render the SX System inoperable. Verify each unit-specific SX manual, power 31 days operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) BRAIDWOOD - UNITS 1 & 2 3.7.8 - 2 Amendment

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits per bus between the offsite transmission network and the onsite Class lE AC Electrical Power Distribution System; and

b. Two Diesel Generators MDGs) capable of supplying the onsite Class lE AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS _r_-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with A.1 Perform SR 3.8.1.1 1 hour one required qualified for the required circuit inoperable. OPERABLE qualified AND circuits. Once per 8 hours thereafter. AND A.2 Restore required 72 hours qualified circuit(s) to OPERABLE status. AND 17 days from discovery of failure to meet LCO (continued) BRAIDWOOD - UNITS 1 & 2 3.8.1 - 1 Amendment @

BRAIDWOOD LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.3, ECCS - SHUTDOWN)

                                         -NOTE-LCO 3.0.4.b is not applicable to ECCS high head subsystem.

INSERT 4 (LCO 3.7.5, AF SYSTEM)

                                         -NOTE-LCO 3.0.4.b is not applicable when entering MODE 1.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                              -NOTE-LCO 3.0.4.b is not applicable to DGs.

ATTACHMENT 2B Markup of Technical Specification Pages BYRON STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-2 3.0-6 3.3.3-1 3.3.4-1 3.4.11-1 3.4.12-2 3.4.15-1 3.4.15-2 3.4.16-1 3.5.3-1 3.6.8-1 3.7.4-1 3.7.5-1 3.7.8-2 3.7.9-2 3.7.9-3 3.7.9-4 3.8.1-1

Frequency 1.4 1.4 Frequency. DESCRIPTION (continued) The use of "met" or "performed" in these instances conveys specific meaning. A surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria. SR 3.0.4 restrictions would not apply if both the following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met-or, even if required to be met, is not known to be failed. -

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3.K BYRON - UNITS 1 & 2 1.4 - 2 Amendmene

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0. 4 When an LCO is not met, entry into aJiqDE or other specifie condition in the Applicability shal not be made except when the associ ed ACTIONS to be ente d permit continued 1operation/in the MODE or other secified condition in the Applicabjity for an unlimite period of time. This Specifiration shall not prevyt changes in MODES or other specif ed conditions in th Applicability that are required to ciply with ACTIONS or that are part of a shutdown of e uni. Exceptions to this ecification are stated inthe individual Specifi ations. LCO 3.0.4 is o y applicable for entry into a M E or other specified c tion in the Applicability in MO 5 1, 2, 3, Vand 4./ LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the required testing to demonstrate OPERABILITY. BYRON - UNITS 1 & 2 3.0 - 2 Amendment X

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 ntry nto a MODE or other specified condition in the Applicabiliy of an LCO shall n be made unless the LCO's Surveillap es have been met wit n their specified Fre uency This provision shl not prevent entry into' MODS o otere specified co fdtins in the Applicabilit that #e required to compl with ACTIONS or that are trt 3f a shdtdwn of the unit.// SR 3.0.4 is only ap cable for entry into a MOD or other specified condition in the Applicability in MOD 1, 2, 3, and 4. SR 3.0.5 SRs shall apply to each unit individual ly, unless otherwise indicated. BYRON - UNITS 1 & 2 3.0 - 6 AmendmentR

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.3-1. ACTIONS 0.4 is -NOTE------------------------------------ eparate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in required channels Table 3.3.3-1 for the inoperable. channel. B. As required by B.1 Restore required 30 days Required Action A.1 channel to OPERABLE and referenced in status. Table 3.3.3-1. C. Required Action and C.1 Initiate action in Immediately associated Completion accordance with Time of Condition B Specification 5.6.7. not met. (continued) BYRON - UNITS 1 & 2 .3.3.3 - 1 Amendment X

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

1. L I. -- i-.NOTED -----------------------------------

parate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours BYRON - UNITS 1 & 2 -3.3.4 - 1 Amendment(

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

                     -----------       NOT    -      -----------

aeparate Condition entry is allowed fbO each PORV and each block valve. 0.4 isgot appli/abl . CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain 1 hour inoperable and capable power to associated of being manually block valve. cycled. B. One PORV inoperable B.1 Close associated 1 hour and not capable of block valve. being manually cycled. AND B.2 Remove power from 1 hour associated block valve. AND B.3 Restore PORV to 72 hours OPERABLE status. (continued) BYRON - UNITS 1 & 2 -3.4.11 - I Amendmen

LTOP System 3.4.12 ACTIO _ ' C not applicabl o R-OE - LCO(3 is not applicableSote CONDITION REQUIRED ACTION COMPLETION TIME A. Two charging pumps A.1 ---------NOTE-------- (centrifugal) capable Two charging pumps of injecting into the may be capable of RCS. injecting into the RCS during pump swap OR operation for

                                          < 15 minutes.

One charging pump (positive displacement) capable Initiate action to Immediately of injecting into the verify a maximum of RCS. one charging pump (centrifugal) is capable of injecting into the RCS. B. One or more SI pumps B.1 Initiate action to Immediately capable of injecting verify no SI pumps into the RCS. are capable of injecting into the RCS. C. An accumulator not C.1 Isolate affected 1 hour isolated when the accumulator. accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed .in the PTLR. (continued) el-'\ BYRON - UNITS 1 & 2 .3.4.12 - 2 knendmen

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and

b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment NOT --- sump monitor lCV3.O.4 is n$ applic 51e. inoperable. --------- A.1 ---------NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND A.2 Restore required 30 days containment sump monitor to OPERABLE status. (continued) BYRON - UNITS 1 & 2 3.4.15 - 1 Amendment(

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment -- - -E- -A--- atmosphere .0.4 is applicAle. radioactivity monitor ------- ---------- inoperable. B.1.1 Analyze grab samples Once per of the containment 24 hours atmosphere. OR B.1.2 ---------NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required monitors D.1 Enter LCO 3.0.3. Immediately inoperable. BYRON - UNITS 1 & 2 3.4.15 - 2 Amendment X

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within the following limits:

a. Dose Equivalent I-131 specific activity < 1.0 gCi/gm; and

b. Gross specific activity < 100/E pCi/gm.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (T.) 2 500 0F. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 - O NOTE------------ specific activity 3-O-4 is( applicable.

    > 1.0 pCi/gm.

A.1 Verify DOSE Once per 4 hours EQUIVALENT I-131 specific activity within the acceptable region of Figure 3.4.16-1. AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 specific activity to within limit. (continued) BYRON - UNITS 1 & 2 3.4.16 - 1 Amendmen 4@

ECCS-Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS-Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

A Residual Heat Removal (RHR) train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation. APPLICABILITY: MODE 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS RHR A.1 Initiate action to Immediately subsystem inoperable. restore required ECCS RHR subsystem to OPERABLE status. B. Required ECCS B.1 Restore required ECCS 1 hour centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 5. 24 hours associated Completion Time of Condition B not met. BYRON - UNITS 1 & 2 3.5.3 - 1 AmendmenX

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Recombiners LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen A.1 f - NOTE-- recombiner inoperable. LCO .0.4 is no app cbl e J Restore hydrogen 30 days recombiner to OPERABLE status. B. Two hydrogen B.1 Verify by 1 hour recombiners administrative means inoperable. that the hydrogen AND control function is maintained. Once per 12 hours thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. BYRON - UNITS 1 & 2 3.6.8 - 1 Amendment I(

SG PORVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Steam Generator (SG) Power Operated Relief Valves (PORVs) LCO 3.7.4 Four SG PORV lines shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SG PORV line A.1 -- NOTE-inoperable. LCO/3.0.4 is no at ]piable. Restore SG PORV line 30 days to OPERABLE status. B. Two or more SG PORV B.1 Restore all but one 24 hours lines inoperable. SG PORV line to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours BYRON - UNITS 1 & 2 3.7.4 - I Amendmen

AF System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AF) System LCO 3.7.5 Two AF trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS_ CONDITION REQUIRED ACTION COMPLETION TIME A. One AF train A.1 Restore AF train to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 12 hours C. Two AF trains C.1 ---------NOTE-------- inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AF train is restored to OPERABLE status. Initiate action to Immediately restore one AF train to OPERABLE status. BYRON - UNITS 1 & 2 3.7.5 - I Amendment

SX System 3.7.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Opposite-unit SX train B.1 inoperable. LCO .0.4 is no ap icable. Restore opposite-unit 7 days SX train to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 -------------------NOTE-------------------- Isolation of SX flow to individual components does not render the SX System inoperable. Verify each unit-specific SX manual, power 31 days operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) BYRON - UNITS 1 & 2 3.7.8 - 2 Amendment( 5

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One Essential Service ----- ------- Water (SX) makeup pump [CO /0.4 i ,fot appl able. inoperable. - -o ----- ----- C.1 Verify basin level 72 hours for each tower is

                                    > 90%.                AND 2 hours thereafter AND C.2      Verify OPERABILITY of 72 hours associated makeup source.

AND C.3 Restore SX makeup 7 days if both pump to OPERABLE units are in status. MODE 1, 2, 3, or 4 AND 14 days if one unit is in MODE 5, 6 or defueled (continued) BYRON - UNITS 1 & 2 3.7.9 - 2 Amendment 4S

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two SX makeup pumps D.1 Verify basin level 1 hour inoperable. for each tower is 2 90%. AND 2 hours thereafter AND D.2 Verify OPERABILITY of 1 hour at least one makeup source. AND D.3 Verify OPERABILITY of 72 hours second makeup source. E. Rock River water level- ----- Nq E-----

    < 670.6 ft Mean Sea    L   3.0.4 i not appl able.

Level (MSL). X ----- --- E.1 Verify Rock River 1 hour water level is

                                    > 664.7 ft MSL and    AND flow 2 700 cubic feet per second (cfs). 12 hours thereafter (continued)

BYRON - UNITS 1 & 2 3.7.9 - 3 Amendment

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action E not - ------ NOE ---------- mt. LC0 0.4 i not applic le. OR F.1 Verify basin level 1 hour Rock River water level for each tower is forecast to exceed > 90%. AND 702.0 ft MSL by the National Weather 2 hours Service (NWS). thereafter OR AND Tornado Watch issued F.2 Verify OPERABILITY of 1 hour by the NWS that at least one deep includes the Byron well pump. site. AND F.3 Verify OPERABILITY of 72 hours both deep well pumps. G. Required Action and G.1 Be inMODE 3. 6 hours associated Completion Time of Condition A, AND B, C, D, or F not met. G.2 Be inMODE 5. 36 hours OR UHS inoperable for reasons other than Condition A, B, C, D, E, or F. BYRON - UNITS 1 & 2 3.7.9 - 4 Amend ment 16

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits per bus between the offsite transmission network and the onsite Class lE AC Electrical Power Distribution System; and

b. Two Diesel Generators (DGs) capable of supplying the onsite Class lE AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with A.1 Perform SR 3.8.1.1 1 hour one required qualified for the required circuit inoperable. OPERABLE qualified AND circuits. Once per 8 hours thereafter AND A.2 Restore required 72 hours qualified circuit(s) to OPERABLE status. AND 17 days from discovery of failure to meet LCO (continued) BYRON - UNITS 1 & 2 3.8.1 - 1 Amendment

BYRON LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.3, ECCS - SHUTDOWN)

                                         -NOTE-LCO 3.0.4.b is not applicable to ECCS high head subsystem.

INSERT 4 (LCO 3.7.5, AF SYSTEM)

                                         -NOTE-LCO 3.0.4.b is not applicable when entering MODE 1.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                     -NOTE-LCO 3.0.4.b is not applicable to DGs.

ATTACHMENT 2C Markup of Technical Specification Pages CLINTON POWER STATION, UNIT 1 FACILITY OPERATING LICENSE NO. NPF-62 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.0-25 3.0-1 3.0-2 3.0-5 3.3-19 3.3-23 3.4-17 3.4-18 3.4-20 3.4-22 3.5-1 3.5-10 3.6-36 3.6-38 3.6-41 3.8-1 3.8-44

Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability 3 of the LCO (LCO not shown) is MODES-1. 2, and . ----------- EXAMPLE 1. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the-associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the

unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable.

(continued) CLINTON 1.0-25 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. When is not met, e try into a MODE or other -eIf ied 0nLC con~tonin the Applica ility shall not be made' ecept when\ the/associated ACTIONS'X be entered permit contjAued o0eation in the MODE/6 other specified condi fn in the pplicability for aUnlimited period of time, This o rvn

                          <Specification~~~~

shl hne nMDES or other (continued) CLINTON 3.0-1 Amendment No.

LCO Applicability 3.0 0' 3.0 LCO APPLICABILITY LCO 3.0.4 specifed conditions in the App icability that are required (continued) to compl with ACTIONS or that are part of a shutdown of the unit. Excep ons to this Specific ion are stated in the indi idual Specifications. These exceptions allow e try int MODES or other speci ied conditions in the Ap icability when the a sociated ACTIONS to be e ered a ow unit operation inthe MODE or other specif ed ondition in the Appli ability only for a limi d period of time.* // ICO 3.0.4 is only applicable for entry into/a MODE or other specified condition in the Applicability i MODES 1, 2, and LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. 0~

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) CLINTON 3.0-2 Amendment No.$ 0-

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met. the LCO must immediately be declared not met. and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition in the Applicabflity of an LCO shall n t be made unless the .CO's Surveillances have been met wi in their specified Freque y. This provision sh not prevent entry tto MODES r other specified con itions in the Applica ity ii thatkre required to comply ith ACTIONS or that a e j )art of a s tdown of-the unit. S3.0.4 is only applicabl for entry into a HOEor cother Spcified condition in te Applicability in ES 1. 22,and CLINTON 3.0-5 Amendment No

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS yJ Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action to Immediately associated Completion prepare and submit a Time-of Condition A Special Report. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) CLINTON 3.3-19 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES I and 2. ACTIONS CinrsOw 0 ----------------------------------- 2!. fi Cndiionentry is allowed for each Function. arae CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. S. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized. (continued) CLINTON 3.3-23 Amendment No.

RCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system;

                 *b. One channel of either drywell atmospheric particulate monitoring system or drywell atmospheric gaseous monitoring system; and

c. Drywell air cooler condensate flow rate monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain -- -- NOT- ------ sump monitoring system LCO .0.4 iset applicIe. inoperable. b-l------- A.1 Restore drywell floor 30 days drain sump monitoring system to OPERABLE status. B. Required drywell B.1 Analyze grab samples Once per atmospheric monitoring of drywell 24 hours system inoperable. atmosphere. (continued) CLINTON 3.4-17 Amendment ND

RCS Leakage Detection Instrumentation 3.4.7 0e ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Drywell air cooler ------------NOTE------------- condensate flow rate Not applicable when the monitoring system *requireddrywell atmospheric inoperable. monitoring system is inoperable. C.1 Perform SR 3.4.7.1. Once per 8 hours D. Required drywell --- NO ---- atmospheric monitoring LCO .0.4 is t applicable. system inoperable. d--,/ _c AND D.1 Restore required 30 days drywell atmospheric Drywell air cooler monitoring system to condensate flow rate OPERABLE status. monitoring system inoperable. OR D.2 Restore drywell air 30 days cooler condensate flow rate monitoring system to OPERABLE status. E. Required Action and E.1. .Be in MODE 3. 12 hours associated Completion Time of Condition A, AND B, C, or D not met. E.2 Be in MODE 4. 36 hours F. All required leakage F.1 Enter LCO 3.0.3. Immediately detection systems inoperable. CLINTON 3.4-18 Amendment No. )

RCS Specific Activity 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Specific Activity LCO 3.4.8 The DOSE EQUIVALENT 1-131 specific activity of the reactor coolant shall be 5 0.2 pCi/gm. APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant ---NO ----- _ - specific activity LCO is applicable.

     > 0.2 pCi/gm and                             _

S 4.0 pCi/gm DOSE EQUIVALENT 1-131. A.1 Determine DOSE Once per EQUIVALENT I-131. 4 hours AND A.2 Restore DOSE 48 hours EQUIVALENT 1-131 to within limits. B. Required Action and B.1 Determine DOSE Once per associated Completion EQUIVALENT 1-131. 4 hours Time of Condition A

not met. AND OR B.2.1 Isolate all main 12 hours steam lines.

Reactor coolant specific activity. OR

      > 4.0 pCi/gm DOSE EQUIVALENT'I-131.         B.2.2.1 Be in MODE 3.               12 hours AND B.2.2.2 Be in MODE 4.               36 hours CLINTON                                 3.4-20                       Amendment No.

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 0 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall'be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure. ACTIONS

              -----                    NOT4 -----------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. (continued) CLINTON 3.4-22 Amendment No. 011

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of seven safety/ relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig. ACTIONS _ _ __ __ CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status. C)_. B. High Pressure Core B.1 Verify by 1 hour Spray (HPCS) System administrative means inoperable. RCIC System is OPERABLE when RCIC is required to be

 .                                          OPERABLE.

AND B.2 Restore HPCS System 14 days to OPERABLE status. (continued) CLINTON 3,5-1 Amendment No. I

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING 0 (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS i _ _ CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by 1 hour inoperable. administrative means High Pressure Core Spray System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 ' Reduce reactor steam 36 hours dome pressure to

                                      < 150 psig.

CLINTON 3.5-10 Amendment No0

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 0 3.6.3.1 Primary Containment Hydrogen Recombiners LCO 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 ICO )V.O.4-is not recombiner inoperable. ap icable.'

Restore primary 30 days containment hydrogen recombiner to OPERABLE status. B. Two primary B.1 Verify by 1 hour containment hydrogen administrative means recombiners that the hydrogen inoperable. control function is maintained. AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. CLINTON 3.6.-36 Amendment No.

Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 3.6 CONTAINMENT SYSTEMS 0 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters LCO 3.6.3.2 Two divisions of primary containment and drywell hydrogen igniters shall be OPERABLE, each with > 90% of the associated igniter assemblies OPERABLE. APPLICABILITY: MODES I and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One primary A.1- NOTE-containment and LCO .0.4 is t drywell hydrogen ap icable. igniter division -------- - inoperable. Restore primary 30 days containment and drywell hydrogen igniter division to OPERABLE status. B. Two primary B.] Verify by 1 hour containment and administrative means drywell hydrogen that the hydrogen igniter divisions control function is inoperable. maintained. AND B.2 Restore one primary 7 days containment and drywell hydrogen igniter division to OPERABLE status. (continued) CLINTON 3.6-38 Amendment No.

Containment/Drywell Hydrogen Mixing Systems 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Containment/Drywell Hydrogen Mixing Systems LCO 3.6.3.3 Two Containment/Drywell Hydrogen Mixing Systems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Containment/ A.1 - - NOTE - Drywell Hydrogen LCO .0.4 is no/ Mixing System a icable. inoperable. ----- Restore Containment/ 30 days Drywell Hydrogen Mixing System to OPERABLE status. B. Two Containment/ B.1 Verify by 1 hour Drywell Hydrogen administrative means Mixing Systems that the hydrogen inoperable. control function is maintained. AND B.2 Restore one 7 days Containment/Drywall Hydrogen Mixing System to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. CLINTON 3 .6 -4 1 Amendment No$

AC Sources -Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class lE AC Electric Power Distribution System; and

b. Three diesel generators (DGs).

APPLICABILITY: MODES 1, 2, and 3.

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

Division 3 AC electrical power sources are not required to be OPERABLE when High Pressure Core Spray System is inoperable. ACTIONSI O N i S 6 CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.l Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuit. AND Once per 8 hours thereafter AND A.2 Restore offsite 72 hours circuit to OPERABLE status. AND 17 days from discovery of I failure to meet LCO (continued) CLINTON 3 .8 -1 Amendment No.

SVC Protection Systems 3.8.11 3.8 ELECTRICAL POWER SYSTEMS 3.8.11 Static VAR Compensator (SVC) Protection Systems LCO 3.8.11 An SVC Protection System consisting of two redundant protection subsystems shall be OPERABLE for each inservice SVC. APPLICABILITY: During SVC operation ACTIONS

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

Separate Condition entry is allowed for each SVC Protection System. CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem of an ---- NOTE------- SVC Protection System inoperable. LCO 3 4 is not app cable. A.1 Restore SVC 30 days protection subsystem to OPERABLE status. B. Both subsystems of an B.1 Restore one SVC 24 hours SVC Protection System protection subsystem inoperable. to OPERABLE status. C. Required Action and C.1 Open SVC output 1 hour associated Completion breaker(s) to remove Time not met. SVC from service. CLINTON 3. 8-44 Amendment No.

CLINTON LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                         -NOTE-LCO 3.0.4.b is not applicable to HPCS.

INSERT 4 (LCO 3.5.3, RCIC SYSTEM)

                                         -NOTE-LCO 3.0.4.b is not applicable to RCIC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                         -NOTE-LCO 3.0.4.b is not applicable to DGs.

ATTACHMENT 2D Markup of Technical Specification Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-5 3.3.3.1-1 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.8.1-2

Frequency Frequency 1.4 1.4 Frequency DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3 . _ _ _ _ _ _ _ _ _ _ _ _t_ _ _ _ _ _ SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is-stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) Dresden 2 and 3 1.4- 2 Amendment No

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO. the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 3 within 13 hours; and

b. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO orn ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 en an LCO is not met, entry into a MODE or other sp ified conditi n in the Applicabilit) shall not be made exc t when the as ociated ACTIONS to be entered permit continu d opera ion in the MODE or ot er specified conditio in the II Appl cability for an unli ted period of time. his Spe ification shall not revent changes in MD S or other sp cified conditions i the Applicability t t are required to comply with ACTIONS or that are part of a shutdown of the unit. (continued) Dresden 2 and 3 3.0- 1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Exception to this Specificati n are stated in the (continued) individ Specifications. LCO .0.4is only applicab e for entry into a ODE or other sp ift condition in t Applicability in DES 1. 2. ad 3. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11, 'Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations (continued) Dresden 2 and 3 3.0-2 Amendment No.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO sha not be made unless-the LCO's lSurvei 'ances have been met within their specified Frequincy. This provisio ,hall not prevent entry nto MODE} or other specifie cypiditions in the Applic ility tha are required to c oply with Actions or tha are part of la hutdown of the uni SR 3.0.4 isonly plicable for entry nt a MODE or other specified condition in the Applicabilit in MODES 1, 2, and_3._ SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. Dresden 2 and 3 3.0- 5 Amendment No. 6

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

[t C appliSb entry-is-ale owed foreach-Function.

2. Sparte Cndiion entry is allowed for each Function.

CONDITION REOUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) Dresden 2 and 3 3.3.3.1 -1 Amendment N(

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity

                   < 0.2 pCi/gm.

APPLICABILITY: MODE 1. MODES 2 and 3 with any main steam line not isolated. ACTIONS . CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -------------- NOTE----------- specific activity LCO is Z applicable.

      > 0.2 pCi/gm and           ----               ------------
      < 4.0 pCi/gm DOSE EQUIVALENT 1-131.         A.1       Determine DOSE            Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND OR .B.2.1 Isolate all main 12 hours steam lines. Reactor Coolant specific activity OR

     > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) Dresden 2 and 3 3.4.6- 1 Amendment No.

SDC System- Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Shutdown Cooling (SDC) System -Hot Shutdown LCO 3.4.7 Two SDC subsystems shall be OPERABLE, and, with no recirculation pump in operation. at least one SDC subsystem shall be in operation.

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

1. Both required SDC subsystems and recirculation pumps may be not in operation for up to 2 hours per 8 hour period.

2. One required SDC subsystem may be inoperable for up to 2 hours for the performance of Surveillances.

APPLICABILITY: MODE 3. with reactor vessel coolant temperature less than the SDC cut-in permissive temperature. ACTIONS

         -NOTE4                                 -----------------------------------

1. LCOSe 0.4aisot ap ble.

Separate Condition entry is allowed for each SOC subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately SDC subsystems restore required SDC inoperable. subsystem(s) to OPERABLE status. AND (continued) Dresden 2 and 3 3.4.7- 1 Amendment No.6

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND ISOLATION CONDENSER (IC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves I shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure

150 psig.

ACTIONS ___ CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status. (LPCI) pump inoperable. B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status. DR One Core Spray subsystem inoperable. C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status. D. Two LPCI subsystems D.1 Restore one LPCI 72 hours inoperable for reasons subsystem to OPERABLE other than Condition status. C. (continued) Dresden 2 and 3 3.5.1-1 Amendment No. Oe

IC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND ISOLATION CONDENSER (IC) SYSTEM 3.5.3 IC System LCO 3.5.3 The IC System shall be OPERABLE. APPLICABILITY: MODE 1. MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS C) CONDITION REQUIRED ACTION COMPLETION TIME A. IC System inoperable. A.1 Verify by Immediately administrative means High Pressure Coolant Injection System is OPERABLE. AND A.2 Restore IC System to 14 days OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to

                                        < 150 psig.

Dresden 2 and 3 3.5.3 -1 Amendment No.

AC Sources-Operating 3.8.1 ACTIONS

     --                ----------          TE---------------------------

-_LCO /.0.4 is not app icable for the oppoPote unit's AC elec rical po o/ ces.- CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter AND A.2. Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable. redundant required feature(s) AND A.3 Restore required 7 days offsite circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) Dresden 2 and 3 3.8.1-2 Amendment No. 9~

DRESDEN LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                                           -NOTE-LCO 3.0.4.b is not applicable to HPCI.

INSERT 4 (LCO 3.5.3, IC SYSTEM)

                                                           -NOTE-LCO 3.0.4.b ---is------not applicable to IC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                         -NOTE-LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG.

ATTACHMENT 2E Markup of Technical Specification Pages LASALLE COUNTY STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-5 3.3.3.1-1 3.3.3.2-1 3.4.7-1 3.4.7-2 3.4.8-1 3.4.9-1 3.5.1-1 3.5.3-1 3.6.3.1-1 3.8.1-2

Frequency 1.4 1.4 Frequency. DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3.A- t~dL aL J EXAMLE 1.4-1 SURVEILLANCE REQUIREMENTS _ SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although'the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) LaSalle 1 and 2 1.4-2 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other sp ifie conditio in the Applicability/shall not be made ex pt when the as ciated ACTIONS to be ntered permit conti ed oper ion in the MODE or ot er specified condit n in the C9) - Appw cability for an unlighted period of time/ This Specification shall notX revent changes n DSo te (continued) LaSalle 1 and 2 3.0 -1 Amendment No. (

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Speons in the Applicability that are require (continued) to comply with ACTIONS or that re part of a shutdown of the unit , Excep ons to this Specif ation are stated in the ind idual Specificatio . 0 3.0.4 is only ap icable for entry into ODE or other specified conditio in the Applicability i ODES 1, 2, and 3. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain (continued) LaSalle 1 and 2 3.0- 2 Amendment No. (8D

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition i ApplicabV ity of an LCO shall t be made unless th LCO's Survei {ances have been met ythin their specif ie \ Freq yncy.This provision hall not prevent enty into o-~~~~~nr<_ MODS or other specified ~nditions in the Ap lcability th are required to c ply with ACTIONS or at are part of a/shutdown of the ./ SR 3.0.4 is oni applicable for entry nto a MODE or other speifid on4tin in the Applicabi ~fy in MODES 1, 2 SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. LaSalle I and 2 3.0-5 Amendment No.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES I and 2. ACTIONS

1. LCX3.O.4 i- appli le.----NOTES -----------------------------------

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) LaSalle I and 2 3.3.3. 1-1 Amendment No.

Remote Shutdown Monitoring System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown Monitoring System LCO 3.3.3.2 The Remote Shutdown Monitoring System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. LaSalle 1 and 2 .3.3.3.2-1 Amendment No.

RCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump flow monitoring system;

b. One channel of either drywell atmospheric particulate or atmospheric gaseous monitoring system; and

c. Drywell air cooler condensate flow rate monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain sump flow monitoring .li system inoperable.p A.1 Restore drywell floor 30 days drain sump flow monitoring system to OPERABLE status. B. Required drywell B.1 Analyze grab samples Once per atmospheric monitoring of drywell 12 hours system inoperable. atmosphere. (continued) LaSalle 1 and 2 3.4. 7-1 Amendment 4F No. i

RCS Leakage Detection Instrumentation 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Drywell air cooler ------------ NOTE------------- condensate flow rate Not applicable when the monitoring system required drywell atmospheric inoperable. monitoring system is inoperable. C.1 Perform SR 3.4.7.1. Once per 8 hours D. Required drywell ----- NOTE ---- atmospheric monitoring LCO O.4 is no applica e. system inoperable. ----------- AND D.1 Restore required 30 days drywell atmospheric Drywell air cooler monitoring system to condensate flow rate OPERABLE status. monitoring system inoperable. DE D.2 Restore drywell air 30 days cooler condensate flow rate monitoring system to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 12 hours associated Completion Time of Condition A, AND B, C, or D not met. E.2 Be in MODE 4. 36 hours F. All required leakage F.1 Enter LCO 3.0.3. Immediately detection systems inoperable. LaSalle 1 and 2 3.4.7-2 Amendment No.

RCS Specific Activity 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Specific Activity LCO 3.4.8 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity

                  < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant - -- NOTE------------ specific activity LCO iso applicable.

     > 0.2 pCi/gm and
     < 4.0 pCi/gm DOSE EQUIVALENT I-131.         A.1      Determine DOSE           Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity

     > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) LaSalle I and 2 3.4.8-1 Amendment No.4

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be not in operation for up to 2 hours per 8 hour period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor vessel pressure less than the RHR cut-in permissive pressure. ACTIONS L0 0.4-----ot--

1. .04i tappl i9 '1e ---NOT O -----------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable. cooling subsystem to OPERABLE status. AUn u __________________________________________________(continued) LaSalle 1 and 2 3.4.9 -1 Amendment (i No.

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor vessel pressure less than the residual heat removal cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable. APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status. (continued) LaSalle 1 and 2 3.5. 1- 1 Amendment No.3

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTI ONSAe-I- i CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Core Spray System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AU B.2 Reduce reactor steam 36 hours dome pressure to

                                        < 150 psig.

LaSalle 1 and 2 3.5.3-1 Amendment No.4

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners LCO 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 OTE-containment hydrogen LCO 3 .4 is no recombiner inoperable. ap cable. Restore primary 30 days containment hydrogen recombiner to OPERABLE status. B. Two primary B.1 Verify by 1 hour containment hydrogen administrative means recombiners that the hydrogen AND inoperable. control function is maintained. Once per 12 hours thereafter AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status. (continued) LaSalle 1 and 2 .3.6.3.1-1 Amendment Q No.

AC Sources-Operating 3.8.1 ACTIONS CONDITION I REQUIRED ACTION I COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power available inoperable to one division when the redundant concurrent with required feature(s) inoperability are inoperable. of redundant required feature(s) AND A.3 Restore required 72 hours offsite circuit to OPERABLE status. AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued) LaSalle 1 and 2 3.8.1- 2 Amendment No. ~

LASALLE LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                                                                                                        -NOTE-LCO 3.0.4.b is not applicable to HPCS.

INSERT 4 (LCO 3.5.3, RCIC SYSTEM)

                                                                                                                        -NOTE-LCO 3.0.4.b is not applicable to RCIC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                                                                                                        -NOTE-LCO 3.0.4.b             ..........

is not applicable to DGs. ......... ......... ......... .......... ......... ......... .........

ATTACHMENT 2F Markup of Technical Specification Pages PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES (BOTH UNIT 2 AND UNIT 3 PAGES) 1.4-2 3.0-1 3.0-2 3.0-5 3.3-24 3.3-27 3.4-12 3.4-14 3.4-16 3.5-1 3.5-12 3.6-31 3.8-2

Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. . {i - FYAMPIF 1 4-

              -, . ,... W ... .

CO 3-4. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. (continued) PBAPS UNIT 2 1.4-2 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry i to a MODE or other specifie conditio in the Applicability hall not be made except w en the ass iated ACTIONS to be tered permit continued operat' n in the MODE or ot er specified condition in e _4 Appli ability for an unli ted period of time. This Speci ication shall no prevent changes in MODES or ther spe fied conditions n the Applicability that are equired t(mply with ACTIONS, or that are part of a shcown ofnd (continued) PBAPS UNIT 2 3.0 -1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Exceptions to this Specification re stated in the (continued) individual Specifications. Thes exceptions allow entry into MOD or other specified conditions in the Applicayility when the associ ed ACTIONS to be entered allow 4nit operation in the lODE or other specified conditon in the Applicabi ity only for a limited period of tim 0 3.0.4 is only appl cable for entry into a MO or other specified condition in the Applicability in MO 5 1, 2, and 3. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) PBAPS UNIT 2 3.0 -2 Amendment No -(

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 IEn nto a MODE or other spe ified condition in the Applicability of an LCO shall ot be made unless the LCVs Surveil ances have been met :ithin their specified Freque cy. This provision shall not prevent entry i to MODES or other specified onditions in the Applica lity that are required to co ply with ACTIONS or that re part of a s utdown of the unit S 3.0.4 is only ap icable for entry into a ODE or other specified condition in the Applicability in ODES 1, 2, and PBAPS UNIT 2 3.0- 5 Amendment No. (

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS 1/ LCO .0.4_isn applc e.-----NOT0-------------------------------------

4. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) PBAPS UNIT 2 3.3-24 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

1. L- iAI-- ----NOTES ------------

eparate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.3.3.2.1 Verify each required control circuit and 24 months transfer switch is capable of performing the intended function. (continued) PBAPS UNIT 2 3.3- 27 Amendment No.

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell sump monitoring system; and

b. One channel of primary containment atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell sump A.1 Restore drywell sump 24 hours monitoring system monitoring system to inoperable. OPERABLE status. B. Required primary - --- NN1-- -E---- containment LCO/3.0.4 is ot appli g le. atmospheric monitoring - system inoperable. B.1 Analyze grab samples Once per of primary 12 hours containment atmosphere. B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status. (continued) PBAPS UNIT 2 3.4 -12 Amendment No.

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

                  < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant - k -- NOTE------------ specific activity LCO is s0applicable.

     > 0.2 pCi/gm and
     < 4.0 pCi/gm DOSE EQUIVALENT 1-131.         A.1      Determine DOSE           Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT 1-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT 1-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity OR

    > 4.0 pCi/gm DOSE EQUIVALENT 1-131.

(continued) PBAPS UNIT 2 3.4 -14 Amendment No. (;

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure. ACTIONS

NOT 6 -----------------------------------

eparate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status. A( i (continued) PBAPS UNIT 2 3.4-16 Amendment No. X

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) is not required to be OPERABLE with reactor steam dome pressure s 150 psig and ADS valves are not required to be OPERABLE with reactor steam dome pressure

100 psig.

ACTIONS Lo-- ___ CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OPERABLE status. One low pressure coolant injection (LPCI) pump in each subsystem inoperable. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 36 hours (continued) PBAPS UNIT 2 3.5 -1 Amendment No. )

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS _ ____a_ CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to s 150 psig. PBAPS UNIT 2 3.5 -12 Amendment No 2

CAD System 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Containment Atmospheric Dilution (CAD) System LCO 3.6.3.1 Two CAD subsystems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS - CONDITION REQUIRED ACTION COMPLETION TIME A. One or both CAD A.1 -NOTE-subsystems inoperable. { 0.4 is not Cp Z able. 2 Restore CAD 30 days subsystem(s) to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. PBAPS UNIT 2 3.6 -31 Amendment No.

AC Sources-Operating 3.8.1 ACTIONS so' CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuits. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s) AND A.3 Restore offsite 7 days circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) PBAPS UNIT 2 3.8- 2 Amendment No. (

PEACH BOTTOM LCO INSERTS INSERT I (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                                    -NOTE-LCO 3.0.4.b is not applicable to HPCI.

INSERT 4 (LCO 3.5.3, RCIC SYSTEM)

                                                    -NOTE-LCO 3.0.4.b is not applicable to RCIC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                                                                                                 -NOTE-LCO              3.0.4.b is not applicable to DGs.

Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3 1.4 D I EXAMPLE 1.4-1 U i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. (continued) PBAPS UNIT 3 1.4 -2 Amendment No. v

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 Wen an L is not met, entry into a MODE or-other s pifie C nditionn the Applicabil ity,4hall not be made exs pt when\ the assoc aed ACTIONS to be +teredpermit contin fd

               ,operatio   in the MODE or oth fr specified conditig in the Applic~    t forla uni       .ed period of time. Z~is SpeciM cation shall not event changes in MOf or other spec fed conditions i zte Applicability tX tre required to comply with ACTIONS or that are parte a shutdown of (continued)

PBAPS UNIT 3 3.0 -1 Amendment No

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Exceptions to this Specification are stated in the (continued) individual Specifications. T ese exceptions allow entry into MO ES or other specifie conditions in the Applic bility when the ass iated ACTIONS to be ente ed allow/unit operation in t MODE or other specified condtion in the Applica ility only for a limited eriod of tim. I io n h L 3.0.4 is only app icable for entry into a DE or other ecified condition n the Applicability in DES 1, 2, and LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) PBAPS UNIT 3 3.0- 2 Amendment No.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Survefliances have been met w thin their specified Freq ency. This provision all not prevent entry o MOD or other specified c nditions in the App'TEayility th t are required to com y with ACTIONS or that re part of

,7               a shutdown of the unit.

SR 3.0.4 is only app cable for entry into a DE or other specified condition in the Applicability in ODES 1, 2, and 3._ PBAPS UNIT 3 3.0- 5 Amendment No.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

NOT ------------------

1 LCO .0.4 i not appli able. Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days

 -  with two required                 channel to OPERABLE channels inoperable.              status.

(continued) PBAPS UNIT 3 3.3 -24 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

~~~~ '-------7-------NOTE ^--

. LCO     t.0.4 i not appli    ab entry-is-ale. wedforeach-Func
 * . epaate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.3.3.2.1 Verify each required control circuit and 24 months transfer switch is capable of performing the intended function. (continued) PBAPS UNIT 3 3.3 -27 Amendment No.

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell sump monitoring system; and

b. One channel of primary containment atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell sump A.1 Restore drywell sump 24 hours monitoring system monitoring system to inoperable. OPERABLE status. B. Required primary - -/-NOT -- containment LCO 3. 4 is n applic le. atmospheric monitoring - --- -- system inoperable. B.1 Analyze grab samples Once per of primary 12 hours containment atmosphere. AND B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status. (continued) PBAPS UNIT 3 3.4 -12 Amendment No.

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

                   < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -- E qQ --- specific activity LC i ( applicable.

     > 0.2 pCi/gm and

4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT I-131.

QAN A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. ANK OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity OR

    > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) PBAPS UNIT 3 3.4 -14 Amendment No.

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation. NOTES---------------------------

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure. ACTIONS - ---- --- --- --- --- --- --- ------NOTEb ----------------------------------- 1 LC 30 .4 is not app jiqjpbl NOES

2. Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status. AND (continued) PBAPS UNIT 3 3.4-16 Amendment No.

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) is not required to be OPERABLE with reactor steam dome pressure s 150 psig and ADS valves are not required to be OPERABLE with reactor steam dome pressure < 100 psig. ACTIONS _ CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OPERABLE status. OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 36 hours (continued) PBAPS UNIT 3 3.5-1 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System .LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES' 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS Lc CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to s 150 psig. PBAPS UNIT 3 3.5-12 Amendment No.

CAD System 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Containment Atmospheric Dilution (CAD) System LCO 3.6.3.1 Two CAD subsystems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both CAD A.1 NOTE-subsystems inoperable. LCO 3 .4 is not p le. Restore CAD 30 days subsystem(s) to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. PBAPS UNIT 3 3.6-31 Amendment No. 2

AC Sources-Operating 3.8.1 ACTIONS O CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuits. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus required feature(s) concurrent with

                           *are inoperable.          inoperability of redundant required feature(s)

QAN A.3 Restore offsite 7 days circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) PBAPS UNIT 3 3.8-2 Amendment No.

PEACH BOTTOM LCO INSERTS INSERT 1 (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                          -NOTE-LCO 3.0.4.b is not applicable to HPCI.

INSERT 4 (LCO 3.5.3, RCIC SYSTEM)

                                          -NOTE-LCO 3.0.4.b is not applicable to RCIC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                     -NOTE-LCO 3.0.4.b is not applicable to DGs.

ATTACHMENT 2G Markup of Technical Specification Pages QUAD CITIES NUCLEAR POWER STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-5 3.3.3.1-1 3.4.5-1 3.4.5-2 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.8.1-2

Frequency 1.4 1.4 Frequency DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO [LCO not shown) is MODES 1, 2, and 3. EXAMPLE 1.4- t x g,4.b.- SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by.SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) Quad Cities 1 and 2 1.4-2 Amendment No. e

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met. except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required. unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 3 within 13 hours: and

b. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1. 2. and 3. LCO 3.0.4 Wen n 0 i~s not~ et, entry into a MODE_/ other specified co ition in the pplicability shall not e made except when e associated CTIONS to be entered p mit continued operation in e MODE or other specifed condition in the Applicabili for an unlimited pen of time. This Specifica on shall not prevent ch nges in MODES or oth specifie conditions in the Appl" ability that are re uired to comp y with ACTIONS or that re part of a shutdo of the unit. (continued) Quad Cities 1 and 2 3.0-1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 Exc tions to t *s Specification are s ted in the (continued) i ividual Spe fications. LCO 3.0.4 i only applicable for ntry into a MODE or her specified ondition in the App cability in MODES LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11. 'Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations (continued) ': W1 Ouad Cities I and 2 3.0-2 Am'endment No. (1911

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 ntry nto a MO r other specified condi *on in the Applicability o an LCO shall not be map unless the LCOs Surveillance ave been met within th r specified Frequency. This provision shall notprevent entry into MODES o other specified conditi s in the Applicability that re required to comply wh Actions or that are part f a utdown of the unit. SR 3.0.4 is only appli ble for entry into a MODE other specified condition n the Applicability in MOD 1. 2. a~nd 3. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. Quad Cities I and 2 3.0-5 Amendment No. TT

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

       ------                           NOTED ------

1./LCO 3.0.4 is not/ pplicabe Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. hot met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) Quad Cities I and 2 3 .3.3.1 -1 Amendment No X~

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system: and

b. Primary containment atmospheric particulate monitoring system.

APPLICABILITY: MODES 1. 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain sump monitoring.system LCO 3. .4 is not pplicable inoperable. / A.1 Restore drywell floor 30 days drain sump monitoring system to OPERABLE status. (continued) Quad Cities I and 2 3.4.5-1 Amendment No.

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Primary containment ------ NOj? atmospheric L 3.0.4 isXt applicab particulate monitoring ---------- of-; system inoperable. B.1 Analyze grab samples Once per of primary 12 hours containment atmosphere. AND B.2 Restore primary 30 days containment atmospheric particulate monitoring system to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 4. 36 hours D. All required leakage D.1 Enter LCO 3.0.3. Immediately detection systems inoperable. Quad Cities 1 and 2. 3.4.5-2 Amendment No. Z

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

                    < 0.2 vCi/gm.

APPLICABILITY: MODE 1. MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -------------NOTE------------ specific activity LCO 3 is o applicable.

      > 0.2 vCi/gm and           --- - ------- tit
      < 4.0 wCi/gm DOSE                3    .     ,

EQUIVALENT 1-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT 1-131. AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor Coolant specific activi.ty OR

     > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) Quad Cities 1 and 2 3.4.6-1 Amendment No. 6w

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE.

                     -  . --------------------- NOTE---------------------------

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for the performance of Surveillances. APPLICABILITY: MODE 3. with reactor steam dome pressure less than the RHR cut-in permissive pressure. ACTIONS

------------------------------------- NOTEO -----------------------------------

0 3.0.4 i not appliabe Separate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REOUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status. AND (continued) Qua.d Cities 1 and 2 3 .4.7-1 Amendment No(2

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves I shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure s 150 psig. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status. (LPCI) pump inoperable. B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status. OR One Core Spray subsystem inoperable. C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status. (continued) Quad Cities I and 2 3.5.1-1 Amendment No.(2E 9 ~

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1. MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS g:: 5 AI9 __ CONDITION REOUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to

                                         < 150 psig.

Ouad Cities I and 2 3.5.3-1 Amendment No. 8

AC Sources-Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable. redundant required feature(s) AND A.3 Restore required 7 days offsite circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) Quad Cities 1 and 2 3.8.1- 2 Amendment No. 6

QUAD CITIES LCO INSERTS INSERT 1 (LCO 3.0.4) When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 2 (SR 3.0.4) Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. INSERT 3 (LCO 3.5.1, ECCS - OPERATING)

                                                              -NOTE-LCO 3.0.4.b is not applicable to HPCI.

INSERT 4 (LCO 3.5.3, RCIC SYSTEM)

                                                              -NOTE-LCO 3.0.4.b is not ----applicable to RCIC.

INSERT 5 (LCO 3.8.1, AC SOURCES - OPERATING)

                                     - -NOTE-LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG.

ATTACHMENT 3A Retyped Technical Specification Pages BRAIDWOOD STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-2 3.0-6 3.3.3-1 3.3.4-1 3.4.11-1 3.4.12-2 3.4.15-1 3.4.15-2 3.4.16-1 3.5.3-1 3.6.8-1 3.7.4-1 3.7.5-1 3.7.8-2 3.8.1-1

Frequency 1.4 1.4 Frequency DESCRIPTION (continued) The use of "met" or "performed" in these instances conveys specific meaning. A'surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria. SR 3.0.4 restrictions would not apply if both the following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. BRAIDWOOD - UNITS 1 & 2 1.4 - 2 Amendment

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the required testing to demonstrate OPERABILITY. BRAIDWOOD - UNITS 1 & 2 3.0 - 2 Amendment

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4 This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. BRAIDWOOD - UNITS 1 & 2 3.0 - 6 Amendment

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.3-1. ACTIONS

NOTE-------------------------------------I Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in required channels Table 3.3.3-1 for the inoperable. channel.

B. As required by B.1 Restore required 30 days Required Action A.1 channel to OPERABLE and referenced in status. Table 3.3.3-1. C. Required Action and C.1 Initiate action in Immediately associated Completion accordance with Time of Condition B Specification 5.6.7. not met. (continued) BRAIDWOOD - UNITS 1 & 2 3.3.3 - 1 Amendment

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

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

Separate Condition entry is allowed for each Function.

    -     CONDITION                   REQUIRED ACTION           COMPLETION TIME A. One or more required       A.1     Restore required        30 days Functions inoperable.             Function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours BRAIDWOOD - UNITS 1 & 2 3.3.4 - 1 Amendment

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

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

Separate Condition entry is allowed for each PORV and each block valve. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain 1 hour inoperable and capable power to associated of being manually block valve. cycled. B. One PORV inoperable B.1 Close associated 1 hour and not capable of block valve. being manually cycled. AND B.2 Remove power from 1 hour associated block valve. AND B.3 Restore PORV to 72 hours OPERABLE status. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.11 - 1 Amendment

LTOP System 3.4.12 ACTIONS

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

LCO 3.0.4.b is not applicable when entering MODE 4. CONDITION REQUIRED ACTION COMPLETION TIME A. Two charging pumps A.1 ---------NOTE-------- (centrifugal) capable Two charging pumps of injecting into the may be capable of RCS. injecting into the RCS during pump swap OR operation for

                                      < 15 minutes.

One charging pump (positive displacement) capable Initiate action to Immediately of injecting into the verify a maximum of RCS. one charging pump (centrifugal) is capable of injecting into the RCS. B. One or more SI pumps B.1 Initiate action to Immediately capable of injecting verify no SI pumps into the RCS. are capable of injecting into the RCS. C. An accumulator not C.1 Isolate affected 1 hour isolated when the accumulator. accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.12 - 2 Amendment

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and

b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I A. Required containment A.1 ---- NOTE-------- sump monitor Not required to be inoperable. performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND A.2 Restore required 30 days containment sump monitor to OPERABLE status. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.15 - 1 Amendment

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME I B. Required containment B.1.1 Analyze grab samples Once per atmosphere of the containment 24 hours radioactivity monitor atmosphere. inoperable. OR B.1.2 --------- NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required monitors D.1 Enter LCO 3.0.3. Immediately inoperable. BRAIDWOOD - UNITS 1 & 2 3.4.15 - 2 Amendment

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within the following limits:

a. Dose Equivalent I-131 specific activity < 1.0 pCi/gm; and

b. Gross specific activity < 100/E pCi/gm.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (Tam) Ž 500 0F. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 ------------ NOTE------------ specific activity LCO 3.0.4.c is applicable.

    > 1.0 pCi/gm.

A.1 Verify DOSE Once per 4 hours EQUIVALENT 1-131 specific activity within the acceptable region of Figure 3.4.16-1. AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 specific activity to within limit. (continued) BRAIDWOOD - UNITS 1 & 2 3.4.16 - 1 Amendment

ECCS-Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS-Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

A Residual Heat Removal (RHR) train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation. APPLICABILITY: MODE 4. ACTIONS

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

LCO 3.0.4.b is not applicable to ECCS high head subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS RHR A.1 Initiate action to Immediately subsystem inoperable. restore required ECCS RHR subsystem to OPERABLE status. B. Required ECCS B.1 Restore required ECCS 1 hour centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 5. 24 hours associated Completion Time of Condition B not met. BRAIDWOOD - UNITS 1 & 2 3.5.3 - 1 Amendment

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Recombiners LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen A.1 Restore hydrogen 30 days I recombiner inoperable. recombiner to OPERABLE status. B. Two hydrogen B.1 Verify by 1 hour recombiners administrative means inoperable. that the hydrogen AND control function is maintained. Once per 12 hours thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. BRAIDWOOD - UNITS 1 & 2 3.6.8 - 1 Amendment

SG PORVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Steam Generator (SG) Power Operated Relief Valves (PORVs) LCO 3.7.4 Four SG PORV lines shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SG PORV line A.1 Restore SG PORV line 30 days I inoperable. to OPERABLE status. B. Two or more SG PORV B.1 Restore all but one 24 hours lines inoperable. SG PORV line to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours BRAIDWOOD - UNITS 1 & 2 3.7.4 - I Amendment

AF System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AF) System LCO 3.7.5 Two AF trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

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

LCO 3.0.4.b is not applicable when entering MODE 1. CONDITION REQUIRED ACTION COMPLETION TIME A. One AF train A.1 Restore AF train to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 12 hours C. Two AF trains C.1 --------- NOTE-------- inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AF train is restored to OPERABLE status. Initiate action to Immediately restore one AF train to OPERABLE status. BRAIDWOOD - UNITS 1 & 2 3.7.5 - 1 Amendment

SX System 3.7.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Opposite-unit SX train B.1 Restore opposite-unit 7 days I inoperable. SX train to OPERABLE status. C.. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 ------------------- NOTE-------------------- Isolation of SX flow to individual components does not render the SX System inoperable. Verify each unit-specific SX manual, power 31 days operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) BRAIDWOOD - UNITS 1 & 2 3.7.8 - 2 Amendment

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits per bus between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two Diesel Generators (DGs) capable of supplying the onsite Class 1E AC Electrical ower Distri bution System.

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS

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

LCO 3.0.4.b is not applicable to DGs. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with A.1 Perform SR 3.8.1.1 1 hour one required qualified for the required circuit inoperable. OPERABLE qualified AND circuits. Once per 8 hours thereafter AND A.2 Restore required 72 hours qualified circuit(s) to OPERABLE status. AND 17 days from discovery of failure to meet LCO (continued) BRAIDWOOD - UNITS 1 & 2 3.8.1 - 1 Amendment

ATTACHMENT 3B Retyped Technical Specification Pages BYRON STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-2 3.0-6 3.3.3-1

3.3.4-1 3.4.11-1 3.4.12-2 3.4.15-1 3.4.15-2 3.4.16-1 3.5.3-1 3.6.8-1 3.7.4-1 3.7.5-1 3.7.8-2 3.7.9-2 3.7.9-3 3.7.9-4 3.8.1-1

Frequency 1.4 1.4 Frequency DESCRIPTION (continued) The use of "met" or "performed" in these instances conveys specific meaning. A surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria. SR 3.0.4 restrictions would not apply if both the following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. BYRON - UNITS 1 & 2 1.4 - 2 Amendment

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the required testing to demonstrate OPERABILITY. BYRON - UNITS 1 & 2 3.0 - 2 Amendment

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. BYRON - UNITS 1 & 2 3.0 - 6 Amendment

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE. APPLICABILITY: According to Table 3.3.3-1. ACTIONS

NOTE-------------------------------------I Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in required channels Table 3.3.3-1 for the inoperable. channel.

B. As required by B.1 Restore required 30 days Required Action A.1 channel to OPERABLE and referenced in status. Table 3.3.3-1. C. Required Action and C.1 Initiate action in Immediately associated Completion accordance with Time of Condition B Specification 5.6.7. not met. (continued) BYRON - UNITS 1 & 2 3.3.3 - 1 Amendment

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. - ACTIONS

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

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours BYRON - UNITS 1 & 2 3.3.4 - I Amendment

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

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

Separate Condition entry is allowed for each PORV and each block valve. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain 1 hour inoperable and capable power to associated of being manually block valve. cycled. B. One PORV inoperable B.1 Close associated 1 hour and not capable of block valve. being manually cycled. AND B.2 Remove power from 1 hour associated block valve. AND B.3 Restore PORV to 72 hours OPERABLE status. (continued) BYRON - UNITS 1 & 2 3.4.11 - I Amendment

LTOP System 3.4.12 ACTIONS

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

LCO 3.0.4.b is not applicable when entering MODE 4. CONDITION REQUIRED ACTION COMPLETION TIME A. Two charging pumps A.1 ---------NOTE-------- (centrifugal) capable Two charging pumps of injecting into the may be capable of RCS. injecting into the RCS during pump swap OR operation for

                                     < 15 minutes.

One charging pump (positive displacement) capable Initiate action to Immediately of injecting into the verify a maximum of RCS. one charging pump (centrifugal) is capable of injecting into the RCS. B. One or more SI pumps B.1 Initiate action to Immediately capable of injecting verify no SI pumps into the RCS. are capable of injecting into the RCS. C. An accumulator not C.1 Isolate affected 1 hour isolated when the accumulator. accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR. (continued) BYRON - UNITS 1 & 2 3.4.12 - 2 Amendment

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and

b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment A.1 ---------NOTE-------- sump monitor Not required to be inoperable. performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND A.2 Restore required 30 days containment sump monitor to OPERABLE status. (continued) BYRON - UNITS 1 & 2 .3.4.15 - I Amendment

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze grab samples Once per I atmosphere of the containment 24 hours radioactivity monitor atmosphere. inoperable. OR B.1.2 --------- NOTE-------- Not required to be performed until 12 hours after establishment of steady state operation. Perform SR 3.4.13.1. Once per 24 hours AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required monitors D.1 Enter LCO 3.0.3. Immediately inoperable. BYRON - UNITS 1 & 2 3.4.15 - 2 Amendment

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within the following limits:

a. Dose Equivalent I-131 specific activity < 1.0 pCi/gm; and

b. Gross specific activity < 100/E pCi/gm.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (Tag) Ž 500oF. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 ------------ NOTE------------ specific activity LCO 3.0.4.c is applicable. I

    > 1.0 pCi/gm.

A.1 Verify DOSE Once per 4 hours EQUIVALENT I-131 specific activity within the acceptable region of Figure 3.4.16-1. AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 specific activity to within limit. (continued) BYRON - UNITS 1 & 2 3.4.16 - 1 Amendment

ECCS-Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS-Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

A Residual Heat Removal (RHR) train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation. APPLICABILITY: MODE 4. ACTIONS

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

LCO 3.0.4.b is not applicable to ECCS high head subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS RHR A.1 Initiate action to Immediately subsystem inoperable. restore required ECCS RHR subsystem to OPERABLE status. B. Required ECCS B.1 Restore required ECCS 1 hour centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status. C. Required Action and C.1 Be in MODE 5. 24 hours associated Completion Time of Condition B not met. BYRON - UNITS 1 & 2 3.5.3 - 1 Amendment

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Recombiners LCO 3.6.8 Two hydrogen recombiners shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS - CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen A.1 Restore hydrogen 30 days I recombiner inoperable. recombiner to OPERABLE status. B. Two hydrogen B.1 Verify by 1 hour recombiners administrative means inoperable. that the hydrogen AND control function is maintained. Once per 12 hours thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. BYRON - UNITS 1 & 2 3.6.8 - 1 Amendment

SG PORVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Steam Generator (SG) Power Operated Relief Valves (PORVs) LCO 3.7.4 Four SG PORV lines shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS . CONDITION REQUIRED ACTION COMPLETION TIME A. One SG PORV line A.1 Restore SG PORV line 30 days I inoperable. to OPERABLE status. B. Two or more SG PORV B.1 Restore all but one 24 hours lines inoperable. SG PORV line to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 4. 12 hours BYRON - UNITS 1 & 2 3.7.4 - I Amendment

AF System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AF) System LCO 3.7.5 Two AF trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. ACTIONS

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

LCO 3.0.4.b is not applicable when entering MODE 1. CONDITION REQUIRED ACTION COMPLETION TIME A. One AF train A.1 Restore AF train to 72 hours inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 12 hours C. Two AF trains C.1 --------- NOTE-------- inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AF train is restored to OPERABLE status. Initiate action to Immediately restore one AF train to OPERABLE status. BYRON - UNITS 1 & 2 .3.7.5 - 1 Amendment

SX System 3.7.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Opposite-unit SX train B.1 Restore opposite-unit 7 days I inoperable. SX train to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 -------------------NOTE------------------- Isolation of SX flow to individual components does not render the SX System inoperable. Verify each unit-specific SX manual, power 31 days operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position. (continued) BYRON - UNITS 1 & 2 3.7.8 - 2 Amendment

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. One Essential Service C.1 Verify basin level 72 hours I Water (SX) makeup pump for each tower is inoperable. 2 90%. AND 2 hours thereafter AND C.2 Verify OPERABILITY of 72 hours associated makeup source. AND C.3 Restore SX makeup 7 days if both pump to OPERABLE units are in status. MODE 1, 2, 3, or 4 AND 14 days if one unit is in MODE 5, 6 or defueled (continued) BYRON - UNITS 1 & 2 3.7.9 - 2 Amendment

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two SX makeup pumps D.1 Verify basin level 1 hour inoperable. for each tower is

                                 > 90%.                AND 2 hours thereafter AND D.2    Verify OPERABILITY of 1 hour at least one makeup source.

AND D.3 Verify OPERABILITY of 72 hours second makeup source. E. Rock River water level E.1 Verify Rock River 1 hour I

    < 670.6 ft Mean Sea          water level is Level (MSL).                 > 664.7 ft MSL and    AND flow 2 700 cubic feet per second (cfs). 12 hours thereafter (continued)

BYRON - UNITS 1 & 2 3.7.9 - 3 Amendment

UHS 3.7.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action E not F.1 Verify basin level 1 hour I met. for each tower is 2 90%. AND OR 2 hours Rock River water level thereafter forecast to exceed 702.0 ft MSL by the AND National Weather Service (NWS). F.2 Verify OPERABILITY of 1 hour at least one deep OR well pump. Tornado Watch issued AND by the NWS that includes the Byron F.3 Verify OPERABILITY of 72 hours site. both deep well pumps. G. Required Action and G.1 Be in MODE 3. 6 hours associated Completion Time of Condition A, AND B, C, D, or F not met. G.2 Be in MODE 5. 36 hours OR UHS inoperable for reasons other than Condition A, B, C, D, E, or F. BYRON - UNITS 1 & 2 3.7.9 - 4 Am~endment

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits per bus between the offsite transmission network and the onsite Class lE AC Electrical Power Distribution System; and

b. Two Diesel Generators (DGs) capable of supplying the onsite Class 1E AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS

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

LCO 3.0.4.b is not applicable to DGs. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with A.1 Perform SR 3.8.1.1 1 hour one required qualified for the required circuit inoperable. OPERABLE qualified AND circuits. Once per 8 hours thereafter AND A.2 Restore required 72 hours qualified circuit(s) to OPERABLE status. AND 17 days from discovery of failure to meet LCO (continued) BYRON - UNITS 1 & 2 3.8.1 - 1 Amendment

ATTACHMENT 3C Retyped Technical Specification Pages CLINTON POWER STATION, UNIT I FACILITY OPERATING LICENSE NO. NPF-62 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.0-25 3.0-1 3.0-2 3.0-5 3.3-19 3.3-23 3.4-17 3.4-18 3.4-20 3.4-22 3.5-1 3.5-10 3.6-36 3.6-38 3.6-41 3.8-1 3.8-44

Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. I EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. (continued) CLINTON 1.0-25 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

CLINTON 3.0-1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management

                    -actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. I LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) CLINTON 3.0-2 Amendment No.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. I (continued) CLINTON 3. 0-5 Amendment No.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action to Immediately associated Completion prepare and submit a Time of Condition A Special Report. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) CLINTON 3.3 -19 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized. (continued) CLINTON 3 .3-23 Amendment No.

RCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system;

b. One channel of either drywell atmospheric particulate monitoring system or drywell atmospheric gaseous monitoring system; and

c. Drywell air cooler condensate flow rate monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I A. Drywell floor drain A.1 Restore drywell floor sump monitoring system drain sump monitoring 30 days inoperable. system to OPERABLE status. B. Required drywell B.1 Analyze grab samples Once per 24 atmospheric monitoring of drywell hours system inoperable. atmosphere. (continued) CLINTON 3.4 -17 Amendment No.

RCS Leakage Detection Instrumentation 3.4.7 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Drywell air cooler ------------NOTE------------- condensate flow rate Not applicable when the monitoring system required drywell atmospheric inoperable. monitoring system is inoperable. C.1 *Perform SR 3.4.7.1. Once per 8 hours D. Required drywell D.1 Restore required I atmospheric monitoring drywell atmospheric 30 days system inoperable. monitoring system to OPERABLE status. AND OR Drywell air cooler D.2 Restore drywell air 30 days condensate flow rate cooler condensate monitoring system flow rate monitoring inoperable. system to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 12 hours associated Completion Time of Condition A, B, AND C, or D not met. E.2 Be in MODE 4. 36 hours F. All required leakage F.1 Enter LCO 3.0.3. Immediately detection systems inoperable. CLINTON 3 .4-18 Amendment No.

RCS Specific Activity 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Specific Activity LCO 3.4.8 The DOSE EQUIVALENT I-131 specific activity of the reactor coolant shall be 5 0.2 gCi/gm. APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant ------------NOTE------------- specific activity > LCO 3.0.4.c is applicable. I 0.2 pCi/gm and 5 4.0 ----------------------------- pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per EQUIVALENT I-131. 4 hours AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per associated Completion EQUIVALENT I-131. 4 hours Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity > OR 4.0 pCi/gm DOSE EQUIVALENT I-131. B.2.2.1 Be in MODE 3. 12 hours AND B.2.2.2 Be in MODE 4. 36 hours CLINTON 3.4-20 Amendment No.

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation. NOTES--------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2.hours for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR cut in permissive pressure. ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. I ___________________________________________________________________continued

                                                                                        -            (continued)

CLINTON 3 .4 -22 Amendment No.

ECCS -Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of seven safety/ relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES .2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 5 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to HPCS. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status. B. High Pressure Core B.1 Verify by 1 hour Spray (HPCS) System administrative means inoperable. RCIC System is OPERABLE when RCIC is required to be OPERABLE. AND B.2 Restore HPCS System 14 days to OPERABLE status. (continued) CLINTON 3.5-1 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System

. LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by 1 hour inoperable. administrative means High Pressure Core Spray System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to 5 150 psig. CLINTON 3.5-10 Amendment No.

                                     - Primary Containment Hydrogen Recombiners 3.6.3.1 3.6   CONTAINMENT SYSTEMS 3.6.3.1   Primary Containment Hydrogen Recombiners LCO   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 Restore primary 30 days I containment hydrogen containment hydrogen recombiner inoperable. recombiner to OPERABLE status. B. Two primary B.1 Verify by 1 hour containment hydrogen administrative means recombiners that the hydrogen inoperable. control function is maintained. AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status. C. *Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. CLINTON 3.6-36 Amendment No.

Primary Containment and Drywell Hydrogen Igniters 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment and Drywell Hydrogen Igniters LCO 3.6.3.2 Two divisions of primary containment and drywell hydrogen igniters shall be OPERABLE, each with > 90t of the associated igniter assemblies OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One primary A.1 Restore primary 30 days containment and containment and I drywell hydrogen drywell hydrogen igniter division igniter division to inoperable. OPERABLE status. B. Two primary B.1 Verify by 1 hour containment and administrative means drywell hydrogen that the hydrogen igniter divisions control function is inoperable. maintained. AND B.2 Restore one primary 7 days containment and drywell hydrogen igniter division to OPERABLE status. (continued) CLINTON 3. 6-3 8 Amendment No.

Containment/Drywell Hydrogen Mixing Systems 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Containment/Drywell Hydrogen Mixing Systems LCO 3.6.3.3 Two Containment/Drywell Hydrogen Mixing Systems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Containment/ A.1 Restore Containment/ 30 days I Drywell Hydrogen Drywell Hydrogen Mixing System Mixing System to inoperable. OPERABLE status. B. Two Containment/ B.1 Verify by 1 hour Drywell Hydrogen administrative means Mixing Systems that the hydrogen inoperable. control function is maintained. AND B.2 Restore one 7 days Containment/Drywell Hydrogen Mixing System to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time not met. CLINTON 3.6-41 Amendment No.

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electric Power Distribution System; and

b. Three diesel generators (DGs).

APPLICABILITY: MODES 1, 2, and 3.

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

Division 3 AC electrical power sources are not required to be OPERABLE when High Pressure Core Spray System is inoperable. ACTIONS

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

LCO 3.0.4.b is not applicable to DGs. CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuit. AND Once per 8 hours thereafter AND A.2 Restore offsite 72 hours circuit to OPERABLE status. AND 17 days from discovery of failure to meet LCO (continued) CLINTON 3. 8-1 Amendment No.

SVC Protection Systems 3.8.11 3.8 ELECTRICAL POWER SYSTEMS 3.8.11 Static VAR Compensator (SVC) Protection Systems LCO 3.8.11 An SVC Protection System consisting of two redundant protection subsystems shall be OPERABLE for each inservice SVC. APPLICABILITY: During SVC operation ACTIONS

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

Separate Condition entry is allowed for each SVC Protection System. CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem of an A.1 Restore SVC 30 days I SVC Protection System protection subsystem inoperable. to OPERABLE status. B. Both subsystems of an B.1 Restore one SVC 24 hours SVC Protection System protection subsystem inoperable. to OPERABLE status. C. Required Action and C.1 Open SVC output 1 hour associated Completion breaker(s) to remove Time not met. SVC from service. CLINTON 3.8B-44 Amendment No.

ATTACHMENT 3D Retyped Technical Specification Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-3 3.0-5 3.3.3.1-1 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.8.1-2

Frequency 1.4 1.4 Frequency DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) Dresden 2 and 3 1.4-2 Amendment No. /

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 3 within 13 hours; and

b. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of (continued)

Dresden 2 and 3 3.0-1 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 the results, determination of the acceptability of (continued) entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) Dresden 2 and 3 3.0- 2 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications. LCO 3.0.8 LCOs, including associated ACTIONS, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units, the ACTIONS will apply to both units simultaneously. Dresden 2 and 3 3.0 -3 Amendment No. 185/180

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. Dresden 2 and 3 3.0-5 Amendment No. /

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

NOTE------------------------------------ I Separate Condition entry is allowed for each Function. l CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) Dresden 2 and 3 3.3.3. 1- 1 Amendment No. /

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -------------- NOTE----------- specific activity LCO 3.0.4.c is applicable.

     > 0.2 pCi/gm and
     ' 4.0 pCi/gm DOSE EQUIVALENT I-131.         A.1       Determine DOSE          Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT 1-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor Coolant specific activity QR

    > 4.0 pCi/gm DOSE EQUIVALENT 1-131.

(continued) Dresden 2 and 3 3.4.6- 1 Amendment No. /

SDC System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Shutdown Cooling (SDC) System-Hot Shutdown LCO 3.4.7 Two SDC subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one SDC subsystem shall be in operation.

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

1. Both required SDC subsystems and recirculation pumps may be not in operation for up to 2 hours per 8 hour period.

2. One required SDC subsystem may be inoperable for up to 2 hours for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor vessel coolant temperature less than the SDC cut-in permissive temperature. ACTIONS

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

Separate Condition entry is allowed for each SDC subsystem. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately SDC subsystems restore required SDC inoperable. subsystem(s) to OPERABLE status. AND (continued) Dresden 2 and 3 3.4.7-1 Amendment No. /

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND ISOLATION CONDENSER (IC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure

150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status. (LPCI) pump inoperable. B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition A. subsystem to OPERABLE status. OR One Core Spray subsystem inoperable. C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status. D. Two LPCI subsystems D.1 Restore one LPCI 72 hours inoperable for reasons subsystem to OPERABLE other than Condition C. status. (continued) Dresden 2 and 3 3.5. 1-1 Amendment No. /

IC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND ISOLATION CONDENSER (IC) SYSTEM 3.5.3 IC System LCO 3.5.3 The IC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to IC. CONDITION REQUIRED ACTION COMPLETION TIME A. IC System inoperable. A.1 Verify by Immediately administrative means High Pressure Coolant Injection System is OPERABLE. AND A.2 Restore IC System to 14 days OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AO B.2 Reduce reactor steam 36 hours dome pressure to

150 psig.

Dresden 2 and 3 3.5.3- 1 Amendment No. /

AC Sources-Operating 3.8.1 ACTIONS NOTE------------------------------------- LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG. CONDITION IREQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable. redundant required feature(s) AND A.3 Restore required 7 days offsite circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) Dresden 2 and 3 3.8.1- 2 Amendment No. /

ATTACHMENT 3E Retyped Technical Specification Pages LASALLE COUNTY STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-I1 AND NPF-18 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-3 3.0-5 3.3.3.1-1 3.3.3.2-1 3.4.7-1 3.4.7-2 3.4.8-1 3.4.9-1 3.5.1-1 3.5.3-1 3.6.3.1-1 3.8.1-2

Frequency 1.4 1.4 Frequency DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours I Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) LaSalle 1 and 2 1.4-2 Amendment No. /

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

LaSalle 1 and 2 3.0- 1 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and. Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. LaSalle 1 and 2 3.0 -2 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications. LCO 3.0.8 LCOs, including associated ACTIONS, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units, the ACTIONS will apply to both units simultaneously. LaSalle 1 and 2 3.0-3 Amendment No. 147/133

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. LaSalle 1 and 2 3.0-5 Amendment No. /

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS NOTE--------------- Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) LaSalle 1 and 2 .3.3.3.1-1 Amendment No. /

Remote Shutdown Monitoring System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown Monitoring System LCO 3.3.3.2 The Remote Shutdown Monitoring System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. LaSalle 1 and 2 3.3.3.2- 1 Amendment No. /

RCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump flow monitoring system;

b. One channel of either drywell atmospheric particulate or atmospheric gaseous monitoring system; and

c. Drywell air cooler condensate flow rate monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain A.1 Restore drywell floor 30 days I sump flow monitoring drain sump flow system inoperable. monitoring system to OPERABLE status. B. Required drywell B.1 Analyze grab samples Once per atmospheric monitoring of drywell 12 hours system inoperable. atmosphere. (continued) LaSalle 1 and 2 3.4. 7-1 Amendment No. /

RCS Leakage Detection Instrumentation 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Drywell air cooler ------- NOTE------------- condensate flow rate Not applicable when the monitoring system required drywell atmospheric inoperable. monitoring system is inoperable. C.1 Perform SR 3.4.7.1. Once per 8 hours D. Required drywell 0.1 Restore required 30 days I atmospheric monitoring drywell atmospheric system inoperable. monitoring system to OPERABLE status. AND OR Drywell air cooler condensate flow rate D.2 Restore drywell air 30 days monitoring system cooler condensate inoperable. flow rate monitoring system to OPERABLE status. E. Required Action and E.1 Be in MODE 3. 12 hours associated Completion Time of Condition A, AND B, C, or D not met. E.2 Be in MODE 4. 36 hours F. All required leakage F.1 Enter LCO 3.0.3. Immediately detection systems inoperable. LaSalle 1 and 2 3.4.7- 2 Amendment No. /

RCS Specific Activity 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Specific Activity LCO 3.4.8 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity s 0.2 pCi/gm. APPLICABILIT*Y: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I 1 A. Reactor coolant ------------- NOTE------------ specific activity LCO 3.0.4.c is applicable. I

     > 0.2 pCi/gm and

4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits.

4-B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131.

Time of Condition A not met. OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity

     > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) LaSalle 1 and 2 - 3.4.8-1 Amendment No. /

RHR Shutdown Cooling System-Hot Shutdown 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.9 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation. NOTES---------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be not in operation for up to 2 hours per 8 hour period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor vessel pressure less than the RHR cut-in permissive pressure. ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable. cooling subsystem to OPERABLE status. AND (continued) LaSalle 1 and 2 3.4.9-1 Amendment No. /

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

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

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor vessel pressure less than the residual heat removal cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable. APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to HPCS. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status. (continued) LaSalle 1 and 2 3.5. 1-1 Amendment No. /

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Core Spray System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to s 150 psig. LaSalle 1 and 2 3.5. 3-1I Amendment No. /

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners LCO 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 Restore primary 30 days I containment hydrogen containment hydrogen recombiner inoperable. recombiner to OPERABLE status. B. Two primary B.1 Verify by 1 hour containment hydrogen administrative means recombiners that the hydrogen AND inoperable. control function is maintained. Once per 12 hours thereafter AND B.2 Restore one primary 7 days containment hydrogen recombiner to OPERABLE status. (continued) LaSalle 1 and 2 3.6.3. 1-1 Amendment No. /

AC Sources-Operating 3.8.1 ACTIONS

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

LCO 3.0.4.b is not applicable to DGs. CONDITION I REQUIRED ACTION ICOMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power available inoperable to one division when the redundant concurrent with required feature(s) inoperability are inoperable. of redundant required feature(s) AND A.3 Restore required 72 hours offsite circuit to OPERABLE status. AND 17 days from discovery of failure to meet LCO 3.8.1.a or b (continued) LaSalle 1 and 2 3.8.1- 2 Amendment No. /

ATTACHMENT 3F Retyped Technical Specificatiori Pages PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES (BOTH UNIT 2 AND UNIT 3 PAGES) 1.4-2 3.0-1 3.0-2 3.0-5 3.3-24 3.3-27 3.4-12 3.4-14 3.4-16 3.5-1 3.5-12 3.6-31 3.8-2

Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are-satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0. 2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. (continued) PBAPS UNIT 2 1.4- 2 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the-associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of (continued)

PBAPS UNIT 2 3.0-1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 entering the MODE or other specified condition in the (continued) Applicability, and establishment of risk management actions,.if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) PBAPS UNIT 2 3.0-2 Amendment No.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. PBAPS UNIT 2 3.0 -5 Amendment No.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) PBAPS UNIT 2 3.3-24 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.3.3.2.1 Verify each required control circuit and 24 months transfer switch is capable of performing the intended function. (continued) PBAPS UNIT 2 3.3-27 Amendment No.

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell sump monitoring system; and

b. One channel of primary containment atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell sump A.1 Restore drywell sump 24 hours monitoring system monitoring system to inoperable. OPERABLE status. B. Required primary B.1 Analyze grab samples Once per containment of primary 12 hours atmospheric monitoring containment system inoperable. atmosphere. QAN B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status. (continued) .PBAPS UNIT 2 3.4-12 Amendment No.

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity

0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 7--------- NOTE------------ A. Reactor coolant LCO3.0.4.c is applicable. I specific activity

     > 0.2 pCi/gm and

4.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity OR

    > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) PBAPS UNIT 2 3.4-14 Amendment No.

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure. ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status. (continued) PBAPS UNIT 2 .3.4-16 Amendment No.

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) is not required to be OPERABLE with reactor steam dome pressure s 150 psig and ADS valves are not required to be OPERABLE with reactor steam dome pressure s 100 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OPERABLE status. OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 36 hours (continued) PBAPS UNIT 2 3.5 -1 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to

                                       < 150 psig.

PBAPS UNIT 2 .3.5-12 Amendment No.

CAD System 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Containment Atmospheric Dilution (CAD) System LCO 3.6.3.1 Two CAD subsystems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both CAD A.1 Restore CAD 30 days subsystems inoperable. subsystem(s) to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. PBAPS UNIT 2 3.6-31 Amendment No.

AC Sources-Operating 3.8.1 ACTIONS

NOTE-------------------.----------------

LCO 3.0.4.b is not applicable to DGs. CONDITION REQUIRED ACTION l COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuits. AND Once per 8 hours thereafter A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s) A.3 Restore offsite 7 days circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) PBAPS UNIT 2 3.8- 2 Amendment No.

Frequency Frequency 1.4 1.4 Frequency DESCRIPTION criteria. SR 3.0.4 restrictions would not apply if both the (continued) following conditions are satisfied:

a. The Surveillance is not required to be performed; and

b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. (continued) PBAPS UNIT 3 1.4-2 Amendment No.

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the-associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 2 within 7 hours;

b. MODE 3 within 13 hours; and

c. MODE 4 within 37 hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of (continued)

PBAPS UNIT 3 3.0-1 Amendment No.

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 entering the MODE or other specified condition in the (continued) Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) PBAPS UNIT 3 3.0- 2 Amendment No.

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified-conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. PBAPS UNIT 3 3.0-5 Amendment No.

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS NOTE------------------------------------ Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) PBAPS UNIT 3 3.3-24 Amendment No.

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION 'COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS FREQUENCY SR 3.3.3.2.1 Verify each required control circuit and 24 months transfer switch is capable of performing the intended function. (continued) PBAPS UNIT 3 3.3- 27 Amendment No.

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell sump monitoring system; and

b. One channel of primary containment atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell sump A.1 Restore drywell sump 24 hours monitoring system monitoring system to inoperable. OPERABLE status. B. Required primary B.1 Analyze grab samples Once per I containment of primary 12 hours atmospheric monitoring containment system inoperable. atmosphere. QAN B.2 Restore required 30 days primary containment atmospheric monitoring system to OPERABLE status. (continued) PBAPS UNIT 3 3.4-12 Amendment No.

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

                   < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated. ACTIONS - CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant ------------- NOTE------------ specific activity LCO 3.0.4.c is applicable. I

     > 0.2 pCi/gm and
     ' 4.0 pCi/gm DOSE EQUIVALENT I-131.          A.1      Determine DOSE          Once per 4 hours EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours EQUIVALENT 1-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours steam lines. Reactor coolant specific activity OR

     > 4.0 pCi/gm DOSE EQUIVALENT 1-131.

(continued) PBAPS UNIT 3 3.4-14 Amendment No.

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both required RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours per 8 hour period.

2. One required RHR shutdown cooling subsystem may be inoperable for up to 2 hours for performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR shutdown cooling isolation pressure. ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required A.1 Initiate action to Immediately RHR shutdown cooling restore required RHR subsystems inoperable. shutdown cooling subsystem(s) to OPERABLE status. (continued) PBAPS UNIT 3 3.4-16 Amendment No.

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) is not required to be OPERABLE with reactor steam dome pressure < 150 psig and ADS valves are not required to be OPERABLE with reactor steam dome pressure < 100 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OPERABLE status. OR One low pressure coolant injection (LPCI) pump in each subsystem inoperable. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 36 hours (continued) PBAPS UNIT 3 3.'5-1 Amendment No.

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to

150 psig.

PBAPS UNIT 3 3.5 -12 Amendment No.

CAD System 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Containment Atmospheric Dilution (CAD) System LCO 3.6.3.1 Two CAD subsystems shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or both CAD A.1 Restore CAD 30 days I subsystems inoperable, subsystem(s) to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. PBAPS UNIT 3 - 3.6- 31 Amendment No.

AC Sources-Operating 3.8.1 ACTIONS

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

LCO 3.0.4.b is not applicable to DGs. CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuits. AND Once per 8 hours thereafter AND A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one 4 kV when the redundant emergency bus required feature(s) concurrent with are inoperable. inoperability of redundant required feature(s) AND A.3 Restore offsite 7 days circuit to OPERABLE status. AND 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) PBAPS UNIT 3 3.8- 2 Amendment No.

ATTACHMENT 3G Retyped Technical Specification Pages QUAD CITIES NUCLEAR POWER STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS PAGES 1.4-2 3.0-1 3.0-2 3.0-3 3.0-5 3.3.3.1-1 3.4.5-1 3.4.5-2 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.8.1-2

Frequency 1.4 1.4 Frequency DESCRIPTION a. The Surveillance is not required to be performed; and (continued)

b. The Surveillance is not required to be met or, even if

                    -  required to be met, is not known to be failed.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified. In these examples, the Applicability of the LCO (LCO not shown) is MODES 1, 2, and 3. The examples do not reflect the potential application of LCO 3.0.4.b. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR (continued) Quad Cities 1 and 2 1.4- 2 Amendment No. /

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 When an LCO is not-met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour to place the unit, as applicable, in:

a. MODE 3 within 13 hours; and

b. MODE 4 within 37.hours.

Exceptions to this Specification are stated in the individual Specifications. Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, and 3. LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the (continued)

Quad Cities 1 and 2 .3.0-1 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 results, determination of the acceptability of entering the (continued) MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.11, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2. (continued) Quad Cities 1 and 2 3.0 -2 Amendment No. /

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications. LCO 3.0.8 LCOs, including associated ACTIONS, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units, the ACTIONS will apply to both units simultaneously. Quad Cities 1 and 2 3.0 -3 Amendment No. 199/195

SR Applicability 3.0 3.0 SR APPLICABILITY (continued) SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's I Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with Actions or that are part of a shutdown of the unit. I SR 3.0.5 SRs shall apply to each unit individually, unless otherwise indicated. Quad Cities 1 and 2 3.0- 5 Amendment No. /

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACTIONS

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

Separate Condition entry is allowed for each Function. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable, status. B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6. not met. C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status. (continued) Quad Cities 1 and 2 3.3.3. 1-1I Amendment No. /

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system; and

b. Primary containment atmospheric particulate monitoring system.

APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain A.1 Restore drywell floor 30 days I sump monitoring system drain sump monitoring inoperable. system to OPERABLE status. (continued) Quad Cities 1 and 2 3.4.5 -1 Amendment No. /

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Primary containment B.1 Analyze grab samples Once per I atmospheric of primary 12 hours particulate monitoring containment system inoperable. atmosphere. AND B.2 Restore primary 30 days containment atmospheric particulate monitoring system to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 12 hours associated Completion Time of Condition A or AND B not met. C.2 Be in MODE 4. 36 hours D. All required leakage D.1 Enter LCO 3.0.3. Immediately detection systems inoperable. Quad Cities 1 and 2 3.4.5- 2 Amendment No. /

RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not i sol ated. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant ------------- NOTE------------ specific activity LCO 3.0.4.c is applicable. I

     > 0.2 pCi/gm and
     < 4.0 pCi/gm DOSE EQUIVALENT I-131.           A.1      Determine DOSE           Once per 4 hours EQUIVALENT I-131.

A.2 Restore DOSE 48 hours EQUIVALENT I-131 to within limits. B. Required Action and B.1 Determine DOSE Once per 4 hours associated Completion EQUIVALENT I-131. Time of Condition A not met. MAD DR B.2.1 Isolate all main 12 hours steam lines. Reactor Coolant specific activity DR

     > 4.0 pCi/gm DOSE EQUIVALENT I-131.

(continued) Quad Cities 1 and 2 3.4.6 -1 Amendment No. /

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE.

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

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours for the performance of Surveillances. APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR cut-in permissive pressure. ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem. I CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status. AND (continued) Quad Cities 1 and 2 3.4. 7-1 Amendment No. /

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI. CONDITION REQUIRED ACTION COMPLETION TIME A. One Low Pressure A.1 Restore LPCI pump to 30 days Coolant Injection OPERABLE status. (LPCI) pump inoperable. B. One LPCI subsystem B.1 Restore low pressure 7 days inoperable for reasons ECCS injection/spray other than Condition subsystem to OPERABLE A. status. OR One Core Spray subsystem inoperable. C. One LPCI pump in each C.1 Restore one LPCI pump 7 days subsystem inoperable. to OPERABLE status. (continued) Quad Cities 1 and 2 3.5. 1-1 Amendment No. /

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE. APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig. ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC. CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE. AND A.2 Restore RCIC System 14 days to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours dome pressure to

150 psig.

Quad Cities 1 and 2 3.5.3- 1 Amendment No. /

AC Sources-Operating 3.8.1 ACTIONS

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

LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to I the opposite unit DG. CONDITION I REQUIRED ACTION J COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 1 hour circuit inoperable. for OPERABLE required offsite circuit. AND Once per 8 hours thereafter A.2 Declare required 24 hours from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable. redundant required feature(s) A.3 Restore required 7 days offsite circuit to OPERABLE status. 14 days from discovery of failure to meet LCO 3.8.1.a or b (continued) Quad Cities 1 and 2 3.8.1- 2 Amendment No. /

ATTACHMENT 4 Regulatory Commitments The following table identifies those actions committed to by Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. REGULATORY COMMITMENT ;: < DUE DATEIEVENT-EGC and AmerGen will establish the Technical Specification Concurrent with implementation (TS) Bases as adopted with the applicable license of the license amendment amendment.

ATTACHMENT 5A Markup of Technical Specification Bases Pages BRAIDWOOD STATION, UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-6 B 3.0-7 B 3.0-8 B 3.0-17 B 3.0-18 B 3.3.3-12 B 3.3.4-3 B 3.4.11-4 B 3.4.12-11 B 3.4.154 B 3.4.15-5 B 3.4.16-4 B 3.5.3-3 B 3.6.84 B 3.7.44 B 3.7.5-5 B 3.7.8-5 B 3.8.1-6

LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Spent Fuel Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in the spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 L .4 establishes limtations on c nges inMODE or other spe ified conditions in the A cability when an LCO is not ft. It precludes placing t unit in a different MODE o'other specified condition ated in that Appliability (e.g., Applicabilit desired to be entered) whe t following exist: a Unit conditions are suc that the requirements of e LCO would not be met itthe Applicability desired o be entered; and

b. Continued noncom iance with the LCO requir nts, if the ApplicabiV y were entered, would res in the unit uired to exit the Applicab ity desired to be enter to comply with the Requi ed Actions.

                                                                                .1
                                                                               /A BRAIDWOOD - UNITS 1 & 2             B 3.0 - 6                         Revisiono

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) 0 oplance with Required Actions that permit continued opration of the unit for an unlimited period of time ina \ MODE or other Secified condition provides an acceptable\ level of safey fr continued operation. This is Wf hout\ regard to th status of the unit before or after tfeMODE\ change. T refore, in such cases, entry into a DE or other spe fied condition in the Applicability y be made in accor ance with the provisions of the Requited Actions. The pr isions of this Specification should t be inte reted as endorsing the failure to ex cise the good pr tice of restoring systems or componen to OPERABLE sd tus before entering an associated MOD or other specified ndition in the Applicability. The provisions of LCO 3.0.4 shall n prevent changes in MODES or other specified condition in the Applicability that are required to comply with CTIONS. In addition, the provisions of LCO 3.0.4 shall n prevent changes in MODES or other specified conditions the Applicability that result from any unit shutdown Exceptions to LCO 3.0.4 are stated in the individual Specifications. The excep ions allow entry into MODES or other specified condition in the Applicability when the associated ACTIONS to bentered do not provide for continued operation for/an unlimited period of time. Exceptions may apply all the ACTIONS or to a specific Required Action of a specification. LCO 3.0.4 is only pplicable when entering MODE 4 fro MODE 5, MODE 3 from MODE 4, MODE 2 from MODE 3, or E1 from MODE 2. F thermore, LCO 3.0.4 is applicable hen entering any oter specified condition in the Ap icability only while op rating in MODE 1, 2, 3, or 4. Th requirement of LCO 3.0.4 do not apply in MOD 5 and 6, or in other specified conditions of the Applica lity (unless in MODE , 2, 3, or 4) because the ACTIONS f individual Specifications sufficiently define the edial measures to be taken. BRAIDWOOD - UNITS 1 & 2 B 3.0 - 7 Revision

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) urveillances do not have to be performed on othe rb associatd inope _le equipment (Hr on vm t ables outside the speEIL edIT lImtp as permitted by SR )Y.1. Therefore, changn\ MODESr other specified caitions while in an ACT(or Covaiable in icompliance dh LCO 3.0.4 or where an the ection to LCOe.d0.4 stated, is not a vioL C 0 3.0.1 or SR 3tablishe those Surveillances torin not rave to be performed eto the associated inoplya wit eqAipment. HowevereRs must be met to en p ov BILITY pior to declarin /he associated equipmen ZOERABLE (or excepion wt LCO30mits) and restoring compl ce with the LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this LCO is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to Aerform the remuired testing to demonstrate OPERABILITY. Thiis Specification does not provide time to perform any other preventive or corrective maintenance. An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing. BRAIDWOOD - UNITS 1 & 2 B 3.0 - 8 Revision

SR Applicability B 3.0 BASES SR 3.0.4 SR304etbi es te requirement that all applicable S must be met before entry. into a MODE or other specified condition in the Applic ility. This Specification e ures that system and component OPERABILITY require nts and variable limits are met be ore entry into MODES orother specified conditions in the Applicability for hich these systems and components nsure safe operation of the unit. The provisions f this Specification should not b interpreted as endorsing the failure to exercise he good practice of r storing systems or component to 0 RABLE status befor entering an associated MODE or o er specified condition the Applicability. However, n certain circumstances, failing o meet an SR will no result in SR 3.0.4 restricting a ODE change or other ecified condition change. When system, subsystem, train component, device, or variable i inoperable or out de its specified limits, the asso ated SR(s) are not for re ired to be performed, per SR 3.0. , which states that srveillances do not have to be perf med on inoperable quipment. When equipment is inope able, SR 3.0.4 does not It,~ apply to the associated SR(s) sinc the requirement for the SR(s) to be performed is removed./ Therefore, failing to perform the Surveillance(s) with the specified Frequency, on equipment that is inoperable does not result inan SR 3.0.4 restriction to changi MODES or other specified conditions of the Applicabilit. However, since the LCO is not met in this instance, LC 3.0.4 will govern any restrictions that may (or m not) apply to MODE or other specified condition change . The provisions of SR 3.0 shall not prevent changes in MODES or other specifie conditions inthe Applicabili y that are required to c ply with ACTIONS. Inadditi , the provisions of LCO 3.0 4 shall not prevent changes i MODES or other specified c nditions inthe Applicabilit that result from any uni shutdown. The precise requi ements for performance of S are specified such at exceptions to SR 3.0.4 age not necessary. Th specific time frames and coditions necessary for meeting the SRs are specifi inthe Frequency, the Surveillance, or both. This allows performanc of Surveillances when the erequisite ' condition s) specified ina Surveill ce procedure require entry into the MODE or other specifed condition inthe BRAIDWOOD - UNITS 1 & 2 .B 3.0 - 17 Revision

SR Applicability B 3.0 BASES SR 3.0.4 (cont, .nsind) Applicability f the associated LCO prior to the performance or completlo of a Surveillance. A Surv llance that could not be perf rmed until after entering tie LCO Applicability, would hay its Frequency specified su that it is not "due" until th s ecific conditions needed/re met. Alternately, the Sur eil ance may be stated in e form of a Note as not requied (to be met or Eerforred) ntil a articular event, con tion, or time has een rea ed. Furter discussion of t specific formats of SRs' anotation is found in ction 1.4, Frequency. SR 3.0.4 isonly applicabl when entering MODE 4 from MODE 5, MODE 3 from MODE , MODE 2 from MODE 3, or MO 1 from MODE 2. Furthermor , SR 3.0.4 is applicable w n entering any other spe fied condition in the App cability only while operating MODE 1, 2, 3, or 4. The requirements of SR .0.4 do not apply in MODES and 6, or in other specified conditions of the Applicab ity (unless in MODE 1, 2, 3, r 4) because the ACTIONS individual Specifications ufficiently define the re dial measures to be taken. SR 3.0.5 SR 3.0.5 establishes the applicability of each Surveillance to both Unit 1 and Unit 2 operation. Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the SR.

                                                                             -- I BRAIDWOOD - UNITS 1 & 2            B 3.0 - 18                       Revision X

PAM Instrumentation B 3.3.3 BASES ACTIONS Note 1 has b en added in the ACTYONS to exclude the MODE change restriction of LCO .0.4. This exception al ows entry int the applicable MOD while relying on the ACT ONS even tho h the ACTIONS may entually require unit shutdo . This exception acceptable due to the ssive functi n of the instrument, the operator's abilit to resod to an accident uigatrnate instrumen iand met is, and the low pr bability of an event re iring these Note has been added in the ACTIONS to clarify the

            @,'0appliation of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to all PAM Functions. Conditipn A addresses the situation where one or more Functions with one or more required channels are inoperable. The Required Action is to refer to Table 3.3.3-1 and to take the Required Actions for the Functions affected. The Completion Times are those from the reference Conditions and Required Actions. B.1 If Condition B is required to be entered by Table 3.3.3-1, the inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval. BRAIDWOOD - UNITS 1 & 2 B 3.3.3 - 12 Revisior@

System Remote Shutdown Remote Shutdown System B 3.3.4 BASES ACTIONS Note 1 i cluded which excludes te MODE change Irestrictio ~of LCO 3.0.4. This exception allows entry int an applic bee MODE whiletorelyinyn the ACTIONS even the the ACTI NS may eventuall req r2 a unit shutdown. Th'i except'on is acceptable due tithe low probability of0 evn/equiring the Remote Sgutdown System-and becaus the eqimnt can generally be/fepaired during operat' wihout Note Q has been added to the ACTIONS to clarify the U ,)1}application of Completion Time rules. Separate Condition entry is allowed for each Function listed on Table 3.3.4-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function. A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System listed in Table 3.3.4-1 are inoperable. The Required Action is to restore the required Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. BRAIDWOOD - UNITS 1 & 2 B 3.3.4 - 3 RevisionV)

Pressurizer PORVs B 3.4.11 BASES APPLICABILITY (continued) Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not applicable in MODE 4, 5, or 6, when both pressure and core energy are decreased and the pressure surges become much less significant. LCO 3.4.12 addresses the PORV requirements in MODES 4 and 5, and in MODE 6 with the reactor vessel head in place. ACTIONS NNo has tebeen added to clarify that all L9)Jpressurizer PORPs and block valves are treated as separate entities, each with separate Completion Times (i.e., the Coipletion Time is on a component I 1is)._J;ne exception or 0 3.0.4 Note , permits entry into VIGDES 1, 2, and 3 o perform cling of the PORVs or IVWock valves to verify heir OPERAB status. Testing is nPrL performed in lower DES. A.1 PORVs may be inoperable and capable of being manually cycled (e.g., excessive seat leakage). In this condition, either the PORVs must be restored or the flow path isolated within 1 hour. The associated block valve is required to be closed but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. This permits operation of the unit until the next refueling outage (MODE 6) so that maintenance can be performed on the PORVs to eliminate the problem condition. Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The Completion Time of 1 hour is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period. BRAIDWOOD - UNITS 1 & 2 B 3.4.11 - 4 Revisio o

LTOP System B 3.4.12 BASES ACTIONS The Actions are modified by a Vote that indicates that provision of LCO 3.0.4 are t applicable to the RCS pressure relief capabilitie g(PORVs and RHR suction rel valves r vent of 2 2.0 sq re inches-with the RCS depre 'surized). As a re it, MODE changes are allow1 d

            )    one   r more of these  caabilities are inoperable, al wance is provided ecause the Required Actio have d termined to provide an acceptable level of s ety.

his A.1 and B.1 With two centrifugal charging pumps capable of injecting into the RCS, or one positive displacement charging pump capable of injecting into the RCS, or any SI pump capable of injecting into the RCS, RCS overpressurization is possible. The requirement to immediately initiate action (except during charging pump swap operation) to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition. Required Action A.1 is modified by a Note that permits two charging pumps capable of RCS injection for < 15 minutes to allow for pump swaps. C.1 and D.1 An unisolated accumulator requires isolation within 1 hour. This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by the P/T limit curves. If the Required Action and associated Completion Time of Condition C are not met, Required Action D.1 must be performed in the next 12 hours. Depressurizing the accumulators below the LTOP limit from the PTLR prevents an accumulator pressure from exceeding the LTOP limits if the accumulators are fully injected. The Completion Times are based on operating experience that these activities can be accomplished in these time periods and on engineering evaluations indicating that an event requiring LTOP is not likely in the allowed times. BRAIDWOOD - UNITS 1 & 2 B 3.4.12 - 11 Revi si on

Instrumentation RCS Leakage Detection RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE. In MODE 5 or 6, the temperature is to be < 2000 F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6. ACTIONS A.1 and A.2 With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours to rovide information that is adequate to detect leakage. A ote is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours after establishing steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and G seal injection and return flows). The 12 hour allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1. Require Action A.1 and Req qred Action A.2 are modifed by a Note hat indicates that he provisions of LCO 3. .4 are not a licable. As a res t, a MODE-change is all ed when the 9ntainment sump mo 'tor is inoperable. Thi allowance is povided because o r instrumentation is a ilable to monitor RCS leakage.v__-- BRAIDWOOD - UNITS 1 & 2 B 3.4.15 - 4 Revisit

RCS Leakage Detection Instrumentation B 3.4.15 BASES I ACTIONS (continued) B.1.1. B.1.2. and B.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed for gaseous and particulate radioactivity or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information. With a sample obtained and analyzed or water inventory balance performed every 24 hours, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. The 24 hour interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours after establishing steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leakage detection is available. Require Action B.1 and Requir d Action B.2 are modifi by a Note hat indicates that t provisions of LCO 3.0. /tare not a licable. As a resul , a MODE change is allow;d when the seous and particulat containment atmosphere radi activity channel is operable. This allow ce is pro ided because other strumentation is avail le to m itor RCS leakage. BRAIDWOOD - UNITS 1 & 2 B 3.4.15 - 5 Revi si i

RCS Specific Activity B 3.4.16 BASES APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS average temperature

                 > 500 0F, operation within the LCO limits for DOSE EQUIVALENT I-131 and gross specific activity are necessary to contain the potential consequences of an SGTR to within the acceptable site boundary dose values.

For operation in MODE 3 with RCS average temperature

                 < 500 0F, and in MODES 4 and 5, the release of radioactivity in the event of a SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the main steam safety valves.

ACTIONS A.1 and A.2 With the DOSE EQUIVALENT I-131 specific activity greater than the LCO limit, samples at intervals of 4 hours must be taken to demonstrate that the limits of Figure 3.4.16-1 are not exceeded. The Completion Time of 4 hours provides sufficient time to obtain and analyze a sample. Sampling is done to continue to provide a trend. The DOSE EQUIVALENT I-131 specific activity must be restored to within limits within 48 hours. The Completion Time of 48 hours is required, if the limit violation resulted from normal iodine spiking. A Note to the Required Actiony excludes the MODE cP nge restr ction of LCO 3.0.4. 1Ts exception allows ntry inti the pplicable MODE(S) whil relying on the ACTIONS even th Zgh the ACTIONS may ev tually require unit h on itab] te sign icant conservatism inea it te ec acivity limit the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the unit remains at, or proceeds to power operation. BRAIDWOOD - UNITS 1 & 2 B 3.4.16 - 4 Reiso

ECCS-Shutdown B 3.5.3 BASES ACTIONS A.1 With no ECCS RHR subsystem OPERABLE, the unit is not prepared to respond to a loss of coolant accident or to continue a cooldown using the RHR pumps and heat exchangers. The Completion Time of immediately to initiate actions that would restore at least one ECCS RHR subsystem to OPERABLE status ensures that prompt action is taken to restore the required cooling capacity. Normally, in MODE 4, reactor decay heat is removed from the RCS by an RHR loop. If no RHR loop is OPERABLE for this function, reactor decay heat must be removed by some alternate method, such as use of the steam generators. The alternate means of heat removal must continue until the inoperable RHR loop components can be restored to operation so that decay heat removal is continuous. With both RHR pumps and heat exchangers inoperable, it would be unwise to require the unit to go to MODE 5, where the only available heat removal system is the RHR. Therefore, the appropriate action is to initiate measures to restore one ECCS NHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status. B.1 With no ECCS centrifugal charging subsystem OPERABLE, due to the inoperability of the centrifugal charging pump or flow path from the RWST, the unit is not prepared to provide high pressure response to Design Basis Events requiring SI. The 1 hour Completion Time to restore at least one centrifugal charging subsystem to OPERABLE status ensures that prompt action is taken to provide the required cooling capacity or to initiate actions to place the unit in MODE 5, where an ECCS train is not required. C.1 When the Required Actions of Condition B cannot be completed within the required Completion Time, a controlled shutdown should be initiated. Twenty-four hours is a reasonable time, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems or operators. BRAIDWOOD - UNITS 1 & 2 ~B 3.5.3 - 3 Revision

Hydrogen Recombiners B 3.6.8 BASES ACTIONS A.1 With one containment hydrogen recombiner inoperable, the inoperable recombiner must be restored to OPERABLE status within 30 days. In this condition, the remaining OPERABLE hydrogen recombiner is adequate to perform the hydrogen control function. However, the overall reliability is reduced because a single failure in the OPERABLE recombiner could result in reduced hydrogen control capability. The 30 day Completion Time is based on the availability of the other hydrogen recombiner, the small probability of a LOCA or SLB occurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit. Rquired Action A.1 has been modified by a Note that states the provis . ns of LCO 3.0.4 are not~/fipplicable. As a\ result aMDE change is allowedwhen one recombiner is / \ inoperab e. This allowance is) h viaiiy~ 1Ksdo the ot er hydrogen recombiner th small probability of/l LOCA r SLB occurring (that ould generate an amount o hydr gen that exceeds the lammability limit), and th am nt of time availabl after a LOCA or SLB (shoul one occur) for operator ac ion to prevent hydrogen acc ulation from exceeding the flamrmability limit. BRAIDWOOD - UNITS 1 & 2 B 3.6.8 - 4 Revisio

SG PORVs B 3.7.4 BASES LCO (continued) A SG PORV is considered OPERABLE when it is capable of providing controlled relief of the main steam flow and capable of fully opening and closing on demand. APPLICABILITY In MODES 1, 2, and 3, the SG PORVs are required to be OPERABLE. In MODE 4, the pressure and temperature limitations are such that the probability of an SGTR event requiring SG PORV operation is low. In addition, the RHR system is available to provide the decay heat removal function in MODE 4. Therefore, the SG PORV lines are not required OPERABLE in MODE 4. In MODE 5 or 6, an SGTR is not a credible event. ACTIONS A.1 With one SG PORV line inoperable, action must be taken to restore OPERABLE status within 30 days. The 30 day Completion Time allows for the redundant capability afforded by the remaining OPERABLE SG PORV lines, a nonsafety grade bakni the Steam Dump System, and M

                         .1 i mritea Dy a Note/sndicatingthtL

{?i57on 0. B.1 With two or more SG PORV lines inoperable, action must be taken to restore all but one SG P0RV line to OPERABLE status. Since the block valve can be closed to isolate a SG PORV, some repairs may be possible with the unit at power. The 24 hour Completion Time is reasonable to repair inoperable SG PORV lines, based on the availability of the Steam Dump System and MSSVs, and the low probability of an event occurring during this period that would require the SG PORV lines. BRAIDWOOD - UNITS 1 & 2 B 3.7.4 - 4 Revisio

AF System B 3.7.5 BASES ACTIONS A.1 With one of the required AF trains (pump or flow path) inoperable, action must be taken to restore OPERABLE status within 72 hours. The 72 hour Completion Time is reasonable, on redundant capabilities afforded by the AF System, timeeede-forbased time nerded for repairs, and the low probability of a DBA occurring during this time period. B.1 and B.2 When Required Action A.1 cannot be completed within the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. C.1 If both AF trains are inoperable, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AF train to OPERABLE status. Required Action C.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AF train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition. In addition, the Completion Times of Required Actions which are suspended are also suspended. BRAIDWOOD - UNITS 1 & 2 B 3.7.5 - 5 Rei i

SX System B 3.7.8 BASES ACTIONS (continued) B.1 If the opposite-unit SX train is not OPERABLE for unit-specific support, action must be taken to restore OPERABLE status within 7 days. In this Condition, if a complete loss of unit-specific SX were to occur, the SX System function would be lost. The 7 day Completion Time is based on the capabilities of the unit-specific SX System and the low probability of a DBA with a loss of all unit-specific SX occurring during this time period Required Action B.1 is modif' d by a Note that st es LCO 3.0. is not applicable> This exception to 0 3.0.4 is based the redundancy o the unit-specific trans and the desi basis analysis t es no credit for the pposite-unit C.1 and C.2 If the unit-specific SX train or the opposite-unit SX train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

                                                                             /'Y BRAIDWOOD - UNITS 1 & 2            B 3.7.8 - 5                       Revisi 0w

AC Sources-Operating B 3.8.1 BASES ACTI ONS A.1 To ensure a highly reliable power source remains with one required qualified circuit inoperable, it is necessary to

 , *~cr{    7    verify the OPERABILITY of the remaining required qualified circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

However, if another required circuit fails SR 3.8.1.1, this qualified circuit is inoperable, and additional Conditions and Required Actions may be appropriate. If the additional inoperability results in a bus with two required qualified circuits inoperable Condition C is entered. If the additional inoperability results in the second bus with one required qualified circuit inoperable Condition A is still applicable. A.2 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours. With one or more buses with one required qualified circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this Condition, however, the remaining OPERABLE required qualified circuits and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. BRAIDWOOD - UNITS 1 & 2 8 3.8.1 - 6 Revisio0

BRAIDWOOD BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. *The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4, and MODE 4 to MODE 5. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4, and MODE 4 to MODE 5. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (LCO 3.4.12, LTOP SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable LTOP system. There is an increased risk associated with entering MODE 4 from MODE 5 with LTOP inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 4 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 5 (LCO 3.5.3, ECCS - SHUTDOWN) A Note prohibits the application of LCO 3.0.4.b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.7.5, AF SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable AF train when entering MODE 1. There is an increased risk associated with entering MODE 1 with an AF train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 7 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 5B Markup of Technical Specification Bases Pages BYRON STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-6 B 3.0-7 B 3.0-8 B 3.0-17 B 3.0-18 B 3.3.3-12 B 3.3.4-3 B 3.4.11-4 8 3.4.12-11 B 3.4.15-4 B 3.4.15-5 B 3.4.16-4 B 3.5.3-3 B 3.6.8-4 B 3.7.4-4 B 3.7.5-5 B 3.7.8-5 B 3.7.9-8 B 3.7.9-10 B 3.8.1-6

LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Spent Fuel Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.14 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in the spent fuel pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 [CO 3.0.4 establishes limitations on hanges in MODES or other specified conditions in the A icability when an LCO is not met. It precludes placing e unit in a different MODE or ot er specified conditiong tated in that Applicabi ty (e.g., Applicabili desired to be entered) when the ollowing exist:

a. U it conditions are such that the requirements of he 0 would not be met i the Applicability desir to e entered; and

b. Continued noncompli nce with the LCO require ents, if the A plicability ere entered, would resul in the unit being requir d to exit the Applicabi ty desired to be entered t comply with the Required Actions.

BYRON - UNITS 1 & 2 B 3.0 - 6 Revision

LCO Applicability B 3.0 BASES L; - . .84 \ LCO 3.0.4 (cont Ilnutu). _--- ompliance with Required Actions that permit continued operation of the unit for an unlimited period of time i a MODE or other specif ed condition provides an acceptabl level of safety for continued operation. This is wit ut regard to the stat s of the unit before or after the ODE change. Therefor , in such cases, entry into a MODE or other specified ondition in the Ap licability may e made in accordance with the provisions of the Required ctions. The provisions/of this Specification should not interpreted a endorsing the failure to exercis the good practice of estoring systems or components to PERABLE status befo e entering an associated MODE or ther specified condition n the Applicability. The prov sions of LCO 3.0.4 shall not pre nt changes in MODES o other specified conditions in t Applicability that e required to comply with ACTION<. In addition, the provi ions of LCO 3.0.4 shall not prev nt changes in MODES or other specified conditions in the pplicability that result from any unit shutdown. Exceptions to LCO 3.0.4 are state in the individual Specifications. The exceptions low entry into MODES or other specified conditions in e Applicability when the associated ACTIONS to be ente d do not provide for continued operation for an u irmited period of time. Exceptions may apply to all/he ACTIONS or to a specific Required Action of a Speci ication. LCO 3.0.4 is only appli ble when entering MODE 4 fro MODE 5, MODE 3 from MO 4, MODE 2 from MODE 3, or El from MODE 2. Further ore, LCO 3.0.4 is applicable hen entering any other ecified condition in the App cability only while operati in MODE 1, 2, 3, or 4. The requirements of 0 3.0.4 do not apply in MODES and 6, or in other specif d conditions of the Applicabi ty (unless in MODE 1, 2, , or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. BYRON - UNITS 1 & 2 B 3.0 - 7 Revision

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) h veillances performed do not have to be on othe associated inopmenabe equipment (or onm varibe es outside the speciIed li mit as permitted by SR 3.021 Therefore, changin MODES tother specified conditons while in an ACTIo Condialon, in compliance wit oring 3.0.4 or where an t exc on to LCO 3.0.4 is s , is not a viola of SR3 .0.1 or SR 3.0.4 fo theae Surveillances thaorin not rmve to be performed du the associated innreto mly ACTipment. However, SRpo st be met to ensur t pERABILITY prior to declaring the sociated equipment 0 RALE (or variable within limitCand restoring compliy ce with the affected LCO. / LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this LCO is to provide an ex~ception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to Perform the required testing to demonstrate OPERABILITY. his Specification does not provide time to perform any other preventive or corrective maintenance. An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the required testing. BYRON - UNITS 1 & 2 B3.0-8 Revision

SR Applicability B 3.0 BASES SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition inthe Applicabilit . This Specification ensures hat system and component OPERABILITY requirements nd variable limits are met before entry into MODES or 0th r specified conditions inthe Applicability for whi these systems and components ens e safe operation of th unit. The provisions of his Specification should not be interpreted as e dorsing the failure to exercise e good practice of re oring systems or component to OP BLE status before ntering an associated MODE or oter specified condition i the Applicability. However, ' certain circumstances, failing o meet an SR will no result inSR 3.0.4 restricting a ODE change or other ecified condition change. When system, subsystem, trai component, device, or variable i inoperable or out de its specified limits, the ass iated SR(s) are not r uired to be performed, per SR 3.0 , which states that urveillances do not have to be per rmed on inoperable equipment. When equipment is nop able, SR 3.0.4 does not apply to the associated SR(s) sin e the requirement for the SR(s) to be performed is removed Therefore, failing to perform the Surveillance(s) wit in the specified Frequency, on equipment that isinoperabl, does not result inan SR 3.0.4 restriction to chan ng MODES or other specified conditions of the Applicabi )ty. However, since the LCO is not met inthis instance, 0 3.0.4 will govern any restrictions that may (or/may not) apply to MODE or other specified condition chan es. The provisions of SR .0.4 shall not prevent changes in MODES or other speci ed conditions inthe Applicabilit that are required t comply with ACTIONS. Inaddition the provisions of LCO .0.4 shall not prevent changes in ODES or other specified conditions inthe Applicability tlat result from an unit shutdown. The precise equirements for performance of SRs re specified ch that exceptions to SR 3.0.4 are ot necessary The specific time frames and cond ions necessar for meeting the SRs are specifiedi the Frequeay, inthe Surveillance, or both. T isallows perfomance of Surveillances when the pre quisite condition(s) specified ina Surveillance rocedure require entry into the MODE or other specified ondition inthe BYRON - UNITS 1 & 2 B 3.0 - 17 Revi si on(

SR Applicability B 3.0 BASES SR 3.0.4 (continued) tpe icability of the siated iCO pr or to the performt or completion of a Surveillance. A Su veillance that could\ not be performd until after entering/te LCO Applicability, would h~ave/is Frequency specified schthat it is not "due" until the/secific conditions eed are met. Alternately, the Surv Il ance may be stated i ~he form of a Note as not require (to be met or performed until a particular event, condit on, or time has been rea ed. Further discussion of the spcific formats of SRs' notation is found in Sect n 1.4, Frequency. SR 3.0.4 is only applicabl when entering MODE 4 fro MO E 5, MODE 3 from MODE , MODE 2 from MODE 3, or UDE 1 from MODE 2. Furthermo e, SR 3.0.4 isapplicable en entering any other sp ified condition in the App icability only while operating n MODE 1, 2, 3, or 4. Th requirements of SR .0.4 do not apply inMODE and 6, or in other specifie conditions of the Appl ica lity (unless in MODE 1, 2, 3, r 4) because the ACTIONS f individual Specifications sufficiently define the remedial measures to / be taken. SR 3.0.5 SR 3.0.5 establishes the applicability of each Surveillance to both Unit 1 and Unit 2 operation. Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the SR. BYRON - UNITS 1 & 2 .B 3.0 - 18 Revision

PAM Instrumentation B 3.3.3 BASES ACTIONS Note 1 has been added in the ACTIONS to exclude the MODE charge restriction of 0 3.0.4. This excetion allows entry i to the applicable DE while relying o the ACTIONS even t ough the ACTIONS m eventually requir unit shutd n. This exceptio is acceptable due the passive func ion of the instrumets, the operator's ability to re pnd to an acciden usi g alternate in tuments and methods, and the low probability of an event requiring these Jz Note 0has been added in the ACTIONS to clarify the W application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function. A.1 Condition A applies to all PAM Functions. Condition A addresses the situation where one or more Functions with one or more required channels are inoperable. The Required Action isto refer to Table 3.3.3-1 and to take the Required Actions for the Functions affected. The Completion Times are those from the reference Conditions and Required Actions. B.1 IfCondition B is required to be entered by Table 3.3.3-1, the inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval. BYRON - UNITS 1 & 2 B 3.3.3 - 12 Revisio @

Remote Shutdown System B 3.3.4 BASES ACTIONS Note 1 is included which excludes the MODE change rest iction of LCO 3.0.4. s exception allows envy into an pplicable MODE while re ying on the ACTIONS eve though th& ACTIONS may eventually require a unit shutdown/. This e' eption is acceptable e to the low probabilit' of an ent requiring the Remke Shutdown System and fecause the quipment can generall be repaired during operation without significant risk of s urious trip. Note @has been added to the ACTIONS to clarify the applfation of Completion Time rules. Separate Condition k-I entry is allowed for each Function listed on Table 3.3.4-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function. A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System listed in Table 3.3.4-1 are inoperable. The Required Action is to restore the required Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. B.1 and B.2 If the Required Action and associated Completion Time of Condition A is not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. BYRON - UNITS 1 & 2 *B3.3.4 - 3 Revision j

Pressurizer PORVs B 3.4.11 BASES APPLICABILITY (continued) Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not applicable in MODE 4, 5, or 6, when both pressure and core energy are decreased and the pressure surges become much less significant. LCO 3.4.12 addresses the PORV requirements in MODES 4 and 5, and in MODE 6 with the reactor vessel head in place. ACTIONS m Notee has been added to clarify that all tpressurizer PORVs and block valves are treated as separate entities, each with separate Completion Times (i.e. the Completion Time is on a component basisQ cif=ep5~ for z~ ~ ~ PM4-~t Lpris entry. YLytODE ,2 andv to peror/cclig f he PORVs or bIock valves to ver gytheir OPRXEsau.Tsting is ngtpromdi oe MODS A.1 PORVs may be inoperable and capable of being manually cycled (e.g., excessive seat leakage). In this condition, either the PORVs must be restored or the flow path isolated within 1 hour. The associated block valve is required to be closed but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. This permits operation of the unit until the next refueling outage (MODE 6) so that maintenance can be performed on the PORVs to eliminate the problem condition. Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The Completion Time of 1 hour is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period. BYRON - UNITS 1 & 2 B 3.4.11 - 4 Revisio @

LTOP System B 3.4.12 BASES ACTIONS The Actions are modified by a Note that indicates that the provisidhs f LCO 3.0. 4 are 6tapplicable to the RCS l

             ,- pressufre, relief capabilitie (POR~s and RHR suction r Tif     I valve or vent of > 2.0 s dre inches with the RCSO/

_' de kessurized). As a regit, MODE changes are allote when

,                oe or more of these c abilities are inoperable. This (lowance isprovid because the Required Actio s have been determined to provide an acceptable level of safety.

A.1 and B.1 With two centrifugal charging pumps capable of injecting into the RCS, or one positive displacement charging pump capable of injecting into the RCS, or any SI pump capable of injecting into the RCS, RCS overpressurization ispossible. The requirement to immediately initiate action (except during charging pump swap operation) to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition. Required Action A.1 ismodified by a Note that permits two charging pumps capable of RCS injection for < 15 minutes to allow for pump swaps. C.1 and D.1 An unisolated accumulator requires isolation within 1 hour. This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by the P/T limit curves. Ifthe Required Action and associated Completion Time of Condition C are not met, Required Action D.1 must be performed inthe next 12 hours. Depressurizing the accumulators below the LTOP limit from the PTLR prevents an accumulator pressure from exceeding the LTOP limits ifthe accumulators are fully injected. The Completion Times are based on operating experience that these activities can be accomplished inthese time periods and on engineering evaluations indicating that an event requiring LTOP isnot likely inthe allowed times. BYRON - UNITS 1 & 2 B 3.4.12 - 11 RevisionD

RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE. In MODE 5 or 6, the temperature is to be < 2000F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6. ACTIONS A.1 and A.2 With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours after establishing steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1. {euie Action A.1 and Requ 'red Action A.2 are modife be-\ I o aNt/hat indicates that he provisions of LCO 3.0Mt are \ Inot apicable. As a resut a MODE change is aly when th onainment sump monh or is inoperable. Thi Xlowance is povided because otX instrumentation is av Kale to nitor RCS leakage. BYRON - UNITS 1 & 2 B 3.4.15 - 4 Revision

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued) B.1.1. B.1.2. and B.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed for gaseous and particulate radioactivity or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information. With a sample obtained and analyzed or water inventory balance performed every 24 hours, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. The 24 hour interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours after establishing steady state operation (stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leakage detection is available.

                   /eured Action B.1 and Required Action B.2 are modi id yA I Ntie/that indicates that he provisions of LCO 3.0./ are     \

Inot a plicable. As a resu t, a MODE change is allo zd when the aseous and particulae containment atmosp~hwere/ radoactivity channel is/inoperable. This alloa ce is p oided because other intrumentation is availaM e to nitor RCS leakage. BYRON - UNITS 1 & 2 B 3.4.15 - 5 Revisio t

RCS Specific Activity B 3.4.16 BASES APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS average temperature 2 500 0F, operation within the LCO limits for DOSE EQUIVALENT I-131 and gross specific activity are necessary to contain the potential consequences of an SGTR to within the acceptable site boundary dose values. For operation in MODE 3 with RCS average temperature

                 < 5000F, and in MODES 4 and 5, the release of radioactivity in the event of a SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the main steam safety valves.

ACTIONS A.1 and A.2 With the DOSE EQUIVALENT I-131 specific activity greater than the LCO limit, samples at intervals of 4 hours must be taken to demonstrate that the limits of Figure 3.4.16-1 are not exceeded. The Completion Time of 4 hours provides sufficient time to obtain and analyze a sample. Sampling is done to continue to provide a trend. The DOSE EQUIVALENT 1-131 specific activity must be restored to within limits within 48 hours. The Completion Time of 48 hours is required, if the limit violation resulted from normal iodine spiking. A Note o the Required Ac ons excludes the MODE c ng restr Xion of LCO 3.0.4 / This exception allows Xtry into the aplicable MODE(S) yhile relying on the ACTONS even thofh the ACTuI mav eveI I 4-recm re unit shutdown. is acceptable due to the signiicant conservatism inco evi y imit, the low probability of an event whic is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the unit remains at, or proceeds to power operation. BYRON - UNITS 1 & 2 B 3.4.16 - 4 Revision

ECCS-Shutdown B 3.5.3 BASES ACTIONS A.1 With no ECCS RHR subsystem OPERABLE, the unit is not prepared to respond to a loss of coolant accident or to continue a cooldown using the RHR pumps and heat exchangers. The Completion Time of immediately to initiate actions that would restore at least one ECCS RHR subsystem to OPERABLE status ensures that.prompt action is taken to restore the required cooling capacity. Normally, in MODE 4, reactor decay heat is removed from the RCS by an RHR loop. If no RHR loop is OPERABLE for this function, reactor decay heat must be removed by some alternate method, such as use of the steam generators. The alternate means of heat removal must continue until the inoperable RHR loop components can be restored to operation so that decay heat removal is continuous. With both RHR pumps and heat exchangers inoperable, it would be unwise to require the unit to go to MODE 5, where the only available heat removal system is the RHR. Therefore, the appropriate action is to initiate measures to restore one EGCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status. B.1 With no ECCS centrifugal charging subsystem OPERABLE, due to the inoperability of the centrifugal charging pump or flow path from the RWST, the unit is not prepared to provide high pressure response to Design Basis Events requiring SI. The 1 hour Completion Time to restore at least one centrifugal charging subsystem to OPERABLE status ensures that prompt action is taken to provide the required cooling capacity or to initiate actions to place the unit in MODE 5, where an ECCS train is not required.

                  .C1 When the Required Actions of Condition B cannot be completed within the required Completion Time, a controlled shutdown should be initiated. Twenty-four hours is a reasonable time, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems or operators.

BYRON - UNITS 1 & 2 B 3.5.3 - 3 Revisiore

Hydrogen Recombiners B 3.6.8 BASES ACTIONS A.1 With one containment hydrogen recombiner inoperable, the inoperable recombiner must be restored to OPERABLE status within 30 days. In this condition, the remaining OPERABLE hydrogen recombiner is adequate to perform the hydrogen control function. However, the overall reliability is reduced because a single failure in the OPERABLE recombiner could result in reduced hydrogen control capability. The 30 day Completion Time is based on the availability of the other hydrogen recombiner, the small probability of a LOCA or SLB occurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit. Required Action A.1 has been modified by a Note that states th rovsions of LCO 3.0.4 ac not applicable. As result a MODE change is al wed when one recombine is inoperble. This allowanc is based on the availa ility of the othexhydrogen recombW er, the small probabilty of a LOC or SLB occurring (t at would generate an a unt of hy ogen that exceeds t e flammability limit), nd the ount of time avail e after a LOCA or SLB should one occur) for operator Yction to prevent hydrogen accumulation from exceeding the flammability limit. BYRON - UNITS 1 & 2 B 3.6.8 - 4 Revi si o

SG PORVs B 3.7.4 BASES LCO (continued) A SG PORV is considered OPERABLE when it is capable of providing controlled relief of the main steam flow and capable of fully opening and closing on demand. APPLICABILITY In MODES 1, 2, and 3, the SG PORVs are required to be OPERABLE. In MODE 4, the pressure and temperature limitations are such that the probability of an SGTR event requiring SG PORV operation is low. In addition, the RHR system is available to provide the decay heat removal function in MODE 4. Therefore, the SG PORV lines are not required OPERABLE in MODE 4. In MODE 5 or 6, an SGTR is not a credible event. ACTIONS A.1 With one SG PORV line inoperable, action must be taken to restore OPERABLE status within 30 days. The 30 day Completion Time allows for the redundant capability afforded by the remaining OPERABLE SG PORV lines, a nonsafety grade bD S.t1m and MS5.1 ,-)1euie-- p~~ctieh A~~fiafe yaQt niaing that 4Q 3.0.4 B.1 With two or more SG PORV lines inoperable, action must be taken to restore all but one SG PO RV line to OPERABLE status. Since the block valve can be closed to isolate a SG PORV, some repairs may be possible with the unit at power. The 24 hour Completion Time is reasonable to repair inoperable SG PORV lines, based on the availability of the Steam Dump System and MSSVs, and the low probability of an event occurring during this period that would require the SG PORV lines. BYRON - UNITS 1 & 2 -B3.7.4 - 4 Revisio

AF System B 3.7.5 BASES ACTIONS A.1 With one of the required AF trains (pump or flow path) (: tinoperable, action must be taken to restore OPERABLE status within 72 hours. The 72 hour Completion Time is reasonable, based on redundant capabilities afforded by the AF System, time needed for repairs, and the low probability of a DBA occurring during this time period. B.1 and B.2 When Required Action A.1 cannot be completed within the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. C.1 If both AF trains are inoperable, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AF train to OPERABLE status. Required Action C.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AF train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition. In addition, the Completion Times of Required Actions which are suspended are also suspended. BYRON - UNITS 1 & 2 B 3.7.5 - 5 Revisions

SX System B 3.7.8 BASES ACTIONS (continued) B.1 If the opposite-unit SX train is not OPERABLE for unit-specific support, action must be taken to restore OPERABLE status within 7 days. In this Condition, if a complete loss of unit-specific SX were to occur, the SX System function would be lost. The 7 day Completion Time is based on the capabilities of the unit-specific SX System and the low probability of a DBA with a loss of all unit-specific SX occurring during this time period. (Rquired Action B.1 is m dified by a Note that s ates LCO gO.4 is not applic le. This exception to LCO 3.0.4 is bas'd on the redundancy of the unit-specific ains and the d Zign basis analysis akes no credit for theyopposite-unit C.1 and C.2 If the unit-specific SX train or the opposite-unit SX train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit _ mast-be-placed--in'at-least-MODE-3-within-6 hours,-and in-- MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. BYRON - UNITS 1 & 2 B 3.7.8 - 5 RevisionC

UHS B 3.7.9 BASES ACTIONS (continued) Required Action C.3 requires the SX makeup pump to be restored to OPERABLE status within 7 days or 14 days respectively. The 7 day limit is applicable if both Unit 1 and Unit 2 are in MODE 1, 2, 3, or 4. The 14 day limit is only applicable if either Unit 1 or Unit 2 is in MODE 5, MODE 6, or defueled. This Required Action serves to provide up to 7 days to restore a SX makeup pump when both units are operating, and up to 14 days when one unit is operating and the other is shutdown. The 14 day allowance provides adequate time to perform pump inspection and extended maintenance when one unit is in an outage. Without this allowance, a dual-unit outage would be required to perform maintenance that requires more than 7 days to complete. The extended Completion Time when one unit is in shutdown is also based on the reduction in the quantity of heat that would have to be removed by the UHS when one unit is in a shutdown condition, a reduction in the amount of water that may be required to satisfy AF demands, and the availability of the other makeup water sources. Although the 14 day Completion Time was justified based on the need to perform extended maintenance, its use and application is not . restricted to these activities because the effects of SX makeup pump inoperability are unrelated to the cause of the inoperability. ontion C Required Actions are modified by a Note ind lating the propjisions of LCO 0. arnoaplable Asaresult, a MOFE change is aloed when one SX Wkup sdpis inoperabIe. This allow ce is providdbie on the owprobability/f an event o curring during titime v roand eredundancy pfthe available ma psources.> BYRON - UNITS I & 2 B 3.7.9 - 8 Revision

UHS B 3.7.9 BASES ACTIONS (continued) E1 With the Rock River water level < 670.6 ft Mean Sea Level (MSL), action must be taken to assure that adequate level and flow remain available from the Rock River intake to the SX makeup pumps to permit their operation. When the water level in the river falls below this limit within one hour, and every 12 hours thereafter, the water level in the river must be verified to be greater than 664.7 ft MSL and the flow rate in the river must be verified to be greater than or equal to 700 cubic feet per second (CFS). 700 cfs assures adequate inventory is available for the pumps to maintain the level in the UHS basins. 664.7 ft is the minimum design operating level of the SX makeup pumps. Assuring adequate inventory and a level greater than the minimum operating level provides assurance that the pumps can perform their function if required. The 1 hour Completion Time for initial performance of this Required Action is reasonable based on the low probability of an accident occurring during the 1 hour and the time required to reasonably complete the Required Actions. The continued performance of this verification every 12 hours is reasonable based on the availability of other makeup sources and the low likelihood of an accident and a rapid unexpected decrease in the river level. equir d Action E.1 is dified by a /ote indicating t e provis ons of LCO 3.0. 7are not applfcable. As a res t, a MODE hange is allowed with ade ua water level an flow. This allowance ispr ided based the low probabilty of an ent occurring ring this tme period, and e re rdany o th a ilable ma up sources. BYRON - UNITS 1 & 2 B 3.7.9 - 10

AC Sources-Operating B 3.8.1 BASES ACTIONS X d I, To ensure a highly reliable power source remains with one required qualified circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required qualified circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if another required circuit fails SR 3.8.1.1, this qualified circuit is inoperable, and additional Conditions and Required Actions may be appropriate. If the additional inoperability results in a bus with two required qualified circuits inoperable Condition C is entered. If the additional inoperability results in the second bus with one required qualified circuit inoperable Condition A is still applicable. A.2 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours. With one or more buses with one required qualified circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this Condition, however, the remaining OPERABLE required qualified circuits and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period. BYRON - UNITS 1 & 2 B 3.8.1 - 6 Revision

BYRON BASES INSERTS - INSERT 1 (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, 'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4, and MODE 4 to MODE 5. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified -- conditions-of the-Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4, and MODE 4 to MODE 5. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (LCO 3.4.12, LTOP SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable LTOP system. There is an increased risk associated with entering MODE 4 from MODE 5 with LTOP inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 4 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 5 (LCO 3.5.3, ECCS - SHUTDOWN) A Note prohibits the application of LCO 3.0.4.b to an inoperable ECCS high head subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS high head subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.7.5, AF SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable AF train when entering MODE 1. There is an increased risk associated with entering MODE 1 with an AF train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 7 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 5C Markup of Technical Specification Bases Pages CLINTON POWER STATION, UNIT I FACILITY OPERATING LICENSE NO. NPF-62 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-5 B 3.0-6 B 3.0-14 B 3.0-15 B 3.3-55 B 3.3-62 B 3.4-36 B 3.4-37 B 3.4-40 B 3.4-41 B 3.4-45 B 3.5-6 B 3.5-22 B 3.6-68 B 3.6-69 B 3.6-74 B 3.6-75 B 3.6-80 B 3.8-5 B 3.8-95

LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the associated fuel storage pool." Therefore, (continued) this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified onditions in the Applicabiljty when an LCO is not met. I precludes placing the unit n a MODE or other specified condition stated in that Aplicability (e.g., Applit bility desired to be enter ) when the following ex st:

a. Unit onditions are such that th requirements of the LCO ould not be met in the App icability desired to b entered; and

b. Continued noncompliance wit the LCO requirements, if the Applicability were en red, would result in the unit being required to edt the Applicability desire to be entered to comply ith the Required Actions.

Compliance with Required tions that permit continued operation of the unitfo an unlimited period of tim in a MODE or other specified condition provides an accep ble level of safety for co tinued operation. This is ithout regard to the status f the unit before or after he MODE change. Therefore, n such cases, entry into a ODE or other specified coddition in the Applicability ay be made in accordance wit the provisions of the Req red Actions. The provisions this Specification should ot be interpreted as endorsing the failure to ex _cise the good practice of storing systems or componen s to OPERABLE status befo e entering an associated MOD or other condition in the Ap(cability.e The pro sions of LCO 3.0.4 shall no prevent changes in MOESorother specified condition /n the Applicabilityl thatarerequired to comply with ATONS. In addition, th l (continued) CLINTON B 3.0-5 Revision No.

LCO Applicability B 3.0 0 BASES LCO 3.0.4 ii s on)as p i byS 3.0. 1 erefor changin M (continued) or other spe conditions in the Applicabilit tha cified result from nyunit shutdown./ Exception'to LCO 3.0.4 are stated in the indoionual Specific ons. Exceptions may apply to allaee ACTIONS or to a sppific Required Action of a Specifi tion. Surv ances do not dnhave to be performed the associated inoprable equipment (or on variablest tosue O specified lirts), as permitted by SR 3.0.1: Therefore, changing MODES or other specified conditions~/While in an ACTIONS Condition, eithin li restoring CO 3.0.4, or where an exception to LCO 3.0a4 is staltedwis notea violation of SR 3.0.1 or SR 3.0.4 for thosejurveillances that do not have to be performed due to tKe associated inoperable equipment. However, iRs e met to ensure o OPERABILITY prior to declaring 1thn s2 .iaTed equipment OPERABLE (or variable within limits) Adrestoring compliance with the / affected LCO.// LCO 3.0.4 is only a g cable when entering MODE 3 from DE 4, MODE 2 from MODif or 4, or MODE I from MODE 2. / Furthermore, LCO §.0.4 is-applicable when entering aiother specified condieion in the Applicability only wie operating in ODE 1, 2, or 3. The requirement o CO 3.0.4 do not appl In MODES 4 and 5, or in other specified conditio s of the Applicability (unless in MOD 1, 2, or 3) because e ACTIONS of individual Specificat' ns sufficiently define the remedial measures t be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

(continued) CLINTON B 3.0-6 Revision No. 0

SR Applicability B 3.0 BASES 0 missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Clinton Power Station Corrective Action Program. If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable then is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be m t before entry into a MODE or other specified condition in the Applicability. This Sp cification ensures that sys m and component OPERAB LITY requirements and varia e limits are met before entry inAo MODES or other specifitd conditions in the App cabi ity for which these sy tems and components ensure sa operktion of the unit. owever, in certain circumst ces failing to meet an SR will/ not result in SR 3.0.4 rest cting a MODE change or other specified condition change When a system, subsystem, / division, component, devi e, or variable is inoperable o outside its specified l ts, the associated SR(s) are ot required to be perform , per SR 3.0.1, which states at surveillances do not rave to be performed on inopera e equipment. When eq pment is inoperable, SR 3.0.4 oes not apply to the asso ated SR(s) since the requireme for the SR(s) to be perf ed is removed. Therefore, f ling to perform the Sur eillance(s) within the specif d Frequency, on equipment at is inoperable, does not r ult in an SR 3.0.4 restri ion to changing MODES or oth r specified conditions *n the Applicability. However since the LCO is

                                                               -cont         0-CLINTON                      B 3.0-14                     Revision R         NoX

SR Applicability 4 B 3.0 BASES SR 3.0.4 not met in this instance, LCO 3.0.4 will govern any (continued) restrictions that may (or may not) apply to MODE or other specified conditio changes. The provisions of this Specification should not be interpreted as e dorsing the failure to exercise he good practice of res ring systems or components to 0PRABLE status before tering an associated MODE or ot er specified condition in e Applicability. The provisi s of SR 3.0.4 shall not preven changes in MODES or o er specified conditions in the pplicability that are equired to comply with ACTIONS. In addition, the provisio s of SR 3.0.4 shall not prevent changes in MODES or other s ecified conditions in the Appli ability that result from a unit shutdown. The p ecise requirements for perfor nce of SRs are spec fied such that exceptions to S 3.0.4 are not nec ssary. The specific time frans and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, r both. This allows performance of Surveillances wh n the prerequisite condition(s) specified in a Su veillance procedure require entry into the MODE or other pecified condition in the Applicability of the associa ed LCO prior to the performance or completion of a Surveill nce. A Surveillance that could not be performed until aft r entering the LCO Applicability would have its Frequency pecified such that it is not "du until the specific condi ions needed are met. Alternatel the Surveillance may be stated in the form of a Note as ot required (to be met or performed) until a particular ev nt, condition, or time ha been reached. Further discuss n of the specific formats of SRs' annotation is found in Section 1.4, Freque cy. SR 3.0.4 is only plicable when entering MODE 3 rom MODE 4, MODE 2 from M E 3 or 4, or MODE 1 from MODE Furthermore, SR 3.0.4 is applicable when enter'g any other specified cond tion in the Applicability only hile operating in ODE 1, 2, or 3. The requiremens of SR 3.0.4 do not appl in MODES 4 and 5, or in other ecified condition of the Applicability (unless in ODE 1, 2, or 3) because the ACTIONS of individual Specifications _sufficiently define the remedial measures to be taken. CLINTON B 3.0-15 Revision No.

PAM Instrumentation B3.3.3.1 BASES LCO 10. Suppression Pool Water Bulk Average Temperature (continued) when pool water level is below the instruments addressed by the Operational Requirements Manual. The outputs for the PAM sensors are recorded on two independent recorders in the control room. These recorders average the output from the four Division 1 sensors and the four Division 2 sensors. Both of these recorders must be OPERABLE to furnish two channels of PAM suppression pool water bulk average temperature. These recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels (Reference 4). APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS o e has been added to the ACTIONS to exclude the ODE change estriction of LCO 3.0. . This exception a ows entry into the applicable MO while relying on t e Actions even though the Actions mayeventually require p ant shu down. This exception is acceptable due to he passive fu ction of the instrume ts, the operator's ab lity to d'agnose an accident u ng alternate instrum ts and methods, and the lows obability of an even equiring these instrmns_______ A Note has X been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for (continued) CLINTON B 3.3-55 Revision No. X

Remote Shutdown System. B 3.3.3.2 0 BASES LCO The scope of this LCO does not include those controls (continued) associated with the steam condensing mode of the Residual Heat Removal System. APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1 and 2. This is required so that the plant can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room. This LCO is not applicable in MODES 3, 4, and 5. In these MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the TS does not require OPERABILITY in MODES 3, 4, and 5.. ACTIONS /A Note as bncluded thpi tom he AO nS reltdit RemoCO 3e .4. This ex Function s entry ion 13 C applic se MODE while relyinge n the ACTIONS even t dugh th s may eventually requbte a plant shutdown.r vis ACTIOu exces ion is acceptable d iorto the low probabi of an Notewihas been provided to modify the ACTIONS related to Remo Me Shutdown System Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown System Functions provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function. (continued) CLINTON B 3.3-62 Revision No

RCS Leakage Detection Instrumentation B 3.4.7 BASES ACTIONS A.1 (continued) continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leaka , - detection that are still availabledrllon ast e A.1 atmo herde all be teak and alyz toeprovisionspodic LCO eakagei e not applicable.d sampl a s taain MODEb is (aIe.aiec both drywell flo drain sump flow monisng avsai abe inoperable. Ther allowance is provided cause iothrmaiostrentationa is ateatole to monitor RCS B.1 With both gaseous and particulate drywell atmospheric monitoring channels inoperable, grab samples of the drywell atmosphere shall be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 24 hours, the plant may continue operation since at least one other form of 'drywell'leakage detection (i.e., air cooler condensate flow rate monitor) is available. The 24 hour interval provides periodic lrnt information that is adequate to detect LEAKAGE. a With the required drywell air cooler condensate flow rate monitoring system inoperable, SR 3.4.7.1 is performed every 8 hours to provide periodic information of activity in the drywell at a more frequent interval than the routine Frequency of SR 3.4.7.1. The 8 hour interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action to be not applicable if the required drywell atmospheric monitoring system is inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment. (continued) CLINTON B 3.4-36 Revision

                                                      .... . ..Nor3  11)

RCS Leakage Detection Instrumentation B 3.4.7 BASES ACTIONS D.1 and D.2 (continued) With both the gaseous and particulate drywell atmospheric monitor channels and the drywell air cooler condensate flow rate monitor inoperable, the only means of detecting LEAKAGE is the drywell floor drain sump monitoring system.. This Condition does not provide the required diverse means of leakage detection.. The Required Action is to restore either of the inoperable monitoring.systems to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a Ien t Required Actiond B, C,r or D canenotb aoie thai states ,t he provisnm s of bCOught 3.0.4 not applicable As a' esult, a MO0DE/change As allowd when both the drywith gaseous and particulate atmosph erc honitoring chnels and drywell air Iolocondensate flo zate monitweng system are inotesrile. This allowr b e is provien because other insrrumentation is avtiable t bruht taMOEiwhic theLDdosnoyapy.

  }             E.1 and E.2 If any Required Action of Condition AbB,n C, or D cannot be met withinithe associated CompletionaTime, the plant must be brought to a MODE in which the LCO does not apply. Toi
.   ..          achieve  this status, the plant must be brought to at least I 3 within MODE            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 inan orderly manner and without challenging plant systems.

F.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires the performance of a CHANNEL CHECK of the required drywell atmospheric monitoring system. The check (continued) CLINTON B 3.4-37 Revision No.X

RCS Specific Activity B 3.4.8 BASES 0f APPLICABLE The limits on specific activity are values from a parametric SAFETY ANALYSES evaluation of typical site locations. These limits are (continued) conservative because the evaluation considered more restrictive parameters than for a specific site, such as the location of the site boundary.and the meteorological conditions of the site. RCS specific activity satisfies Criterion 2 of the NRC Policy Statement. LCO The specific iodine activity is limited to - 0.2 pCi/gm DOSE EQUIVALENT I-131. This limit ensures the source term assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 100 limits. APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment. In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5, no limits are required since the reactor is not pressurized and the potential for leakage is reduced. ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT 1-131 limit, but is < 4.0 Ci/gm, samples must be analyzed for DOSE EQUIVALENT 1-131 at least once every 4 hours. In addition, the specific activity must.be restored to the LCO limit within 48 hours. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 48 hour Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. (continued) CLINTON B 3.4-40 Revision No. 0 0 ", I

                                                                             %:1t_1

RCS Specific Activity B 3.4.8 BASES ACTIONS A.1 and A.2 (continued) A Noe tthRequired Act~ions of Condition A excl des t

         ,--_      MODE chnge restriction of SCO 3.0.4. This excep on allows 4    Shent          yito the ap~plicabl;%M00DE(S) while relying    6n the I~~~~ las pATO    S even      thsmuq h ACTIONS hee' may      eventually require plan jrhi       T-spd acceptable auesLe--~~

significant conserva ism incorporated into the specitic activity limit; the low probability of a limiting event while exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation. B.I. B.2.1. B.2.2.1, and B.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to < 0.2 pCi/gm within 48 hours, or if at any time it is > 4.0. pCi/gm, it must be determined at least every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident. Alternately, the plant can be brought to MODE 3 within 12 hours and to MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for bringing the plant to MODES 3 and 4 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. (continued) CLINTON B 3.4-41 Revision No

RHR Shutdown Cooling System-Hot Shutdown B 3.4.9 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 are (continued) discussed in LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.8, "Residual Heat Removal (RHR)--High Water Level"; and LCO 3.9.9, "Residual Heat Removal (RHR)-Low Water Level." ACTIONS A Note to the ACTIONS excludes he MODE change restriction of LCO DfIb This excepti on Alows entry into the \ applia~ MODE(S) while rely ng on the ACTIONS even thUgh the A tfNS may eventually rquire plant shutdown..1 exce ion is acceptable du to the redundancy of t Kis' OPERALE subsystems,' the owpressure at which th plant is 0 ~ating, the low pro blity of an event occupyn during o eration in this condtin, and the availabft of alternate methods o cay heat removal cap ility. A$ Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem. A.I. A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore an alternate method of decay heat removal must be provided. (continued) CLINTON B 3.4-45 Revision No

ECCS-Operating B 3.5.1 BASES (continued) ACTIONS A.1 If any one low pressure ECCS injection/spray subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a LOCA may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability by assuming that various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times). B.1 and B.2 If the HPCS System is inoperable, and the RCIC System is verified to be OPERABLE (when RCIC is required to be

OPERABLE), the HPCS System must be restored to OPERABLE status within 14 days. In this .Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with the ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Verification of RCIC OPERABILITY .within 1 hour is therefore required when HPCS is inoperable and RCIC is required to be OPERABLE. This may be performed by an administrative check, by examining logs or other information, to determine if RCIC is out of service for maintenance or other reasons. It is not necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System. However, if the OPERABILITY of the RCIC System cannot be verified and RCIC is required to be OPERABLE, Condition D must be immediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is based on the results of a reliability study (Ref. 12) and has been found to be acceptable through operating experience.

(continued) CLINTON B 3.5-6 Revision No

RCIC System B 3.5.3 0 BASES BACKGROUND The RCIC pump is provided with a minimum flow bypass line, (continued) 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 line 'keep fill' system is designed to maintain the pump discharge line filled with water. APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES. events by providing makeup coolant to the reactor. Should a design basis control rod drop accident occur, the RCIC System can be used in conjunction with the HPCS System to meet the single failure criteria in mitigating the consequences of the event (Ref. 4). The RCIC System is an Engineered Safety Feature for this event and satisfies Criterion 3 of the NRC Policy Statement. LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity to maintain RPV inventory during an isolation event. O1 APPLICABILITY The RCIC System is required to be OPERABLE in 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 ECCS injection/spray subsystems can provide sufficient flow to the vessel. ACTIONS A.1 and A.2 T If the RCIC System is inoperable during MODE 1, or MODES 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCS System is verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high (continued) CLINTON B 3.5-22 Revision No. 0

Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES (continued) APPLICABILITY In MODES 1 and 2, the two primary containment hydrogen recombiners are required to control the hydrogen concentration within primary containment below its flammability limit of 4.0 v/o following a LOCA, assuming a worst case single failure. In MODE 3, both the hydrogen production rate and the total hydrogen production 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 A.1 With one primary containment hydrogen recombiner inoperable, the inoperable primary containment hydrogen recombiner must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE primary containment hydrogen recombiner is adequate to perform the hydrogen control function. However, the overall reliability is reduced because a single failure in the OPERABLE recombiner 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 amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent hydrogen accumulation exceeding this limit, and the low probability of failure of the OPERABLE primary containment hydrogen recombiner. the ovisions LCO 3.0.4 are not pplicable. As a res t, a MOEcange is allowe whe ?-pne recombi er i ipperibleM.,"his allowance ipro4ided because of tW~ low Xrobabilit/ of the occurrec of/a LOCA that would gnrt hydrogen/in amounts capable of/eceeding the flam ailt l imit, the low probability otte failureoft OEAL (continued) CLINTON B 3.6-68 Revision No.

Primary Containment Hydrogen Recombiners B 3.6.3.1' BASES ACTIONS Ai. (continued) recombine and the amount of ti available after a postul 8fi'LOCA for operator 4etion to prevent e ing the B.1 and B.2 With two primary containment hydrogen recombiners inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour. The alternate hydrogen control capabilities are provided by one division of the hydrogen igniters. The 1 hour Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. The verification may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control system. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control 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 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 the amounts capable of exceeding the flammability limit. C.1 If any Required Action and required 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 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. (continued) CLINTON B 3.6-69 Revision No.

Primary Containment and Drywell Hydrogen Igniters B 3.6.3.2 C BASES (continued) APPLICABILITY In MODES I and 2, the hydrogen igniter is required to control hydrogen concentration to near the flammability limit of 4.0 v/o following a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75% of the core cladding. The control of hydrogen concentration prevents overpressurization of the primary containment. The event that could generate hydrogen in quantities sufficiently high enough to exceed the flammability limit is limited to MODES I and 2. In MODE 3, both the hydrogen production rate and the total hydrogen produced after a degraded core accident 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 hydrogen igniter is low. Therefore, the hydrogen igniter is not required in MODE 3. In MODES 4 and 5, the probability and consequences of a degraded core accident are reduced due to the pressure and temperature limitations. Therefore, the hydrogen igniters are not required to be OPERABLE in MODES 4 and 5 to control hydrogen. ACTIONS A.1 With one hydrogen igniter division inoperable, the inoperable division must be restored to OPERABLE *status within 30 days. In this Condition, the remaining OPERABLE hydrogen igniter division is adequate to perform the hydrogen burn function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced hydrogen control capability. The 30 day Completion Time is based on the low probability of the occurrence of a degraded core event that would generate hydrogen in amounts equivalent to a metal water reaction of 75% of the core cladding, the amount of time available after the event for operator action to prevent hydrogen accumulation from exceeding the flammability limit, and the low probability of failure of the OPERABLE hydrogen igniter division. Required Action, .1 has been modified by a Note i dicati the provision of LCO 3.0.4 e not applicable As a result, a MOO change is a owed when one hy ogen igniter division i inoperable. e allowance is ovided because of the wrobability o the ocan event (continued) CLINTON B 3.6-74 Revision No.

Primary Containment and Drywell Hydrogen Igniters B 3.6.3.2 BASES ACTIONS A.1 (continued) dflammabilityi eat, the low p ability of the hylure of Ihydrgen conthydrogen ignites aivision and tby amount of ltime availkfble after the ev, t for operat H action to B* and B=2 hydrovent rxecmine in conjuncion withbell With twonpriat yry ogntainmn and dryw f igier hydrogen bye B.1 admnisratiemasBihnLor and B.2 h alternt With two primary containment and drywell igniter hydrogen divisions inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within hour. c The alternate hydrogen control capabilities are provided by at least one hydrogen recombiner in conjunction with one Containment/ Drywell Hydrogen Mixing System and two drywell post-LOCA vacuum relief subsystems. The I hour Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. The verification may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control capabilities. It does not emeant th plantrm Surveillances bhe needed to demonstrate OPERABILITY of the alternate hydrogen control capabilities. If the ability to perform the hydrogen control function is maintained, continued operation is permithou clnh two igniter divisions inoperable for up to 7 days. Seven days is a reasonable time to allow two igniter divisions 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 the amounts capable of exceeding the flammability limit. C.1 If any Required Action and required 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 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. (continued) CLINTON B 3.6-75 Revision No.

Containment/Drywell Hydrogen Mixing System B 3.6.3.3 BASES APPLICABILITY calculated for the DBA LOCA. Also, because of the limited (continued) time in this MODE, the probability of an accident requiring the Containment/Drywell Hydrogen Mixing System is low. Therefore, the Containment/Drywell Hydrogen Mixing System is not required in MODE 3. In MODES 4 and 5, the probability and consequences of a LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, the Containment/Drywell Hydrogen Mixing System is not required in these MODES. ACTIONS A.1 With one Containment/Drywell Hydrogen Mixing System inoperable, the inoperable system must be restored to OPERABLE status within 30 days. In this condition, the remaining OPERABLE system is adequate to perform the hydrogen mixing function. However, the overall reliability is reduced because a single failure in the OPERABLE system could result in reduced hydrogen mixing capability. The 30 day Completion Time is based on the low probability of failure of the OPERABLE Containment/Drywell Hydrogen Mixing system, the low probability of a LOCA that would generate 4-hydrogen in amounts capable of exceeding the flammability limit, and the amount of time available after the event for operator action to prevent hydrogen accumulation from exceeding this limit. Required Action A.1 has been mgiified by a Note indica ing the provi ions of LCO 3.0.4 a e not applicable. As result, MODE change is all wed when one system is inoper e. This allowanc is provided because o the low proba lity of the occurr nce of a LOCA that wou d generate hydr gen in amounts cap le of exceeding the f mmability li t, the low probab' ity of the failure of0 he OPERABLE system, and the amoun of time 'available a er a postulated OCA for operator action to prevent exceeding the flammability limit. B.1 and B.2 With two Containment/Drywell Hydrogen Mixing Systems inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within I hour. The alternate hydrogen control capabilities are provided by one division of the hydrogen igniters. The I hour Completion Time allows a (continued) CLINTON B 3.6-80 Revision No

AC Sources-Operating B 3.8.1 BASES APPLICABILITY A Note has been added taking exception to the Applicability (continued) requirements for Division 3 sources, provided the HPCS System is declared inoperable. This exception is intended to allow declaring of the HPCS System inoperable either in lieu of declaring the Division 3 source inoperable, or at any tiffe subsequent to entering ACTIONS for .an inoperable Division 3 source. This exception is acceptable since, with the HPCS System inoperable and the associated ACTIONS entered, the Division 3 AC sources provide no additional assurance of meeting the above-criteria. AC power requirements for MODES 4 and 5 are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS ___ A.I To ensure a highly reliable power source remains, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies 'perform," a failure of SR 3.8.1.1 acceptance criteria does not result in the Required Action not met. However, if a second circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered. A.2 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to -the plant safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class IE distribution system. The Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period. (continued) CLINTON B 3.8-5 Revision No X

SVC Protection Systems B 3.8.11 BASES (continued) APPLICABILITY An SVC Protection System must be OPERABLE whenever its associated SVC is in operation, i.e., whenever the SVC's associated offsite circuit is energized with the SVC connected. Although the plant ESF busses are normally aligned together and to either the RAT or ERAT, an SVC Protection System must be OPERABLE if its associated SVC is connected to the associated auxiliary transformer (RAT or ERAT); the transformer is energized by the offsite network; and the transformer is supplying power to at least one ESF bus, or automatic transfer capability to that transformer exists such that it could supply power to at least one ESF bus. The requirements for the offsite electrical power sources are addressed in LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, "AC Sources-Shutdown." ACTIONS A.1 With one SVC protection subsystem of a required SVC Protection System inoperable, the inoperable subsystem must be restored to OPERABLE status within 30 days. With the SVC Protection System in this condition, the remaining subsystem is adequate to provide the protection function. However, the overall reliability of the SVC Protection System is reduced because a failure of the OPERABLE subsystem would result in a loss of the SVC failure protection function. The 30-day Completion Time is based on the low probability of an SVC failure occurring during this time period, and the fact that the remaining subsystem can provide the required protection function. Requir d Action A.1 is modi ied by a note that sta s that the p ovisions of LCO 3.0. are not applicable. is exc tion allows entry in o MODES or other specifed co itions in the Applic bility when one SVC pr ection s system is inoperabl . This exception is ac ptable due o the redundancy of e protection systems agd the low probability of an S failure (fault) that uld adversely affect the plant equipment. B.l If both SVC protection subsystems of a required SVC Protection System are inoperable, the backup protection system designed for the SVC is unavailable to provide its protection function. Though not all failure modes of the SVC would necessarily be unprotected or potentially damaging to ESF equipment with the required protection system unavailable, there is a significant increase in calculated risk based on conservative failure assumptions for the SVCs. Thus, at least one subsystem must be restored to OPERABLE (continued) CLINTON B 3.8-95 Revision No )

CLINTON BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, 'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring .systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCS subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCS subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, RCIC SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 5D Markup of Technical Specification Bases Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-5 B 3.0-6 B 3.0-16 B 3.0-17 B 3.3.3.1-7 B 3.3.3.1-8 B 3.4.6-3 B 3.4.7-3 B 3.5.1-6 B 3.5.3-2 B 3.8.1-7

LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the spent fuel storage pool." Therefore, this (continued) LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1. 2. or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of 'Suspend movement of fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 LCD 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCD is not met. It recludes placing the unit in a DODE or other specifie condition stated in that Applic ility (e.g.. Applic ility desired to be entered) wh n the following e st:

a. Unit conditions are such that the re irements of the LC would not be met in the Applic ility desired to b entered: and

b. Continued noncompliance with t e LCO requirements, if the Applicability were enter , would result in the unit being required to exit the Applicability desired to be entered to comply w h the Required Actions.

Compliance with Required Ac ons that permit continued operation of the unit for n unlimited period of time in/a MODE or other specified ndition provides an acceptab e level of safety for con nued operation. This is wi out regard to the status o the unit before or after t MODE change. Therefore, such cases, entry into a DE or other specified co ition in the Applicability y be made in accordance wit/the provisions of the Requi ed Actions. The provisions o this Specification should t be interpreted as 7ndorsing the failure to exe cise the good practice of r storing systems or component to OPERABLE status bef entering an associated MOD or other specified condition In the Applicability. The provisions of LCO 3.0.4 shall no prevent changes in MODES or other specified conditions in the Applicability (continued) Dresden 2 and 3 B 3.0-5 Revision

LCO Applicability B 3.0 BASES LCO 3.0.4 that are required to comply with ACTIONS. In addition, th (continued) provisions of LCO 3.0.4 shall not prevent changes MODES or other specified onditions in the Applicabilit that result from any u t shutdown. Exceptions to 0 3.0.4 are stated in the mdin idual Specificatio . The exceptions allow entry to MODES or other spe~ci ed conditions in the Appliciabi ity when the associated ACTIONS to be entered do not pr vide for continue operation for an unlimited per'od of time. Excepti s may apply to all the ACTIONS or to a specific Requir d Action of a Specification. Surv illances do not have to be per ormed on the associated in erable equipment (or on variables outside the specified Vmits). as permitted by SR 3.0. . Therefore, changing MODES or other specified condi ons while in an ACTIONS Condition, either in complian e with LCO 3.0.4 or where a exception to LCO 3.0.4 is stared, is not a violation of SR 3.0.1 or SR 3.0.4 for t ose Surveillances that do n have to be performed due teo the associated inoperable equipment. However, SR must be met to ensure OPERA ILITY prior to declaring the associated equipment OPERABL (or variable within limit/) and restoring compliance wrth the affected LCO. LCO 3.0.4 is only pplicable when entering MO 3 from MODE

4. MODE 2 from M E 3 or 4. or MODE 1 from DE 2.

Furthermore. LC 3.0.4 is applicable when ntering any other specified con tion in the Applicability nly while operating in ODE 1. 2, or 3. The requ rements of LCO 3.0.4 do not appl in MODES 4 and 5. or in oher specified condition of the Applicability (unl ss in MODE 1. 2. or 3) because he ACTIONS of individual specifications sufficiently define the remedial measures to be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate: (continued) Dresden 2 and 3 B 3.0-6 Rev i si on(

SR Applicability B 3.0 BASES SR 3.0.3 LCO Conditions begin immediately upon expiration of the (continued) delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 .4 establishes the requirement that all applicable SRs must be met befe e entry into a MODE or other speci ied condition in te Applicability. This Speci cation ensures that system and com nent OPERABILI requirements and variable limits le met before entry i o MODES or other specified conditio s in the Applic ility for which these systems and mponents ensure safe peration of the unit. Th provisions of this Specification s ould not be i erpreted as endorsing the failure o exercise the good ractice of restoring systems or co ponents to OPERABLE status before entering an associatd MODEjor other specified condition in the Applicability. However, in certain circumsta es, failing to meet an SR will not result in SR 3.0.4 stricting a MODE change or other specified condition c ange. When a system, subsystem, division, component, devic , or variable is inoperable or outside its specified li ts, the associated SR(s) are not required to be performe per SR 3.0.1, which states that Surveillances do not h ve to be performed on inoperable equipment. When equi ment is inoperable, SR 3.0.4 does/not apply to the associ ed SR(s) since the requirement f r the SR(s) to be perfor ed is removed. Therefore, faili g to perform the Surv illance(s) within the specified requency, on equipment t at is inoperable, does not res in an SR 3.0.4 res iction to changing MODES or her specified conditions f the Applicability. Howeve , since the LCO is not met i this instance, LCO 3.0.4 wiJ govern any restrictions that may (or may not) apply to MODE or other specified condition changes. (continued) Dresden 2 and 3 8 3.0-16 Revi si on

SR Applicability B 3.0 BASES SR 3.0.4 The provisions of SR 3.0.4 shall not prevent changes in (continued) MODES or other specified onditions in the Applicability that are required to co ply with ACTIONS. In addition. the provisions of SR 3.0. shall not prevent changes in M ES or other specified condtions in the Applicability tha result from any unit shut wn. The precise req rements for performance of SRs re specified such that exceptions to SR 3.0.4 are/not necessary. e specific time frames and cond tions necessary f r meeting the SRs are specified n the Frequency in the Surveillance, or both. is a lows performa ce of Surveillances when the pre equisi'te conditi n(s) specified in a Surveillanc proced re require entry nto the MODE or other specified condition in the Applcability of the associated LCO p ior to the performance or ompletion of a Surveillance. A urveillance that could n be performed until after enter'ng the LCO Applicability uld have its Frequency specifi such that it is not "due" until the specific conditions n eded are met. Alternately, the Surveillance may be state in the form of a Note as not required (to be met or perfo ed) until a particular event, condition, or time has bee reached. Further discussion of the specific formats of S ' annotation is found in Section 1.4, Frequency. SR 3.0.4 is only appli able when entering MODE 3 from DE 4, MODE 2 from MODE or 4, or MODE 1 from MODE 2. Furthermore, SR 3.0 4 is applicable when entering a other specified conditi in the Applicability only whil operating in MOD 1, 2, or 3. The requirements SR 3.0.4 do not apply i MODES 4 and 5, or in other spe fied conditions o the Applicability (unless in MO E 1, 2, or 3) because th ACTIONS of individual Specifica ions sufficien y define the remedial measures o be taken. SR 3.0.5 SR 3.0.5 establishes the applicability of each Surveillance to both Unit 2 and Unit 3 operation. Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the SR. Dresden 2 and 3 B 3.0-17 Revi si oX

PAM Instrumentation B 3.3.3.1 BASES LCO 9. Torus Water TemDerature (continued) Torus water temperature is a Type A and Category I variable provided to detect a condition that could potentially lead to containment breach and to verify the effectiveness of ECCS actions taken to prevent containment breach. The torus water temperature instrumentation allows operators to detect trends in torus water temperature in sufficient time to take action to prevent steam quenching vibrations in the torus. Sixteen temperature sensors are arranged in two groups of eight sensors in independent and redundant channels, located such that there are two sensors (one inner and one outer) located in each of the four quadrants to assure an accurate measurement of bulk water temperature. The range of the torus water temperature channels is 00 F to 300 0F. Thus, two groups of sensors are sufficient to monitor the bulk average temperature of the torus water. Each group of eight sensors is averaged to provide two bulk temperature inputs for PAM. The averaged temperatures are recorded on two independent recorders in the control room. Both of these recorders must be OPERABLE to furnish two channels of PAM indication. These recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels. APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4. and 5. plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS Note 1 hay been added to the AC IONS to exclude the DE change r striction of LCO 3.0 . This exception al ?ws entry into the applicable MO while relying on th ACTIONS even ough the ACTIONS may eventually require p1 nt shut wn. This exception is acceptable due to e passive fu tion of the instru nts, the operator's a (continued) Dresden 2 and 3 B 3.3.3.1-7 Revision

PAM Instrumentation B 3.3.3.1 BASES ACTIONS iagnose accident using a rnattve instrumen an (continued) method . and thfelow probabi ity of an event re uiring these S Note i has been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered. subsequent divisions, subsystems, components. or var-iahles expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function. A.1 When.one or more Functions have one required channel that is inoperable, the required inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channels or remaining isolation barrier (in the case of primary containment penetrations with only one PCIV), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval. B.1 If a channel has not been restored to OPERABLE status in 30 days. this Required Action specifies initiation of action in accordance with Specification 5.6.6. which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability and identifies proposed restorative actions. This Required Action is appropriate in lieu of a shutdown (continued) I Dresden 2 and 3 B 3.3.3.1-8 Revisio Xj

RCS Specific Activity B 3.4.6 BASES ACTIONS A.] and A.2 (continued) every 4 hours. In addition, the specific activity must be restored to the LCO limit within 48 hours. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 48 hour Completion Time to restore the activity level provides a reasonable time for temporary coolant-activity increases (iodine spikes-or crud bursts) to be cleaned up with the normal processing systems. A Note to the equired Actions of Condition A excludes the (-{- ") MODE chang restriction of LCO 3.0./ This exceptio allows entry i the applicable MODE(S)Ahile relying on he L.A ACTIO sh ow even This A a ehpv s dccepLaure oue to tfle i jj uirS laaent significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at. or proceeds to power operation. B.1. B.2.1. 1.2.2.1. and 8.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to s 0.2 pCi/gm within 48 hours. or if at any time it is > 4.0 pCi/gm. it must be determined at least once every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 and GDC 19 of 10 CFR 50. Appendix A (Ref. 3) during a postulated MSLB accident. Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4. the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without (continued) Dresden 2 and 3 B 3.4.6-3 Revision

Shutdown SOC System-Hot SDC System - Hot Shutdown B 3.4.7 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 are (continued) discussed in LCO 3.4.8. "Shutdown Cooling (SDC) System-Cold Shutdown"; LCO 3.9.8. "Shutdown Cooling (SDC)-High Water Level"; and LCO 3.9.9, "Shutdown Cooling (SDC)-Low Water Level." ACTIONS A Note to the ACTIONS;excludes t e MODE change restriction of LCO 3 .4. This exception agqows entry into the applica e MODE while relying n the ACTIONS even t ough the ACTIO may eventually requi e plant shutdown. T 5 exce tion is acceptable du to the redundancy of the OPEABLE subsystems, the jow pressure at which he plant is o ertig. the low probX ility of an event o ~rring during / Mprain in this condtlion. and the avai aiity of emethods o*'decay heat removal c pbility. A g Note has been provided to modify the ACTIONS relate to SDC subsystems. Section 1.3. Completion Times. specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable SDC subsystem. A.1. A.2. and A.3 With one required SDC subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced SDC capability. Therefore, an alternate method of decay heat removal must be provided. (continued) Dresden 2 and 3 B 3.4.7-3 Revision

ECCS - Operating B 3.5.1 BASES (continued) APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1. 2. and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is < 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2. "ECGS- Shutdown." ACTIONS A.1 If any one LPCI pump is inoperable, the inoperable pump must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE pumps provide adequate imcri core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE LPCI subsystems, concurrent with a LOCA, may result in the LPCI subsystems not being able to perform their intended safety function. The 30 day Completion Time is based on a reliability study cited in Reference 10 that evaluated the impact on ECCS availability, I assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowable repair times (i.e.. Completion Times). B.1 If a LPCI subsystem is inoperable for reasons other than Condition A or a CS subsystem is inoperable, the inoperable low pressure ECCS injection/spray subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However. overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 10) that evaluated the impact on I ECCS availability, assuming various components and (continued) Dresden 2 and 3 B 3.5.1-6 Revisio

IC Sy'stem B 3.5.3 BASES BACKGROUND Transfer System. Since during operation of the IC System, (continued) water in the shell will boil, the condenser is vented to the atmosphere via one line. APPLICABLE The function of the IC System is to respond to main steam SAFETY ANALYSES line isolation events by providing core cooling to the reactor. Although the IC System is an Engineered Safety Feature System, no credit is taken in the accident analyses for IC System operation. Based on its contribution to the reduction of overall plant risk, the system satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii). LCO The OPERABILITY of the IC 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. The IC System reduces the loss of RPV inventory during an isolation event. APPLICABILITY The IC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig. ' since IC is the primary non-ECCS 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, IC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient core cooling. ACTIONS 'LA._ and A.2 If the IC System is inoperable during MODE 1. or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to be OPERABLE, the IC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the IC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified immediately when the IC System is inoperable. This may be performed as an administrative check, by examining logs or (continued) Dresden 2 and 3 B 3.5.3-2 Revision

AC Sources-Operating B 3.8.1 BASES APPLICABILITY intended to allow declaring of the opposite unit's (continued) Division 2 supported equipment inoperable either in lieu of declaring the opposite unit's Division 2 source inoperable, or at any time subsequent to entering ACTIONS for an inoperable opposite unit Division 2 source. This exception is acceptable since, with the opposite unit powered Division 2 equipment inoperable and the associated ACTIONS entered, the opposite unit Division 2 AC sources provide no additional assurance of meeting the above criteria. The AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS A Note has been added to the ACYIONS to exclude the MOE change re/triction of LCO 3.0. for the opposite uni 's AC electri l power sources. T s exception allows en ry into the ap icable MODE while rlying on the ACTIONS en though the A IONS may eventuall require a plant shutd wn. This all ance is acceptabl due to the low probabi ty of an event requiring the posite unit equipment. A.1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered. Required Action A.2, which only applies if the division cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single failure of the associated DG does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., (continued) Dresden 2 and 3 B 3.8.1-7 Rev ision

DRESDEN BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.' These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE I for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified --conditions-of the-Applicability when -aSurveillance-has-not-been-performed -within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, IC SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable IC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable IC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable unit or common DG. The note allows application of LCO 3.0.4.b to the opposite unit DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable unit or common DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. With an opposite unit DG inoperable, the risk increase of entering a MODE or other specified condition in the Applicability is smaller and can be assessed on a case-by-case basis.

ATTACHMENT 5E Markup of Technical Specification Bases Pages LASALLE COUNTY STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-5 B 3.0-6 B 3.0-16 B 3.0-17 B 3.3.3.1-7 B 3.3.3.2-3 B 3.4.7-3 B 3.4.7-4 B 3.4.7-5 B 3.4.8-3 B 3.4.9-3 B 3.5.1-6 B 3.5.3-3 B 3.6.3.1-4 B 3.8.1-7

LCO Applicability B 3.0 BASES LCO 3.0.3 assemblies in the spent fuel storage pool." Therefore, this (continued) LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of "Suspend movement of fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 aLC .0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an L is not met. It pecludes placing the unit in a MODE or other specified nondition stated in that Applicrbility (e.g., Applicablity desired to be entered) we n the following ex/ t:/

a. Unit Coditions are such that the re urements of the LOould not be met in the Applic ility desired to b nered; and/

b. oniued noncompliance with t C0 requirements, if unit being required to exit he Applicability desired to be entered to comply wi the Required Actions.

Compliance with Required Acti ns that permit continued operation of the unit for a unlimited period of time in a MODE or other specified co dition provides an acceptable level of safety for conti ued operation. This is witho regard to the status of he unit before or after the M E change. Therefore, in such cases, entry into a MODE r other specified condi ion in the Applicability may e made in accordance with e provisions of the Required ctions. The provisions of is Specification should notate interpreted as edorsing the failure to exerci e the good practice of res oring systems or components o OPERABLE status before ntering an associated MODE other specified condition i the Applicability. The prov ions of LCO 3.0.4 shall no prevent changes in MODES or other specified condition in the Applicability that are required to comply with A TIONS. In addition, the (continued) LaSalle 1 and 2 B 3.0-5 Revi si on

LCO Applicability B 3.0 BASES LCO 3.0.4 provisions of LCO 3.0.4 shall not prevent changes in MODES (continued) or other specified conditions in the Applicability that result from any unit shutdown. Exceptions to LCO 3.0.4 are stated in the individ 1 Specifications. The ceptions allow entry into ODES or other specified cond ions in the Applicability when the associated ACTIONS o be entered do not provid for continued operati for an unlimited period time. Exceptions may a ply to all the ACTIONS or o a specific Required Actio of a Specification. Surveillanc do not have to be perform d on the associated inoperable equipment (or on variables utside the specified limits), s permitted by SR 3.0.1. T erefore, changing MODES or other specified conditions/hile in an ACTIONS Condit' n, either in compliance wi dh LCO 3.0.4, or where an excep ion to LCO 3.0.4 is stated/is not a violation of SR .0.1 or SR 3.0.4 for those rveillances that do not have to be performed due to th associated inoperable equipment. However, SRs mus be met to ensure OPERABIL Y prior to declaring the asso iated equipment OPERABLE (pr variable within limits) a restoring compliance wit the affected LCO. LCO 3.0.4 is only app cable when entering MODE from MODE 4, MODE 2 from MODE or 4, or MODE 1 from MODE2. Furthermore, LCO 3 0.4 is applicable when en t ing any other specified conditj n in the Applicability onl while operating in MO E 1, 2, or 3. The require nts of LCO 3.0.4 do not apply } MODES 4 and 5, or in othe specified conditions the Applicability (unless n MODE 1, 2, or 3) because the ACTIONS of individual Spe fications sufficiently define the remedial measures to be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or (continued)

LaSalle 1 and 2 B 3.0-6 Revision g

SR Applicability B 3.0 BASES SR 3.0.3 of the delay period. If a Surveillance is failed within the (continued) delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 .0.4 establishes the requirement that all applicaei 3R must be met before entry into a MODE or other specifiedl condition in the / licability.l This Specificat'o ensures that system and com oet OPERABILITY re uirements and variable limits ak met before entry into M ES or other specified condition in the Applicabili for which these systems and co ponents ensure safe oper ion of the unit. The pr isions of this Specification sh ld not be interr eted as endorsing the failure exercise the good prac ice of restoring systems or co onents to OPERABLE st us before entering an associat d MODE or other specified c ndition in the Applicability. However, in certain circumsta es, failing to meet an SR will not result in SR 3.0.4 estricting a MODE change or other specified condition ange. When a system, subsyste division, component, devi e, or variable is inoperable or outside its specified li7its, the associated SR(s) are l required to-be performyd per SR 3.0.1 which states th / Surveillances do not ave to be performed on inoper le equipment. When e ipment is inoperable, SR 3.0. does not apply to the asso; ated SR(s) since the require nt for the SR(s) to be per rmed is removed. Therefore, ailing to perform the Sukveillance(s) within the speci ed Frequency, on equipment hat is inoperable, does not r sult in an SR 3.0.4 restr ction to changing MODES or o er specified condition of the Applicability. Howe r, since the LCO is not me ~nthis instance, LCO 3.0.4 11 govern any restr ctions that may (or may not) pply to MODE or other ein changes. (continued) LaSalle 1 and 2 8 3.0-16 Revision,0

SR Applicability B 3.0 BASES SR 3.0.4 The provisions of SR 3.0.4 shall not prevent changes in (continued) MODES or other specif ed conditions in the Applicabi ity that are required t comply with ACTIONS. In addit dn, the provisions of SR 3 0.4 shall not prevent changes i MODES or other specified nditions in the Applicability at result from any unit s tdown. The precise quirements for performance of s are specified s ch that exceptions to SR 3.0.4 e not necessary The specific time frames and c nditions necessar for meeting the SRs are specifi d in the Freque y, in the Surveillance, or both. This allows perfo mance of Surveillances when the erequisite conk tion(s) specified in a Surveilla ce procedure require e ry into the MODE or other specifi d condition in the oplicability of the associated LC prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after en ering the LCO Applicability would have its Frequency spec'ied such that it is not "due" until the specific conditio needed are met. Alternately the Surveillance may be st ed in the form of a Note as ot required (to be met or p formed) until a particular ev nt, condition, or time has een reached. Further discussyon of the specific formats o SRs' annotation is found in Section 1.4, Frequen . SR 3.0.4 is only pplicable when entering MODE from MODE 4, MODE 2 from DE 3 or 4, or MODE 1 from MOD 2. Furthermore, 3.0.4 is applicable when ent ing any other specified c dition in the Applicability ory while operating jn MODE 1, 2, or 3. The requir ients of SR 3.0.4 do not aply in MODES 4 and 5, or in ot _r specified conditi ns of the Applicability (unles/ in MODE 1, 2, or 3) becau the ACTIONS of individual Sp ifications sufficiently define the remedial m sures to be taken. SR 3.0.5 SR 3.0.5 establishes the applicability of each Surveillance to both Unit 1 and Unit 2 operation. Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the SR. LaSalle 1 and 2 B 3.0-17 Revisiono

PAM Instrumentation B 3.3.3.1 BASES LCO 9. Suppression Pool Water Temperature (continued) well has two thermocouples. Each channel receives input from the thermocouples in 7 wells for a total of 14 thermocouples. A channel is considered OPERABLE if it receives input from at least one OPERABLE thermocouple from each of the 7 wells. The thermocouples are distributed throughout the pool area so as to be able to redundantly detect a stuck open safety/relief valve continuous discharge into the pool. The output for each channel of sensors is recorded on an independent recorder in the control room. These recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels. APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS ot as een added to the ACTIO,NS to exclude the MODE change re riction of LCO 3.0.4. /This exception allows entry i o the applicable MODE ile relying on the ACTIO even t ough the ACTIONS may e entually require plant shut wn. This exception i acceptable due to the p sive fun tion of the instrumen s, the operator's abilit to di gose an accident us'n alternate instrumentsn i hds, and the low / bability of an event qing these instruments./, _ A Note has W been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required (continued) LaSalle 1 and 2 B 3.3.3.1-7 Revisio j

Remote Shutdown Monitoring System B 3.3.3.2 BASES (continued) ACTIONS A Note is included that excludes /he MODE change rest tion of LC j..4. This exception aj ows entry into an/\

                 . applical MODE while relying/on the ACTIONS even, ogh the ACIOS ayevntaly requ i e a plant shutdown. j~is exXpio i acetble weto the low probabi Xy         of an      /

e'ent requiring this s tem. The Remote Shutdown Monitoring System is inoperable when each required function is not accomplished by at least one designated Remote Shutdown Monitoring System channel that satisfies the OPERABILITY criteria for the channel's Function. These criteria are outlined in the LCO section of the Bases. ( ,Notetg has been provided to modify the ACTIONS related to J Remote Shutdown Monitoring System Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown Monitoring System Functions provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown Monitoring System Function. A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown Monitoring System is inoperable. This includes any required Function listed in Reference 2. The Required Action is to restore the Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. (continued) LaSalle 1 and 2 B 3.3.3.2-3 Revisio

RCS Leakage Detection Instrumentation B 3.4.7 BASES APPLICABLE shut down the reactor for further investigation and SAFETY ANALYSES corrective action. The allowed LEAKAGE rates are well below (continued) the rates predicted for critical crack sizes (Ref. 6). Therefore, these actions provide adequate response before a significant break in the RCPB can occur. RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii). LCO The drywell floor drain sump flow monitoring system is required to quantify the unidentified LEAKAGE from the RCS. Thus, for the system to be considered OPERABLE, the floor drain sump fillup rate monitor portion of the system must be OPERABLE. The other monitoring systems provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded. APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.5. This Applicability is consistent with that for LCO 3.4.5. ACTIONS A.1 With the drywell floor drain sump flow monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage. However, the drywell atmospheric activity monitor and the drywell air cooler condensate flow rate monitor will provide indications of changes in leakage. With the drywell floor drain sump flow monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 12 hours (SR 3.4.5.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still availa Require Ac 1oA.1 is zmodifith by a Note that states that the provisions/of LCO 3 .4 are not applicably/ As a result, a MO change is ah rywell(oor drain sump flo m toring (continued) LaSalle 1 and 2 B 3.4.7-3 Revi si o

RCS Leakage Detection Instrumentation B 3.4.7 BASES ACTIONS A.I (continued) sys inperabe. Thi /allowance i~s provideMduu botnstumetaton

                        /              is/1vailable to monitor R     laag.

B.1 With both gaseous and particulate drywell atmospheric monitoring channels inoperable (i.e., the required drywell atmospheric monitoring system), grab samples of the drywell atmosphere shall be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 12 hours, the plant may continue operation since at least one other form of drywell leakage detection (i.e., air cooler condensate flow rate monitor) is available. The 12 hour interval provides periodic information that is adequate to detect LEAKAGE. With the required drywell air cooler condensate flow rate monitoring system inoperable, SR 3.4.7.1 is performed every 8 hours to provide periodic information of activity in the drywell at a more frequent interval than the routine Frequency of SR 3.4.7.1. The 8 hour interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action to be not applicable if the required drywell atmospheric monitoring system is inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment. D.1 and D.2 With both the gaseous and particulate drywell atmospheric monitor channels and the drywell air cooler condensate flow rate monitor inoperable, the only means of detecting LEAKAGE is the drywell floor drain sump flow monitor. This (continued) LaSalle 1 and 2 B 3.4.7-4 Revision'

RCS Leakage Detection Instrumentation B 3.4.7 BASES ACTIONS D.1 and D.2 (continued) Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated to monito r akage.time If aye Required Actio of onds are mod ifBi ed by a0 Note acesvtha the provisions of LCa3.0.4 are not ap le. As a reswith a MODE chan lowed when both tho Tous and pal iculate primary conare rena based on oring channo s and air cooler c densate flow rate are operable. Thi 1llowance is provi e~d because other instru en at'o i E.1 and E.2 If any Required Action of Condition AbB,n C, or D cannot be met 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 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions in an orderly manner and without challenging plant systems. With all required monitors inoperable, no required automatic means of monitoring LEAKAGEae pplavailable, and immediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE The Surveillances are modified by a Note to indicate that REQUIREMENTS when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours, provided the other required instrumentation (the drywell sump flow monitoring system, drywell atmospheric monitoring channel, or the drywell air cooler condensate flow monitoring system, as applicable) is OPERABLE. Upon (continued) LaSalle 1 and 2 B 3.4.7-5 Revi si on (O

RCS Specific Activity B 3.4.8 BASES ACTIONS A.1 and A.2 (continued) restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. iAnote to the RequiremActin of Condition A ex cfdes the MODE. grange restriction o KCO 3.0.4. This ex eption allows entr/ into the applica 1 MODE(S while relyin on the t-- ACZIONS even though the ACTIONS may eventually require plant sh hs epabledue to t~he activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to power operation. B.1. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to < 0.2 pCi/gm within 48 hours, or if at any time it is > 4.0 pCi/gm, it must be determined at least every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident. Alternately, the plant can be brought to MODE 3 within 12 hours and to MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for bringing the plant to MODES 3 and 4 are reasonable, based on (continued) LaSalle 1 and 2 .B 3.4.8-3 Revi si on0

RHR Shutdown Cooling System-Hot Shutdown B 3.4.9 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 are (continued) discussed in LCO 3.4.10, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.8, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.9, "Residual Heat Removal (RHR)-Low Water Level." ACTIONS A Note tp the ACTIONS excludes th MODE change restriction of LCO .0.4. This exception al ows entry into the appli ble MODE while relying n the ACTIONS even th ugh the ACTI S may eventually requir plan>'shutdown. Th' exce tion i-s-acceptable due to the redundancy of e OP ABLE subsystems, the 1 w pressure at which t e plant is o rating, the low proba lity of an event occ ring during operation in this cond ion, and the availab ity of lternate methods of ecay heat removal ca bility. A Note has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem. A.1. A.2. and A.3 With one RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the. OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore an alternate method of decay heat removal must be provided. (continued) LaSalle 1 and 2 .B 3.4.9-3 Revi sion

ECCS-Operating B 3.5.1 (continued) BASES APPLICABILITY piping. In MODES 2 and 3, the ADS function is not required (continued) when pressure is

150 psig because the low pressure ECCS subsystems (LPCS and LPCI) are capable of providing flow into the RPV below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown.

ACTIONS A-d If any one low pressure ECCS injection/spray subsystem is inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE subsystems concurrent with a LOCA may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 12) that evaluated the impact on ECCS availability by assuming that various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times). B.1 and B.2 If the HPCS System is inoperable, and the RCIC System is immediately verified to be OPERABLE (when RCIC is required to be OPERABLE), the HPCS System must be restored to OPERABLE status within 14 days. In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with the ADS. Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Immediate verification of RCIC OPERABILITY is therefore required when HPCS is inoperable and RCIC is required to be OPERABLE. This may be performed by an administrative check, by examining logs or other information, to determine if RCIC is out of service for maintenance or other reasons. It is not necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System. However, if the OPERABILITY (continued) LaSalle 1 and 2 .B 3.5.1-6 Revi si on (@

RCIC System B 3.5.3 BASES (continued) AC'rIONS r A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODES 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCS System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high RPV pressure since the HPCS System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of the HPCS is therefore immediately verified when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if the HPCS is out of service for maintenance or other reasons. Verification does not require performing the Surveillances needed to demonstrate the OPERABILITY of the HPCS System. If the OPERABILITY of the HPCS System cannot be immediately verified, however, Condition B must be entered. For transients and certain abnormal events with no LOCA, RCIC (as opposed to HPCS) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status. The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming that various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of the similar functions of the HPCS and RCIC, the AOTs (i.e., Completion Times) determined for the HPCS are also applied to RCIC. B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCS System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and reactor steam dome pressure reduced to (continued) LaSalle 1 and 2 B 3.5.3-3 Revi si onk

Containment Hydrogen Recombiners Primary Primary Containment Hydrogen Recombiners B 3.6.3.1 BASES ACTIONS A.1 (continued) Required Action A.1 has been modified by a Note statin that the provisions of LCO 3.0.4 are t applicable. As result, MODE change is allowe? when one recombine is inopera e. This allowance iUprovided because o the low probab ity of the occurrenc of a LOCA that wou d generate hydr en in amounts capabl of exceeding the fl mmability limt, the low probabilit of the failure of e OPERABLE recombiner, and the amo t of time availabl after a postulated LOCA for op rator action to pre Yent exceeding the B.1 and B.2 With two primary containment hydrogen recombiners inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour. The alternate hydrogen control capabilities are provided by the Primary Containment Vent and Purge System. The 1 hour Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. In addition, the alternate 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 alternate hydrogen control system. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control 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 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 the amounts capable of exceeding the flammability limit. (continued) LaSalle 1 and 2 B 3.6.3.1-4 Revision

AC Sources-Operating B 3.8.1 BASES APPLICABILITY allowed by this Note, the Division 3 AC sources cannot be (continued) considered as a support system to the Division 3 AC distribution subsystem. Thus, as required by LCO 3.0.2, the Distribution System-Operating ACTIONS for the inoperable Division 3 AC electrical power distribution subsystem must be entered. Note 2 has been added taking exception to the Applicability requirements for the required opposite unit's Division 2 DG in LCO 3.8.1.c, provided the associated required equipment is inoperable (i.e., one SGT subsystem, one primary containment hydrogen recombiner subsystem, one control room area filtration subsystem, and one control room area ventilation air conditioning subsystem). This exception is intended to allow declaring the opposite unit's Division 2 supported equipment inoperable either in lieu of declaring the opposite unit's Division 2 DG inoperable, or at any time subsequent to entering ACTIONS for an inoperable opposite unit Division 2 DG. This exception is acceptable since, with the opposite unit powered Division 2 equipment inoperable and the associated ACTIONS entered, the opposite unit Division 2 DG provides no additional assurance of meeting the above criteria. AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS A.1

    - 6G>      To ensure a highly reliable power source remains, it is necessary to verify the availability of the remaining required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in the Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition D, for two required offsite circuits inoperable, is entered.

Required Action A.2, which only applies if the division cannot be powered from an offsite source, is intended to (continued) LaSalle 1 and 2 B83.8.1- 7 Revision

LASALLE BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT 1 (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified ---conditions-of the-Applicability when a-Surveillance-has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCS subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCS subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, RCIC SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. -INSERT 6-(LCO-3.8.1-,-AC-SOURCES OEOPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 5F Markup of Technical Specification Bases Pages PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES (BOTH UNIT 2 AND UNIT 3 PAGES, EXCEPT AS NOTED) B 3.0-5 B 3.0-6 B 3.0-14 B 3.0-15 B 3.3-71 (Unit 2) B 3.3-72 (Unit 3) B 3.3-78 (Unit 2) B 3.3-79 (Unit 3) B 3.4-27 B 3.4-31 B 3.4-35 B 3.5-6 B 3.5-26 B 3.6-67 B 3.8-6

LCO Applicability B 3.0 BASES LCO 3.0.3 in the spent fuel storage pool." Therefore, this LCO can be (continued) applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 L .0.U establishes limitations on changes in MOf th other specified conditions in the Applicability when an LCO is not met. t precludes placing theui in a MODE or\ other specinied condition stated in plicability (e.g., Appicability desired to be ed,oud when the i following/exist:/

a. Unig conditions are such that he requirements of the LO would not be met in the Aplicability desired to

                      ,bntered; and//

b. / ontinued noncompliance wththe LCO requirements, the Applicability were etred, would result in thy unit being required to xit the Applicability des red to be entered to compl with the Required Actio

             > Compliance with Required ctions that permit conti ed operation of the unit f r an unlimited period of     me in a MODE or other specifie condition provides an ac ptable level of safety for c ntinued operation. This s without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into/a MODE or other specified c dition in the Applicabili y may be made in accordance wi     the provisions of the R uired Actions.

The provisions this Specification shou d not be interpreted as ndorsing the failure to xercise the good practice of r toring systems or compo nts to OPERABLE status befor entering an associated DE or other specified condition i the Applicability. The prov ions of LCO 3.0.4 shall ot prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the (continued) PBAPS UNIT 2 B 3.0-5 Revision No.5

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) or other specified conditions in the Applicability thit result from any u fit shutdown. Exceptions to X03.0.4 are stated in the/individual Specification/ Exceptions may apply to/all the ACTIONS or to a specifiS Required Action of a Spec ication. Surveillanes do not have to be perf med on the associated inoperabl equipment (or on variabls outside the specified limits), as permitted by SR 3.0.1. Therefore, changing MODES o other specified conditio s while in an ACTIONS Conditi n, either in compliance ith LCO 3.0.4 or where a excep on to LCO 3.0.4 is stat , is not a violation of SR 3. .1 or SR 3.0.4 for thos Surveillances that do no hay to be performed due to e associated inoperable eq pment. However, SRs mu be met to ensure OPERAB LITY p ior to declaring the ass iated equipment OPERABLE (or variable within limits) a restoring compliance wi h the affected LCO. LCO 3.0.4 is only appl'cable when entering MODE from MODE 4, MODE 2 from DE 3 or 4, or MODE 1 fro MODE 2. Furthermore, LCO 3. .4 is applicable when enering any other specified conditio in the Applicability on while operating in MODE/1, 2, or 3. The require ents of LCO 3.0.4 do not apply in ODES 4 and 5, or in oth specified conditions of e Applicability (unless/in MODE 1, 2, or 3) because the A TIONS of individual Spec fications sufficiently define the remedial measures to be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

(continued) PBAPS UNIT 2 B 3.0-6 Revision No.QS

SR Applicability B 3.0 BASES SR 3.0.3 the program in place to implement 10 CFR 50.65(a)(4) and its (continued) implementation guidance, NRC Regulatory Guide 1.182,

                'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component.

Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program. If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable'LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 Howevri ertai- r tanes u f that ai t anl S wcll must be met before entry into a MOD or other specified condition ithe Applicabil ty. W hes Specimfication ensurese that syste nd component OPER, or B T requirements and o variable itmits are met before try into MODES or other specified conditions in the Ape icability for which thase /7 systems/ad components enurY safe operation of the unit./ SuHowev e in cesta hv to bes failing to meet an S ill not Rsult in SR 3.0.4 restricting a MODE change or o fer speXcified conditio0n charge. When a system, subsystem _ divvision, component,ddice, or variable is inoper ble or outside its spe cifie /limits, the associated SR(s /are not required to be perf fmed, per SR 3.0.1, which st fes that Survillncesdo t have to be performed on i operable equipment. Whe tequipment is inoperable, SR .0.4 does not apply to the associated SR(s) since the re irement for the (continued) PBAPS UNIT 2 8 3.0- 14 Revision No.Q

SR Applicability B 3.0 BASES SR 3.0.4 SR(s) to be performed is removed. Therefore, failing to (continued) perform the Su eillance(s) within the specified Frequency does not resul in an SR 3.0.4 restriction to chan ing MODES or other spec fied conditions of the Applicabilit However, sin e the LCO is not met in this instan e, LCO 3.0.4 will overn any restrictions that may (or may not) apply to M E or other specified condition cha ges. The provi ions of this Specification should ot be interpre ed as endorsing the failure to exe cise the good practic of restoring systems or component to OPERABLE status efore entering an associated MODE or other specified conditon in the Applicability. The rovisions of SR 3.0.4 shall not p event changes in MOD S or other specified conditions i the Applicability th t are required to comply with ACT NS. In addition, the p ovisions of SR 3.0.4 shall not pr ent changes in MODES or ther specified conditions in the plicability that result from any unit shutdown. The precise requirements for per ormance of SRs are specified such that exceptions o SR 3.0.4 are not necessary. The specific time rames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillan e, or both. This allows performance of Surveillance when the prerequisite condition(s) specified in Surveillance procedure re ire entry into the MODE or ot er specified condition in t e Applicability of the ass ciated LCO prior to the per ormance or completion of a Surv illance. A Surveillance th t could not be performed until after entering the LCO Appl cability would have its Freque cy specified such that it i not "due" until the specific c nditions needed are met. ternately, the Surveillance ma be stated in the form of Note as not required (to be me or performed) until a par cular event, condition, or tim has been reached. Furthe discussion of the specific for ts of SRs' annotation is ound in Section 1.4, Fre uency. SR 3.0.4 is on y applicable when enterin MODE 3 from MODE 4, MODE from MODE 3 or 4, or MOD 1 from MODE 2. Furthermore, R 3.0.4 is applicable wh n entering any other specified c dition in the Applicabi ty only while operating MODE 1, 2, or 3. The r quirements of SR 3.0.4 do not apy in MODES 4 and 5, or i other specified conditio s of the Applicability (u ess in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. PBAPS UNIT 2 B 3.0-15 Revision No

PAM Instrumentation B 3.3.3.1 BASES (continued) LCO 11. Suppression Chamber Water Temperature (continued) inputs are averaged by the processor to provide a bulk average temperature output to the associated control room recorder. The allowance that only 10 RTDs are required to be OPERABLE for a channel to be considered OPERABLE provided no 2 adjacent RTDs are inoperable is acceptable based on engineering judgement considering the temperature response profile of the suppression chamber water volume for previously analyzed events and the most challenging RTDs inoperable. These recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels. APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS Note 1 has been added to the ACTIONS to exclude the MODE hange estriction of h LCO .0.4. This exception alls entry jto the applicable/MODE while relying on th/ACTION even ugh the ACTIONS ay eventually require plented shut en. This excepts n is acceptable due to tore passive funerson of the instrdents, the operator's aberity to din nose an accidenwsing alternative instrte nts and tiods, and the I robability of an eve requiring these mSoe 0 as been provided to modify the ACTIONS related to AM in trumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on-initial entry into the Condition. However, the Required Actions for (continued) PBAPS UNIT 2 B 3.3-71 Revision No.

Remote Shutdown System B 3.3.3.2 BASES APPLICABILITY This LCO is not applicable in MODES 3, 4, and 5. In these (continued) MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the TS do not require OPERABILITY in MODES 3, 4, and 5. ACTIONS A Note is included that excludes the MODE chang r tricti of LCO 3/.0.4. This exceptio allows entry into anZ ap pli ca leMODE while relyin on the ACTIONS evrthough the ACTIN may eventually reqM e a plant shutdown This excepzioni acceptable dyn to the low probabi iy of an eve requiring this sytM. Note @has been provided to modify the ACTIONS related to Remote Shutdown System Functions. Section 1.3, Completion

            & ,Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown System Functions provide appropriate compensatory measures for separate Functions.

As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function. LJ Condition A addresses the situation where one or more required Functions of the Remote Shutdown System is inoperable. This includes the control and transfer switches for any required function. The Required Action is to restore the Function (all required channels) to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. (continued) PBAPS UNIT 2 B 3.3-78 Revision No.

RCS Leakage Detection Instrumentation B 3.4.5 BASES ACTIONS B.1 and B.2 (continued) The 12 hour interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available. fe Required Actions are modcfied by a Note that stat that ahe pM visions of LCO ds.4/ar not apply chievAs r1hurs a MODE 4angewith 3howu.n the gaseous pltmary cTinmes are sphericbe n oringchannel isine rable. Tper allowance is provi because other instd tation is C.1 and C.2 If any 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 LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within PA 12 hours and MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems. D.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate

          - plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours is based on instrument reliability and is reasonable for detecting off normal conditions. (continued) PBAPS UNIT 2 B 3.4-27 Revision No.

Activity RCS Specific RCS Specific Activity B 3.4.6 BASES ACTIONS A.1 and A.2 (continued)

            /-    Note to the Required Actions f Condition A excludes the gr~s MODE chae restriction of LCt 3.0.4. This exceptio allows
        ,   3  entr fto the applicable MRE(S) while rearing on Jh

{14f ACTION even thoh CINS Dh may evntu1ally r tire plant hiseptable dubt n n--_ significant conservatism incorporate into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to, power operation. B.1. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT I-131 cannot be restored to < 0.2 ItCi/gm within 48 hours, or if at any time it is > 4.0 pCi/gm, it must be determined at least once every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident. Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) PBAPS UNIT 2 B 3.4-31 Revision No.

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES APPLICABILITY Additionally, in MODE 2 below this pressure, the OPERABILITY (continued) requirements for the Emergency Core Cooling Systems (ECCS) CLCO 3.5.1, "ECCS-Operating") do not allow placing the RHR shutdown cooling subsystem into operation. The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level." ACTIONS A Note to the ACTIONS excludes the MODE change restriction of LCO .0.4. This except on allows entry into the applic ble MODE(S) while elying on the ACTIONS even ough the AC IONS may eventual y require plant shutdown. his exce ion is acceptable due to the redundancy of the OPRBLE subsystems, t ie low pressure at which t~e op ating, the low pr bability of an event ocu ing ui plant is 0 fation in this co ition, and the availabi ity of~- alternate methods of decay heat removal ca g ilillty./ A rs5 Note has been provided to modify the ACTIONS re Ta-ed to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem. A.1. A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The (continued) PBAPS UNIT 2 B 3.4-35 Revision No.

ECCS-Operating B 3.5.1 BASES LCO LPCI mode and not otherwise inoperable. At these low (continued) 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. APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is

150 psig, HPCI is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. In MODES 2 and 3, when reactor steam dome pressure is
100 psig, ADS is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown."

ACTIONS A.I If any one low pressure ECCS injection/spray subsystem is inoperable, or if one LPCI pump in each subsystem is inoperable, all inoperable subsystems must be restored to OPERABLE status within 7 days (e.g., if one LPCI pump in each subsystem is inoperable, both must be restored within 7 days). In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 9) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times). (continued)

                                                                       .1--

PBAPS UNIT 2 B 3.5-6 Revision No.

RCIC System B 3.5.3 BASES (continued) ACTIONS /LaAA.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore immediately verified when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be verified immediately, however, Condition B must be immediately entered. For certain transients and abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status. The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e., Completion Times) determined for HPCI are also applied to RCIC. B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and reactor steam dome pressure reduced to

150 psig within 36 hours. The allowed Completion Times (continuedH)

PBAPS UNIT 2 B 3.5 Revision No.

CAD System B 3.6.3.1 BASES ACTIONS AL1 (continued) 30 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in 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 availability of other hydrogen mitigatin sys I aequ red Action A.1 has been modified by a Note that Cpicaons tiat the provis ns of LCO 3.0.4 are not i appli ~le. As a result a MODE change is allowed hen 0ne or b t CAD subsystems not inoperable. This altlownce is proln dms because of th ow probability of the oci rrence of a The that would Time tenhydrogen and oxygen ia amounts o opable of exceendiente flammability limit, t amount of ime available aftey a postulated LOCA for op rtor action ont orderlythe flammannet withoutchengntheg anevent and platg ststems. Id If any Required Action cannot be met withe 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 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.3 .1.1 REQUIREMENTS This SR ensures that the pressure in the SGIG System header is d 80 psig. This ensures that ehe post-LOCA nitrogen pressure provided to the valve operators and valve seals is adequate for the SGIG System to perform its design function. The 24 hour Frequency was developed considering the importance of the'SGIG System for maintaining the containment isolation function and combustible gas control function of valves supplied by the SGIG System. The 24 hour Frequency is also considered to be adequate to ensure timely detection of any breach in the SGIG System which would render the system incapable of performing its function. (continued) PBAPS UNIT 2 B 3.6-67 Revision No.

AC Sources-Operating B 3.8.1 BASES LCO In addition, since some equipment required by Unit 2 is (continued) powered from Unit 3 sources, the DG(s) capable of supplying the Unit 3 onsite Class 1E AC electrical power distribution subsystem(s) needed to support this equipment must be OPERABLE. The OPERABILITY requirements for these DGs are the same as described above, except that each required DG must be capable of connecting to its respective Unit 3 4 kV emergency bus. (In addition, the Unit 3 ECCS initiation logic SRs are not applicable, as described in SR 3.8.1.21 Bases.) The AC sources must be separate and independent (to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical. A circuit may be connected to more than one 4 kV emergency bus division, with automatic transfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is not connected to at least three 4 kV emergency buses is required to have OPERABLE automatic transfer interlock mechanisms such that it can provide power to at least three 4 kV emergency buses to support OPERABILITY of that circuit. APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of abnormal operational transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 4 and 5 are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS < Ll To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does (continued) PBAPS UNIT 2 B 3.8-6 Revision

PEACH BOTTOM BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.' These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

PEACH BOTTOM BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4 (b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System specific activity), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due' until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, RCIC SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

LCO Applicability B 3.0 BASES LCO 3.0.3 in the spent fuel storage pool." Therefore, this LCO can be (continued) applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It precludes placing the unit in a MODE or other specified ondition stated in that Applica plity (e.g., Applicab lity desired to be entered) whe the following exis :

a. Unit c ditions are such that the requi ements of the LCO w uld not be met in the Applicabil ty desired to be e.tered; and

b. C ntinued noncompliance with the L requirements, if he Applicability were entered, w uld result in the unit being required to exit the pplicability desired to be entered to comply with t e Required Actions.

Compliance with Required Actions hat permit continued operation of the unit for an un imited period of time in a MODE or other specified condit on provides an acceptable level of safety for continue operation. This is without regard to the status of the nit before or after the MODE change. Therefore, in suc cases, entry into a MODE or other specified condition in the Applicability may be mie in accordance with the p ovisions of the Required Acti ns. The provisions of this pecification should not be interpreted as endors' g the failure to exercise th good practice of restorin systems or components to OP ABLE status before ente ng an associated MODE or ot r specified condition in the pplicability. The provision of LCO 3.0.4 shall not prev t changes in MODES or other specified conditions in th Applicability that are required to comply with ACTION~ In addition, te (continued) PBAPS UNIT 3 B 3.0-5 Revision No

LCO Applicability B 3.0 BASES LCO 3.0.4 (continued) or other specified conditions in the Applicability that\ result from aH unit shutdown. Exceptions goLCO 3.0.4 are stated in the dvidual Specificat'ons. Exceptions may apply to 11 the ACTIONS or to a specfic Required Action of a Spec' ication. Surveil ances do not have to be perf ed on the associated inoper ble equipment (or on variabl s utside the specified limit), as permitted by SR 3.0.1. T erefore, changing MOD or other specified conditio s while in an ACTIONS Co ition, either in compliance ith LCO 3.0.4 or where an exception to LCO 3.0.4 is stat d, is not a violation of SR 3.0.1 or SR 3.0.4 for thos Surveillances that do not have to be performed due to he associated inoperable equipment. However, SRs mu t be met to ensure OPERABILIT prior to declaring the ass ciated equipment OPERABLE (or variable within limits) a d restoring compliance with e affected LCO. LCO 3.0.4 is only app cable when entering MODE 3 rom MODE 4, MODE 2 from ODE 3 or 4, or MODE 1 from DE 2. Furthermore, LCO 3. .4 is applicable when enter ng any other specified conditi in the Applicability only while operating in MOD 1, 2, or 3. The requirem ts of LCO 3.0.4 do not apply in MODES 4 and 5, or in other specified conditions of he Applicability (unless MODE 1, 2, or 3) because the JCTIONS of individual Spec ications ufficienti define the remedial measures to be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

(continued) PBAPS UNIT 3 B 3.0-6 Revision No.63

SR Applicability B 3.0 BASES SR 3.0.3 place to implement 10 CFR 50.65(a)(4) and its implementation (continued) guidance, NRC Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants.' This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program. If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 SR 3.0.4 establishes the requirement t at all applicable SRs must be met before entry into a MODE r other specified condition in the Applicability. Thi Specification ensures that sys em and component OPERABI TY requirements and variabl limits are met before e ry into MODES or other specif ed conditions in the Ap icability for which these syst s and components ensure safe operation of the unit. Hoever, in certain circu tances failing to meet an will not result in SR 3.0.4 r stricting a MODE change or ther specified condition ch ge. When a system, subsys em, division, component, evice, or variable is iop able or outside its specifi limits, the associated 5 s) are not required to be per ormed, per SR 3.0.1, which/sats that Surveillances do fit have to be performed of inoperable equimen. Whs/euipment is inoperable,/ 3.0.4 doesno / appy t te asoiated SR(s) since the Requirement forth / (confntinud) Revision No.§) B 3.0-14 PBAPS UNIT 3 PBAPS UNIT 3 B 3.0-14 Revision No.-

SR Applicability B 3.0 BASES SR 3.0.4 SR~s) to be performed is removed. Therefore, failing to (continued) perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specifie conditions of the Applicability. However, since Me LCO is not met in this instance, LCO 3.0.4 will gov n any restrictions that may (or may not apply to MODE r other specified condition changes. The provisio s of this Specification should not be interpreted as endorsing tP failure to exercise t e good practice o restoring systems"or components to OP RABLE status be ore entering an associated MODE or ot r specified conditio in the Applicability. / The pr visions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the pplicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent hanges in MODES or other specified conditions in the Appli bility that result from any unit shutdown. The precise requirements for perform ce of SRs are specified such that exceptions to S 3.0.4 are not necessary. The specific time fram s and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, r both. This allows performance of Surveillances wh the prerequisite condition(s) specified in a Su veillance procedure require entry into the MODE or other pecified condition in the Applicability of the associa ed LCO prior to the performance or completion of a Surveill nce. A Surveillance that could not be performed until aft r entering the LCO Applicability would have its Frequency pecified such that it is not "due" until the specific condi ions needed are met. Alternately, the Surveillance may b stated in the form of a Note as n required (to be met o performed) until a particular eve t, condition, or time h s been reached. Further discussi of the specific format of SRs' annotation is found in Section 1.4, Freq ncy. SR 3.0.4 is onl applicable when entering MODE from MODE 4, MODE from MODE 3 or 4, or MODE 1 fro MODE 2. Furthermore, R 3.0.4 is applicable when ent ing any other specified c ndition in the Applicability ory while operating in MODE 1, 2, or 3. The requir ents of SR 3.0.4 do not apply in MODES 4 and 5, or in ot r specified conditions of the Applicability (unle in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. PBAPS UNIT 3 B 3.0-15 Revision No d)

PAM Instrumentation B 3.3.3.1 BASES LCO inputs are averaged by the processor to provide a bulk (continued) average temperature output to the associated control room recorder. The allowance that only 10 RTDs are required to be OPERABLE for a channel to be considered OPERABLE provided no 2 adjacent RTDs are inoperable is acceptable based on engineering judgement considering the temperature response profile of the suppression chamber water volume for previously analyzed events and the most challenging RTDs inoperable. These recorders are the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with this portion of the instrument channels. APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2. These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and .2. In MODES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES. ACTIONS ote has been added to the ACT heNS TI relthe MO chan estrumectaion of LCO 3. Tio exception allow entry in inthe applicable discovhile relying on the ACo even wthoilh ts, wIll tay evstually requirae ent i shutdon This exception is acce pable due t thequire functio of the instrument the operator's abilci diagngi an accident usi galternative instrumrenui nan met yS, and the low pro faility of an event iring these a Note has been provided to modify the ACTIONS related to PA diAM trumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for (continued) PBAPS UNIT 3 B 3.3-72 Revision No. 2

Remote Shutdown System B 3.3.3.2 BASES APPLICABILITY This LCO is not applicable in MODES 3, 4, and 5. In these (continued) MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the TS do not require OPERABILITY in MODES 3, 4, and 5. ACTIONS A Not is included that excl des the MODE change re riction of L 3.0.4. This excepti n allows entry into an app icable MODE while rel ngp_-the ACTIONS eve though the A IONS may eventually r quire a plant shutdown This ception is acceptabl due to the low proba ity of an event requiring this ystem.

             ~\,NNote    has been provided to modify the ACTIONS related to emo     Shutdown System Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown System Functions provide appropriate compensatory measures for separate Functions.

As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function. A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System is inoperable. This includes the control and transfer switches for any required function. The Required Action is to restore the Function (all required channels) to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room. (continued) PBAPS UNIT 3 B 3.3-79 Revision No. p

RCS Leakage Detection Instrumentation B 3.4.5 BASES ACTIONS B.1 and B.2 (continued) The 12 hour interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available. The Re uired Actions are modified by a Note that sta es tha the p ovisions of LCO 3.0. are not applicable, a resul , a MODE change is KIwed-when the gaseou primary cont inmeja-tmospheric onitoring channel is operable. Thi} allowance is provided because other i rumentation is av ilable to monitor RCS leakage. C.1 and C.2 If any 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 LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems. D.1 With all required monitors inoperable, no required automatic means of monitoring LEAKAGE are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours is based on instrument reliability and is reasonable for detecting off normal conditions. (continued) PBAPS UNIT 3 B 3.4-27 Revision No.

RCS Specific Activity B 3.4.6 BASES ACTIONS A.1 and A.2 (continued) A No to the Required Acti ns of Condition A exclude e MOD 'change restriction o LCO 3.0.4. This exceptio allows en y into th. applicab MODE(S) while relying on he

            'ACTINAS IONS eetm                            entuallr sphutdown. his             s  acceptable due to the sgn     icnt conserva ism incorporated into the specific~ f thL activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to, power operation.

B.1. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT I-131 cannot be restored to

0.2 pCi/gm within 48 hours, or if at any time it is > 4.0 pCi/gm, it must be determined at least once every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 during a postulated MSLB accident.

Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g., due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without challenging plant systems. Also, the allowed Completion Times for Required Actions B.2.2.1 and B.2.2.2 for placing the unit in MODES 3 and 4 are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. (continued) PBAPS UNIT 3 B 3.4-31 Revision No

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES APPLICABILITY Additionally, in MODE 2 below this pressure, the OPERABILITY (continued) requirements for the Emergency Core Cooling Systems (ECCS) (LCO 3.5.1, "ECCS-Operating") do not allow placing the RHR shutdown cooling subsystem into operation. The requirements for decay heat removal in MODES 4 and 5 are discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level." ACTIONS A ote to the ACTIONS excludes the MODE change rest iction of LC 3.0.4. This exception Allows entry into ths appl able MODE(S) while relyM ng on the ACTIONS e en though the CTIONS may eventually r quire plant shutdow . This ex ption is acceptable due/to the redundancy o the OP RABLE subsystems, the 1 w pressure at which the plant is oerating, the low proba finty of an event oc urring during peration in this condi ion, and the availab' ity of ___ alternate methods of de cy heat removal capablt A Note has been provided to modify the ACTIONS re TTi&to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry-into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem. A.1. A.2. and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by LCO Note 2, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The (continued) PBAPS UNIT 3 B 3.4-35 Revision No.d

ECCS-Operating B 3.5.1 BASES LCO LPCI mode and not otherwise inoperable. At these low (continued) 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. APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is

150 psig, HPCI is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. In MODES 2 and 3, when reactor steam dome pressure is s 100 psig, ADS is not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown.

ACTIONS A.J

        '9   If any one low pressure ECCS injection/spray subsystem is inoperable, or if one LPCI pump in each subsystem is inoperable, all inoperable subsystems must be restored to OPERABLE status within 7 days (e.g., if one LPCI pump in each subsystem is inoperable, both must be restored within 7 days). In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA.

However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 9) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times). (continued) PBAPS UNIT 3 B 3.5-6 Revision No.

System RCIC RCIC System B 3.5.3 BASES (continued) ACTIONS A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore immediately verified when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be verified immediately, however, Condition B must be immediately entered. For certain transients and abnormal events with no LOCA, RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status. The 14 day Completion Time is based on a reliability study (Ref. 3) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC, the AOTs (i.e., Completion Times) determined for HPCI are also applied to RCIC. B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and reactor steam dome pressure reduced to

                   < 150 psig within 36 hours. The allowed Completion Times (continued)

PBAPS UNIT 3 B 3.5-26 Revision No.X

System CAD CAD System B 3.6.3.1 BASES ACTIONS A.1 (continued) 30 day Completion Time is based on the low probability of the occurrence-of a LOCA that would generate hydrogen and oxygen in 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 availability of other hydrogen mitigating systems. I Required Action as been modified by a ote at indicates that the pro isiont uf LCO 3.0.4 are not i applicablh e As a result ap ODE change is saloweds hen or both msb subsystems aret noperable. Thi all once is pr ovaidebecause of the ime probability of the a burrence ofb a LOCAp at would gener te hydrogen and 3 oxygen amounts capaboi of exceeding todeflammability limit, e amount of time/available afterj postulated LOCA for o eator acto to event exceedin e flammability li and the availability of other hydrogen mitigating B.1 If any Required Action cannot be met withe 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 hours. The allowed Completion Time of 12 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.3.1.1 REQUIREMENTS This SR ensures that the pressure in the SGIG System header is d 80 psig. This ensures that ehe post-LOCA nitrogen pressure provided to the valve operators and valve seals is adequate for the SGIG System to perform its design function. The 24 hour Frequency was developed considering the importance of the SGIG System for maintaining the containment isolation function and combustible gas control function of valves supplied by the SGIG System. The 24 hour Frequency is also considered to be adequate to ensure timely detection of any breach in the SGIG System which would render the system incapable of performing its function. (continued) PBAPS UNIT 3 B 3.6-67 Revision No.

AC Sources-Operating B 3.8.1 BASES LCO In addition, since some equipment required by Unit 3 is (continued) powered from Unit 2 sources, the DG(s) capable of supplying the Unit 2 onsite Class lE AC electrical power distribution subsystem(s) needed to support this equipment must be OPERABLE. The OPERABILITY requirements for these DGs are the same as described above, except that each required DG must be capable of connecting to its respective Unit 2 4 kV emergency bus. (In addition, the Unit 2 ECCS initiation logic SRs are not applicable, as described in SR 3.8.1.21 Bases.) The AC sources must be separate and independent (to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practical. A circuit may be connected to more than one 4 kV emergency bus division, with automatic transfer capability to the other circuit OPERABLE, and not violate separation criteria. A circuit that is not connected to at least three 4 kV emergency buses is required to have OPERABLE automatic transfer interlock mechanisms such that it can provide power to at least three 4 kV emergency buses to support OPERABILITY of that circuit. APPLICABILITY The AC sources are required to be OPERABLE in MODES 1, 2, and 3 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of abnormal operational transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 4 and 5 are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS A1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does (continued) PBAPS UNIT 3 B 3.8-6 Revision No.

PEACH BOTTOM BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., Reactor Coolant System specific activity), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, RCIC SYSTEM) A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

ATTACHMENT 5G Markup of Technical Specification Bases Pages QUAD CITIES NUCLEAR POWER STATION, UNITS I AND 2 FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.0-5 B 3.0-6 B 3.0-16 B 3.0-17 B 3.3.3.1-8 B 3.4.5-3 B 3.4.5-4 B 3.4.6-3 B 3.4.7-3 B 3.5.1-6 B 3.5.3-3 B 3.8;1-7

LCO Applicability B 3.0 C BASES LCO 3.0.3 assemblies in the spent fuel storage pool." Therefore. this (continued) LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1. 2. or 3. there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of 'Suspend movement of fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications. LCO 3.0.4 LCD 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It prec des placing the unit in a MODE other specified con ition stated in that Applicabi ty (e.g.. ApplicabilVy desired to be entered) whe the following exist:

a. Unit co itions are such that the re irements of the LCO wo d not be met in the Applic ility desired to be e ered; and

b. ontinued noncompliance with te LCD requirements, if the Applicability were enter . would result in the unit being required to exitthe Applicability desired to be entered to comply wth the Required Actions.

Compliance with Required A ions that permit continued operation of the unit for an unlimited period of time Xn a MODE or other specified condition provides an accept le level of safety for c mtinued operation. This is w thout regard to the statu of the unit before or after e MODE change. Therefore/in such cases, entry into a DE or other specified ndition in the Applicability ay be made in accordance w' h the provisions of the Requ'red Actions. The provision of this Specification should ot be interpreted s endorsing the failure to e rcise the good practice restoring systems or compon ts to OPERABLE status before entering an associated DE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shal not prevent changes in specified conditions in the Applicability tI . I iiueu Quad Cities 1 and 2 B 3.0-5 Revi si on

LCO Applicability B 3.0 BASES LCO 3.0.4 ttare required to comply with ACTIONS. In addion t (continued) provisions of LCO 3.0 4 shall not prevent changes in MODES \ or other specified Xnditions in the Applicability that\ result from any ut shutdown./ Exceptions to 0 3.0.4 are stated in the in vidual Specification/. The exceptions allow entry into MODES or other speci ed conditions in the Applica lity when the associate ACTIONS to be entered do not rovide for continue operation for an unlimited p iod of time. Excepty ns may apply to all the ACTI' or to a specific Requi ed Action of a Specification. Surveillances do not have to be p rformed on the associated inoperable equipment (or on vari bles outside the specified limits). as permitted by SR 3. 1. Therefore, changing MODES or other specified cond ions while in an ACTIONS Condition, either in complia ce with LCO 3.0.4 or where an exception to LCO 3.0.4 is ated. is not a violation of SR 3.0.1 or SR 3.0.4 for ose Surveillances that do not have to be performed due to the associated inoperable equipment. However. S must be met to ensure OPERABILI Y prior to declaring t associated equipment OPERABLE r variable within limn s) and restoring compliance wit the affected LCO. LCO 3.0.4 is ony applicable when entering MODE from MODE

4. MODE 2 fro MODE 3 or 4. or MODE 1 from MOD 2.

Furthermore. CO 3.0.4 is applicable when en ring any other specified c ndition in the Applicability o y while operatin g MODE 1. 2. or 3. The requir rents of LCO 3.0.4 do not ply in MODES 4 and 5. or in o er specified conditions of the Applicability (unl s in MODE 1. 2. or 3) because the ACTIONS of individual specifications sufficiently define the remedial measures to be taken. LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate: (continued) Ouad Cities 1 and 2 B 3.0-6 Revision

SR Applicability B 3.0 BASES SR 3.0.3 If a Surveillance is not completed within the allowed delay (continued) period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance. Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1. SR 3.0.4 SR 3.0.4 establishes the requirement t at all applicable SRs must be met before entry into a MODE other specified condition n the Applicability. This Spe ification ensures that sy tem and component OPERABI ITY requirements and vari ble limits are met before entry nto MODES or other specif ed conditions in the Appli ability for which these Systems and components ensure saf operation of the unit. The provisions of. this Spe fication should not be interpreted as endorsing e failure to exercise the good practice of restoring sy tems or components to OPERABLE status before entering n associated MODE or other specfied condition in the Appl ability. However, in certain circumstances, failing to meet n SR will not result i SR 3.0.4 restricting a MODE ch nge or other specified ondition change. When a syste , subsystem, division, comp ent, device, or variable is i perable or outside its s ecified limits, the associated R(s) are not required to e performed per SR 3.0.1, whi states that Surveillan s do not have to be performed/on inoperable equipment When equipment is inoperably,SR 3.0.4 does not apply t the associated SR(s) since th requirement for the SR(s) Gobe performed is removed. failing to (refore, perfrm urvillnces) he ithn te specified Frequency, (continued) Quad Cities 1 and 2 B 3.0-16 RevisionX

SR Applicability B 3.0 BASES SR 3.0.4 n equipment that is inoperable, does not result in an (continued) SR 3.0.4 restriction to changing MODES or other specified conditions of the Appli ability. However, since the LCO is not met in this insta ce, LCO 3.0.4 will govern any restrictions that m (or may not) apply to MODE or other specified conditio changes. The provisions f SR 3.0.4 shall not prevent changes in MODES or othe specified conditions in the Applica lity that are re ired to comply with ACTIONS. In addtion, the provisions f SR 3.0.4 shall not prevent change in MODES or other spec fied conditions in the Applicabilit that result from any nit shutdown. The precise requirements for performance o SRs are specified such that exceptions to SR 3.0. are not necessary. The specific time frames an conditions necessary for meeting the SRs are spec ied in the Frequency, in the Surveillance, or bo h. This allows performance of Surveillances when t prerequisite condition(s) specified in a Survei ance procedure require entry into the MODE or other spec'fied condition in the Applicability of the associated CO prior to the performance or completion of a Surveillanc . A Surveillance that could not be performed until after ntering the LCO Applicability would have its Frequency sp cified such that it is not "due" until the specific condit ns needed are met. Alternately, the Surveillance may be tated in the form of a Note as no required (to be met or erformed) until a particular even condition, or time ha been reached. Further discussio of the specific format of SRs' annotation is found in Section 1.4, Frequ cy. SR 3.0.4 is onl applicable when entering MODE 3 rom MODE 4, MODE 2 fr MODE 3 or 4, or MODE 1 from MOO 2. Furthermore, SR 3.0.4 is applicable when ent ing any other specified condition in the Applicability ory while operating in MODE 1, 2, or 3. The requi ments of SR 3.0.4 do not apply in MODES 4 and 5, or in o er specified conditions of the Applicability (unl ss in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. (continued) Quad Cities 1 and 2 B 3.0-17 Revi si oX

PAM Instrumentation B 3.3.3.1 BASES (continued) ACTIONS Note 1 has been added to the ACTIO S to exclude the MODE change restriction of LCO 3.0.4. This exception allow entry into 7he applicable MODE ile relying on the A IONS even thougy the ACTIONS may ev ntually require plant shutdown./ This exception is cceptable due to the assive functio of the instruments the operator's abil y to ilia n fe an accident using/aternative inst rumens and met ~s. and the low pro bility of an even v eiring these instruments. L (i'\ Note has been provided to modify the ACTIONS related to OkJ PAM instrumentation channels. Section 1.3. Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components. or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function. A.1 When one or more Functions have one required channel that is inoperable, the required inoperable channel must be restored to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channels or remaining isolation barrier (in the case of primary containment penetrations with only one PCIV), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments). and the low probability of an event requiring PAM instrumentation during this interval. (continued) Ouad Cities I and 2 B 3.3.3.1-8 Revisior@

RCS Leakage Detection Instrumentation B 3.4.5 BASES (continued) LCO The drywell floor drain sump monitoring system is required to quantify the unidentified LEAKAGE from the RCS. Thus. for the system to be considered OPERABLE, the flow monitoring portion of the system must be OPERABLE. The other monitoring system (particulate) provides early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded. APPLICABILITY In MODES 1. 2, and 3. leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4. ACTIONS A.1 With the drywell floor drain sump monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage. However, the primary containment atmospheric particulate monitoring system will provide indication of changes in leakage. With the drywell floor drain sump monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 12 hours (SR 3.4.4.1). operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available._J Required Action A.te modifipd by a Note that staties that the/provisions oft LCO 3n0.4 are not ap cable. As a rdul t, a MOD t rnvge is lall Fed when the dry1el floor drain/sump monitori system is/inoperable. Tha allowance is Pro vided becausme other B.1 and B.2 With the primary containment atmospheric particulate mentat(continued)a monitoring system inoperable. grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information. Provided a sample is obtained _ (continued) Quad Cities 1 and 2 B 3.4.5-3 Revision

Instrumentation RCS Leakage Detection RCS Leakage Detection Instrumentation B 3.4.5 BASES ACTIONS B.1 and 8.2 (continued) and analyzed once every 12 hours, the plant may be operated for up to 30 days to allow restoration of the required monitor. The 12 hour interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available. I Required Actions are modified C N lati tate toat the provisigos of LCO 3.0.4 are plantp ustcable.As t resulti a wiDE change is allowen when the primary t continet atmospheric particX ate monitoigcanli 1noper anOe This allowance isprovided because oer Times are reasonable to mo ntor RCS leakage. to sotatuth C.1 and C.2 latmute abogh-oattleast MOD 3 withi If any 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 LCO does not apply. To achieve this statusu the plant must be brought to at least MODE 3 within 12 hours and MODE 4 within 36 hours. The allowed Completion Times are reasonable. based on operating experienced to perform the actions in an orderly manner and without challenging plant systems. D.1 With all required monitors inoperable. no required automatic means of monitoring LEAKAGE are available. and immediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE The Surveillances are modified by a Note to indicate that REQUIREMENTS when a channel is placed in an inoperable status solely for performance of required Surveillances. entry into associated Conditions and Required Actions may be delayed for up to 6 hours. provided the other required instrumentation (either the drywell floor drain sump monitoring system or the (continued) Quad Cities 1 and 2 B 3.4.5-4 Revision

RCS Specific Activity RCS Specific Activity B 3.4.6 BASES ACTIONS A.1 and A.2 (continued) every 4 hours. In addition, the specific activity must be restored to the LCO limit within 48 hours. The Completion Time of once every 4 hours is based on the time needed to take and analyze a sample. The 48 hour Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems. A-T~ioeto th Required Actions f Condition A exclud the MODE chan restriction of LC 3.0.4. This except n allows

             )      entry i o the applicable M E(S) while relying             the ACTIO     even though the A      OWS-may-eventuall    equire plant shut own,    his            ils acceptable due to the nt conservatism incorporated into Me specific            9 activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore'transient specific activity excursions while the plant remains at. or proceeds to power operation.

B.Y. B.2.1. B.2.2.1. and B.2.2.2 If the DOSE EQUIVALENT 1-131 cannot be restored to

                   < 0.2 pCi/gm within 48 hours, or if at any time it is
                   > 4.0 pCi/gm. it must be determined at least once every 4 hours and all the main steam lines must be isolated within 12 hours. Isolating the main steam lines precludes the possibility of releasing radioactive material to the environment in an amount that is more than a small fraction of the requirements of 10 CFR 100 and GDC 19 of 10 CFR 50.
                 'Appendix A (Ref. 3) during a postulated MSLB accident.

Alternatively, the plant can be placed in MODE 3 within 12 hours and in MODE 4 within 36 hours. This option is provided for those instances when isolation of main steam lines is not desired (e.g.. due to the decay heat loads). In MODE 4, the requirements of the LCO are no longer applicable. The Completion Time of once every 4 hours is the time needed to take and analyze a sample. The 12 hour Completion Time is reasonable, based on operating experience, to isolate the main steam lines in an orderly manner and without (continued) Quad Cities 1 and 2 B 3.4.6-3 Revisions

RHR Shutdown Cooling System -Hot Shutdown B 3.4.7 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 are (continued) discussed in LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System- Cold Shutdown"; LCO 3.9.8.

                   "Residual Heat Removal (RHR)- High Water Level": and LCO 3.9.9. "Residual Heat Removal (RHR) -Low Water Level."

ACTIONS A Note to the ACTIONS excludes the MODE change restriction of LCO 3.0 4. This exception aVows entry into the applicabl MODE while relying6n the ACTIONS even though the ACTIONS ay eventually requi e plant shutdown. Thi excepti n is acceptable du to the redundancy of e OPERA E subsystems, theiow pressure at which e plant is oper ing. the low pr ability of an event oc rring during ope ation in this co dition. and the availa lity of alternate methods of decay heat removal capabi A d Note has been provided to modify the ACTIONS retated to RHR shutdown cooling subsystems. Section 1.3. Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems. components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such..a. Note..has been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem. A.I. A.2. A.3. A.4. and A.5 With one RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by the LCO Note, the inoperable subsystem must be restored to OPERABLE status without delay (Required Action A.1). In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however. because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided (Required Action A.2). (continued) Quad Cities I and 2 B 3.4.7-3 Revisio @

ECCS-Operating B 3.5.1 BASES LCO the limits specified in Reference 9 could be exceeded. All I (continued) ECCS subsystems must therefore be OPERABLE to satisfy the single failure criterion required by Reference 9. I 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. Alignment and operation for decay heat removal includes: a) when the system is being realigned to or from the RHR shutdown cooling mode and; b) when the system is in the RHR shutdown cooling mode, whether or not the RHR pump is operating. 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. APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is < 150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS-Shutdown." ACTIONS ALI If any one LPCI pump is inoperable, the inoperable pump must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE pumps provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE LPCI subsystems, concurrent with a LOCA, may result in the LPCI subsystems not being able to perform their intended safety function. The 30 day Completion Time is based on a reliability study cited in Reference 10 that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowable repair times (i.e., Completion Times). (continued) Quad Cities 1 and 2 B 3.5.1-6 Revision

RCIC System B 3.5.3 BASES (continued) ACTIONS A.l and A.2 r " If the RCIC System is inoperable during MODE 1. or MODE 2 or 3 with reactor steam dome pressure > 150 psig. and the ii$j- HPCI System is immediately verified to be OPERABLE. the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore immediately verified when the RCIC System is inoperable. This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System. If the OPERABILITY of the HPCI System cannot be immediately verified, however, Condition B must be entered. For transients and certain abnormal events with no LOCA. RCIC (as opposed to HPCI) is the preferred source of makeup coolant because of its relatively small capacity, which allows easier control of the RPV water level. Therefore, a limited time is allowed to restore the inoperable RCIC to OPERABLE status. The 14 day Completion Time is based on a reliability study (Ref. 2) that evaluated the impact on ECCS availability. assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and RCIC. the AOTs (i.e.. Completion Times) determined for HPCI are also applied to RCIC. B.1 and B.2 If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System is simultaneously inoperable, the plant must be brought to a condition in which the LCO does not apply. To achieve this (continued) Quad Cities 1 and 2 B 3.5.3-3 Revision

AC Sources-Operating B 3.8.1 BASES APPLICABILITY A Note has been added taking exception to the Applicability (continued) requirements for the opposite unit's AC electrical power sources in LCO 3.8.1.c and d, provided the associated required equipment (SGT subsystem, CREV System (Unit 2 only), and Control Room Emergency Ventilation AC System (Unit 2 only)) is inoperable. This exception is intended to allow declaring of the opposite unit's supported equipment inoperable either in lieu of declaring the opposite unit's source inoperable, or at any time subsequent to entering ACTIONS for an inoperable opposite unit source (should the opposite unit's supported equipment be declared inoperable following entry into LCO 3.8.1.c or d, the allowed outage time for the opposite unit equipment begins when the exception is invoked). This exception is acceptable since, with the opposite unit powered equipment inoperable and the associated ACTIONS entered, the opposite unit AC sources provide no additional assurance of meeting the above criteria. The AC power requirements for MODES 4 and 5 and other conditions in which AC sources are required are covered in LCO 3.8.2, "AC Sources-Shutdown." ACTIONS A Note ha been added to the ACTIO S to exclude the M E change r striction of LCO 3.0.4 or the opposite uni s AC electr~ al power sources. Thi exception allows e ry into the a plic6-Te MODE while re ing on the ACTIONS yen though the CT1ONS may eventually equire a plant shu own. This allowance is acceptable ue to the low proba lity of an event requiring the opposite unit equipmen To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered. (continued) Quad Cities 1 and 2 B 3.8.1-7 Revisio

QUAD CITIES BASES INSERTS INSERT I (LCO 3.0.4 BASES) LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c. LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, 'Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability. LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

INSERT I (cont'd.) The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented. The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LtO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable. LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant-specific approval. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

INSERT 2 (SR 3.0.4 BASES) SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability. A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with LCO 3.0.4. However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified -conditions-of the -Applicability when a-Surveillance has -not been -performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE I to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4. The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

INSERT 3 (RCS SPECIFIC ACTIVITY BASES) A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. INSERT 4 (LCO 3.5.1, ECCS - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 5 (LCO 3.5.3, RCIC SYSTEM) A Note prohibits the application of LCO 3.04.b to an inoperable RCIC system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC system and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. INSERT 6 (LCO 3.8.1, AC SOURCES - OPERATING) A Note prohibits the application of LCO 3.0.4.b to an inoperable unit or common DG. The note allows application of LCO 3.0.4.b to the opposite unit DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable unit or common DG and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance. With an opposite unit DG inoperable, the risk increase of entering a MODE or other specified condition in the Applicability is smaller and can be assessed on a case-by-case basis.

Attachment 6 Justification for Additional Flexibility Regarding Opposite Unit Emergency Diesel Generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station 1.0 Introduction TSTF-359, as approved, requires removal of current exceptions that allow mode changes with inoperable equipment. Although the TSTF allows mode changes with inoperable equipment based on a risk assessment, the TSTF restricts the ability to use the risk assessment by excluding a small subset of systems and components that have been determined to be more important to risk. The TSTF lists emergency diesel generators (EDGs) as one of these systems and components more important to risk. However, the TSTF also states, 'Individual plants may perform plant specific assessments along with their respective Owners Groups reports to justify additional flexibility beyond the generic flexibility provided by this TSTF." The Technical Specifications (TS) for the two dual unit sites at Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, currently allow mode changes with the opposite unit's emergency AC electrical power sources inoperable. The analysis presented below provides a justification for allowing the use of a risk assessment to change modes with the opposite unit's EDG inoperable at DNPS and QCNPS. 2.0 Proposed Change for DNPS and QCNPS The approved TSTF includes a note in the Actions section of TS 3.8.1, that states, "LCO 3.0.4.b is not applicable to DGs." The proposed change is to modify the TSTF wording for the TS 3.8.1 note to state, "LCO 3.0.4.b is not applicable to the unit and common DGs, but is applicable to the opposite unit DG." This note would have the effect of allowing LCO 3.0.4.b to be used in cases in which the opposite unit DG is inoperable. The TS Bases will be revised to explain this revised note and its basis. 3.0 Background DNPS and QCNPS TS Section 3.8.1, "AC Sources - Operating," LCO parts c and d, require that the following alternating current (AC) electrical power sources be operable in Modes 1, 2, and 3.

c. One qualified circuit between the offsite transmission network and the opposite unit's Division 2 onsite Class 1E AC electrical power distribution subsystem capable of supporting the equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System," LCO 3.7.4, "Control Room Emergency Ventilation (CREV) System" (Unit 3 only for DNPS and Unit 2 only for QCNPS), and LCO 3.7.5, "Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 3 only for DNPS and Unit 2 only for QCNPS); and

d. The opposite unit's DG capable of supporting the equipment required to be OPERABLE by LCO 3.6.4.3, LCO 3.7.4 (Unit 3 only for DNPS and Unit 2 only for Page 1 of 4

Attachment 6 Justification for Additional Flexibility Regarding Opposite Unit Emergency Diesel Generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station QCNPS), and LCO 3.7.5 (Unit 3 only for DNPS and Unit 2 only for QCNPS). Section 3.8.1 is currently modified by a note that states, "LCO 3.0.4 is not applicable for the opposite unit's AC electrical power sources." This note regarding LCO 3.0.4 allows entry into the applicable mode while relying on the actions even though the actions may eventually require a plant shutdown. The TS Bases state that this allowance is acceptable due to the low probability of an event requiring the opposite unit equipment. The requirements described above were incorporated into the DNPS and QCNPS TS during the conversion to the Industry Standard Improved Technical Specifications as approved by the NRC in References 1 and 2. The basis for the requirements stated in LCO 3.8.1, parts c and d, is as follows. The Class I E unit AC distribution system is, for the most part, divided into redundant load groups (Divisions 1 and 2), so loss of any one group does not prevent the minimum safety functions from being performed. The exception is that the opposite unit's AC electrical power distribution system provides power to some shared loads. Specifically, for the standby gas treatment (SGT) system, the emergency power source for one of the two shared trains is the opposite unit's emergency power source. The shared control room emergency ventilation (CREV) system and CREV air conditioning system are single train systems that are powered only from a single motor control center (Unit 2 for DNPS and Unit I for QCNPS). The requirements stated in parts c and d ensure that emergency power is available to both trains of SGT and that one source of emergency power is available to the CREV system. 4.0 Technical Basis for Proposed Change Description of DNPS and QCNPS Electrical Distribution Systems The sources of power to the safety-related buses at DNPS and QCNPS consist of the following.

Offsite power sources as described in the Updated Final Safety Analysis Report, Section 8.3.
Three emergency DGs (EDGs) as required in TS. This includes one EDG dedicated to each unit that automatically aligns to the unit's Division 2 emergency buses and a common EDG that automatically aligns to the affected unit's Division 1 emergency buses upon a loss of offsite power.
Two diesel generators (DGs) installed to meet the requirements of 10 CFR 50.63, "Loss of all alternating current power." Specifically, each unit has a station black out (SBO)

DG that is capable of being aligned to either of the unit's emergency buses if no EDG is aligned to that emergency bus. A unit's SBO DG has approximately 50% greater capacity than an EDG, and a unit's SBO DG may be aligned to a unit emergency bus and then simultaneously cross-tied to supply power to the opposite unit. The electrical distribution system provides considerable flexibility such that multiple AC sources are available to power safety-related equipment. The safety-related 480-volt buses that provide power to the SGT system and the CREV system can receive power from their own division emergency power sources (offsite, EDG, and SBO DG), from the same division on the opposite Page 2 of 4

Attachment 6 Justification for Additional Flexibility Regarding Opposite Unit Emergency Diesel Generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station unit via a 4 kilovolt cross-tie, and from the opposite division on the same unit via a 480 volt cross-tie. This provides significant redundancy and diversity in the available power sources. Procedures are in place to implement each of these power source lineups. Risk Analysis The following quantitative and qualitative risk arguments show that the proposed changes to the TSTF regarding the opposite unit EDG would not result in mode changes that would place DNPS or QCNPS in a situation of significant risk. Because the basis for the current TS requirement for the opposite unit EDG is to supply power to the SGT and CREV systems, it is appropriate to review the risk significance of these two systems. The risk metrics used to gauge the importance of plant changes using the probabilistic risk analysis (PRA) are core damage frequency (CDF) and large early release frequency (LERF). The SGT and CREV systems are designed to process the design radioactive leakage from the containment after a design basis accident. Because severe accident damage states used in PRA so far exceed the design basis accident conditions used for the SGT and CREV systems, relatively little mitigation is credited for these systems and therefore they are not included in the PRA. That is, unavailability of the SGT and CREV systems has no impact on the CDF and LERF calculated and used as indicators of severe accident risk in the plant-specific PRAs. Because operability of the SGT and CREV systems is the primary reason for consideration of the opposite unit EDG in TS 3.8.1, it is seen that the opposite unit EDG for support of these systems also has no significant impact on the risk metrics of CDF and LERF. Thus, the current exception to TS 3.0.4 for TS 3.8.1 can be retained for the opposite unit EDG without significant increase in plant risk. Although the PRA models do not include the SGT or CREV systems, the opposite unit EDG itself is included because of its ability to power other equipment able to be used for mitigation of severe accidents. For example, at DNPS, the opposite unit EDG may be used to power a control rod drive make-up pump that can be cross-tied into the CRD system of the affected unit for reactor pressure vessel injection. At QCNPS, the opposite unit EDG may be used to power the common safe shutdown makeup pump that can be tied into the feedwater system for the affected unit for reactor pressure vessel injection. The risk importance of the opposite unit EDG can be determined by setting this opposite unit EDG unavailable and re-calculating the CDF in the PRA model. For DNPS and QCNPS, the risk importance, i.e., risk achievement worth (RAW), associated with setting the opposite unit EDG unavailable is much lower than the RAW value of two typically considered for risk significance. This low risk importance of the opposite unit EDG is expected due to the large complement of equipment available at DNPS and QCNPS. As noted above, there are three EDGs and two SBO DGs located on site, and significant crosstie capability exists for each facility. Further, both DNPS and QCNPS have systems for accident mitigation that do not rely on AC power for short-term operation (i.e., the isolation condenser at DNPS and the reactor core isolation Page 3 of 4

Attachment 6 Justification for Additional Flexibility Regarding Opposite Unit Emergency Diesel Generator for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station cooling system at QCNPS). Thus, the low individual risk importance of the opposite unit EDG at DNPS and QCNPS is not the result of modeling assumptions, but results from significant defense-in-depth installed against loss of AC power. The risk of allowing a mode change with the opposite unit EDG inoperable is further reduced by considering the limited time (i.e., 7 days) that this EDG can be inoperable in Modes 1, 2, and 3 in accordance with TS. 5.0 Relationship to Current Licensing Basis As noted above, the DNPS and QCNPS TS currently allow mode changes with the opposite unit's required AC power sources inoperable. This allowance was approved in References 1 and 2 for DNPS and QCNPS, respectively. The basis for the allowance (i.e., the low probability of an event requiring the opposite unit equipment) is not changed by this amendment request. The proposed changes provide additional controls compared to the current licensing basis, since a risk assessment will be required to demonstrate that the mode change with inoperable opposite unit power sources is acceptable. 6.0 Conclusion The above analysis shows that from either the specific TS viewpoint of the SGT and CREV systems, or the more general viewpoint of PRA, the transition into Modes 3, 2, or 1 with the opposite unit EDG alone being unavailable will not result in significant risk increase. The proposed revision to the TSTF is consistent with the intent of the TSTF, and provides additional controls compared to the current licensing basis. Thus, the proposed revision to TSTF-359 is acceptable. 7.0 References

1. Letter from U. S. NRC to 0. D. Kingsley (Exelon Generation Company, LLC), "Issuance of Amendments," dated March 30, 2001

2. Letter from U. S. NRC to O. D. Kingsley (Exelon Generation Company, LLC), "Issuance of Amendments," dated March 30, 2001 Page 4 of 4}}

RS-04-067, Amergen, Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

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3.0 REGULATORY ANALYSIS

6.0 REFERENCES

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RS-04-067, Amergen, Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

Text

Subject:

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

6.0 REFERENCES

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