RS-19-054, Application to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control

Application to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control

ML19169A146
Person / Time
Site:	Dresden, Clinton
Issue date:	06/18/2019
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-19-054
Download: ML19169A146 (42)

Text

4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 65 7 2000 Office RS-19-054 10 CFR 50 .90 June 18, 2019 U.S . Nuclear Regulatory Commission ATTN: Document Control Desk Washington , D.C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

Subject:

Application to Revise Technical Specifications Following Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" References : 1. Letter from NRC to B. C. Hanson (Exelon Generation Company, LLC (EGC),

"Clinton Power Station , Unit No. 1 - Issuance of Amendment to Revise Technical Specifications to Adopt Technical Specifications Task Force Traveler TSTF-542, Revision 2, 'Reactor Pressure Vessel Water Inventory Control,"' dated March 22, 2018

2. Letter from NRC to B. C. Hanson (EGC), "Dresden Nuclear Power Station, Unit Nos. 2 and 3 - Issuance of Amendments to Facility Operating License Nos. DPR-19 and DPR-25 to Revise Technical Specifications to Adopt Technical Specifications [Task Force Traveler] TSTF-542, Revision 2,

'Reactor Pressure Vessel Water Inventory Control ,"' dated January 8, 2018 Pursuant to 10 CFR 50.90, EGC is submitting a request for an amendment to the Technical Specifications (TS) for Clinton Power Station (CPS), Unit 1, and Dresden Nuclear Power Station (DNPS), Units 2 and 3.

The proposed changes modify existing TS requirements following the adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel Water Inventory Control," as discussed in the referenced letters. provides a description and assessment of the proposed changes. Attachments 2 and 3 provide the existing TS pages marked to show the proposed changes for CPS and DNPS, respectively. Attachments 4 and 5 provide the existing TS Bases pages marked to

June 18, 2019 U.S. Nuclear Regulatory Commission Page 2 show the proposed changes for information only for CPS and DNPS, respectively.

The proposed changes have been reviewed and recommended for approval by the CPS and DNPS Plant Operations Review Committees in accordance with the EGC Quality Assurance Program .

Approval of the proposed amendments is requested by June 18, 2020. Once approved, the amendments shall be implemented within 90 days.

EGC is notifying the State of Illinois of this application for a change to the TS by sending a copy of this letter and its attachments to the designated State Official in accordance with 10 CFR 50.91 , "Notice for public comment; State consultation," paragraph (b) .

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of June 2019.

Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments: 1. Description and Assessment

2. Proposed Technical Specifications Changes for Clinton Power Station (Mark-Up)

3. Proposed Technical Specifications Changes for Dresden Nuclear Power Station (Mark-Up)

4. Proposed Clinton Power Station Technical Specifications Bases Changes (Mark-Up) - For Information Only

5. Proposed Dresden Nuclear Power Station Technical Specifications Bases Changes (Mark-Up) - For Information Only cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

Subject:

Application to Revise Technical Specifications Following Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 No Significant Hazards Consideration 4.2 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

Page 1 of 11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

DESCRIPTION Exelon Generation Company, LLC (EGC) proposes a change to the Clinton Power Station (CPS), Unit 1, and Dresden Nuclear Power Station (DNPS), Units 2 and 3, Technical Specifications (TS) requirements related to the recent adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-542, "Reactor Pressure Vessel (RPV) Water Inventory Control."

These changes consist of the deletion of Technical Specification 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," and Technical Specification 3.8.2, "AC Sources -

Shutdown," Surveillance Requirements (SRs) that are no longer necessary as a result of the utilization of NRG-approved manual controls for maintaining RPV water inventory during Modes 4 and 5.

EGC is proposing an alternative option for ensuring that functions associated with automatic isolation of reactor pressure vessel penetrations that are below the top of active irradiated fuel (TAF) on lowering RPV level are met through placing a required instrument in trip when it is found to be inoperable.

Emergency core cooling systems (ECCS) subsystems are controlled manually to maintain RPV water inventory in Modes 4 and 5. Automatic controls are likewise unnecessary for starting emergency diesel generators (EDGs) on ECCS initiation signals. Therefore, EGC is proposing to add two Technical Specification 3.8.1, "AC Source-Operating," SRs that verify that EDGs start automatically on the receipt of an ECCS initiation signal to the list of those that are not applicable in Technical Specification 3.8.2.

Other editorial changes are proposed for Technical Specification 3.5.1, "Emergency Core Cooling Systems (ECCS)-Operating," and Technical Specification 3.5.2, "Reactor Pressure Vessel Water (RPV) Inventory Control."

The proposed changes are described in detail in Sections 2.0 and 3.0 below, and in the TS markups provided in Attachments 2 and 3 for CPS, Unit 1 and DNPS , Units 2 and 3, respectively.

2.0 DETAILED DESCRIPTION The markup of the CPS, Unit 1 Technical Specification 3.3.5.2 shown in Figure 1 below shows the proposed addition of an alternative Technical Specification 3.3.5.2, Actions , Condition B, Required Action that would allow placing a non-functional penetration isolation instrument in trip in lieu of declaring the penetration flow path(s) incapable of automatic isolation and calculating the DRAIN TIME.

Page 2of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT B . As requ i red by B.1 Init i ate act i on to Immediately Required Ac t i on A . 1 place cha n nel in trip .

and re f erenced i n Table 3 . 3 . 5 . 2 - 1 . OR B . 2 . l +/- Declare assoc i ated Immed i a t e l y pe n et r at i on f l ow pat h (s ) i ncapab l e of automatic i so l at i on .

AND B. 2 . 2 Initiate action to Immed i a t e l y b c alcu l ate DRAIN TIME .

Figure 1: Representative Markup of Technical Specification 3.3.5.2 Condition B Since the required ECCS subsystems are manually controlled, SRs that verify proper flow path alignment for ECCS initiation are no longer required and proposed for deletion. CPS SR 3.5.2.5 is shown in Figure 2 below as an example of this proposal. Additional details are provided in Section 3.0 below.

aR 3 . 3 . 2.§

~lot requ i red to be Riet for systeffl vent flo 'a' paths opened under adfflinistrative oontrol.

Verify , for the required EGGS In accordance injection/spray subsysteffl , each manual , with the power operated , and autofflatic va l ve in the Surveillance flow path , that is not locked , sealed , or Frequency otherw i se secured in position , is in the Control Prograffl correct position .

Figure 2: Representative Markup of Technical Specification 3.5.2 SR Associated with ECCS Subsystem Alignment As shown in Figure 3 below, EGC proposes to clarify that it is acceptable to perform the Technical Specification 3.5.2 SR associated with verifying the operability of an ECCS injection/spray subsystem by directing subsystem flow through the full flow test return line or with normal system operation that satisfies this SR. This change is further described in Section 3.0 below. CPS, Unit 1 SR 3.5.2.6 (i.e., renumber to SR 3.5.2.5, as-proposed) is shown in Figure 3. The equivalent SR for DNPS, Units 2 and 3 is SR 3.5.2.5.

Page 3of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT SR 3 . 5 . 2 . 56 -------------------NOTES-------------------

1 . Operation may be through the full flow test return line .

2 . Credit may be taken for normal system operation that satisfies this SR .

Operate th e required ECCS injection/spray I n accordance subsystem through the reoiroulation line wi th the for ~ 10 minutes . Survei ll ance Frequency Cont r o l Pr ogram Figure 3: Representative Markup of SR for Operation of ECCS Injection/Spray Subsystem Through Full Flow Test Return Line or Normal System Operation Since, as shown in Figure 3 above, the SR imposes the operation of the required ECCS injection/spray subsystem for greater than or equal to 10 minutes whenever the ECCS subsystem(s) are being credited for meeting Limiting Condition for Operation (LCO) 3.5.2. This SR effectively verifies that the required subsystem(s) can be manually operated; therefore, as shown in Figure 4 below, EGC proposes to delete the Technical Specification 3.5.2 SRs that verify that the required ECCS injection/spray subsystem can be manually operated . CPS SR 3.5.2.8 is shown as a representative example in Figure 4. The equivalent SR for DNPS is SR 3.5.2.7.

SR 3.5.2.8 HOTE Vessel inj eoti o n/spray may be eJwluded .

Verify the required EGGS injeotion/spray In .111ooordanoe subsystem oan be manually o perated . with the Surveillance Frequency Control Program Figure 4: Representative Markup of the Proposed Elimination of the SRs that Verify the Capability of Manual Operation of the Required ECCS Injection/Spray Subsystem The DNPS, Units 2 and 3 Applicability for LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVS)," is proposed to be revised to delete the phrase, "When associated instrumentation is required to be OPERABLE per LCO 3.3.6 .1, "Primary Containment Isolation Instrumentation."

As shown in Figure 5 below, this change would clarify that DNPS LCO 3.6.1.3 is only applicable Modes 1, 2, and 3.

APPLIC ABILIT Y: MOD ES 1, 2, and 3, W~eA associated i AstrumeAtat i oA is required to be OP ERABL E per LCD 3 . 3 . 6 . 1 , "Primary GoAtaiAffiCAt IsolatioA I As t rumeA t at i oA . ~

Figure 5: Elimination of LCO 3.3.6.1 Applicability from DNPS , LCO 3.6.1.3 Page 4of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT CPS and DNPS licensed operators in the Main Control Room are responsible for manually controlling RPV inventory, and no ECCS signals are credited for automatically starting ECCS injection/spray subsystems in Modes 4 and 5. Therefore, automatic starts of EDGs on actual or simulated ECCS initiation signals in Modes 4 and 5 are likewise proposed for deletion. As shown in Figure 6 below (i.e., representative TS markup for CPS, Unit 1), EGC is proposing the elimination of the Technical Specification 3.8.1 SRs that verify EOG auto-starts on ECCS actuation signals from those listed in TS 3.8.2, SR 3.8.2.1. For CPS, the applicable SRs are SR 3.8.1.12 and SR 3.8.1.19. A similar change is proposed for DNPS , Units 2 and 3 (i.e., the addition of SR 3.8.1.13 and SR 3.8.1.19 to the SR 3.8.2.1 list of Technical Specification 3.8.1 SRs that are not applicable in Modes 4 and 5).

SR 3.8.2.1 ------------------- NOTE --------------------

The fo l lowi n g SRs are n o t requ i re d t o b e performed : SR 3 . 8 . 1 . 3 , SR 3 . 8 . 1 . 9 thr o u gh SR 3 . 8 . 1 . 1 1 , SR 3 . 8 . 1 . 13 t h rough SR 3 . 8 . 1 . 1 6 , and SR 3 . 8 . 1 . 18 , and SR 3 . 8 . 1. 1 9 .

For AC sources requ i red t o be OPERAB LE , t he followiftg SRs o f Specification 3 . 8 . 1 ,

except SR 3 . 8 . 1 . 8 , SR 3 . 8 . 1 . 12 ,

SR 3 . 8 . 1 . 17 , SR 3 . 8 . 1 . 19 , a nd SR 3 . 8 . 1 . 20 are appl i cable .+

SR 3 . 8 .1.1 SR 3 . 8 .1.7 SR 3 . 8 .1.14 SR 3 . 8 .1. 2 SR 3 . 8 .1. 9 gp, 3 . 8 .1.15 SR 3 . 8 .1. 3 SR 3 . 8 .1.1 0 SR 3 . 8 .1.1 6 SR 3 . 8 .1.4 SR 3 . 8 .1.1 1 SR 3 . 8 .1.1 8 SR 3 . 8 .1. 5 SR 3 . 8 .1.1 2 SR 3 . 8 .1.19 SR 3 . 8 .1. 6 SR 3 . 8 .1.1 3 Figure 6: Proposed Elimination of Certain TS 3.8.1 SRs from Inclusion in SR 3.8.2.1 The justification for this change is provided in Section 3.0 .

=

Background===

Following the adoption of TSTF-542, for CPS , Unit 1, and DNPS , Units 2 and 3, the required ECCS injection/spray subsystems utilized for the addition of reactor cavity or RPV inventory in Modes 4 and 5 as required by LCO 3.5.2 are manually controlled. The manual control of these subsystems involves relatively simple evolutions, including the manipulation of a small number Page 5of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT of components by licensed operators in the Main Control Room. The manual control of required ECCS injection/spray subsystems in Modes 4 and 5 was previously justified by EGC and approved by the NRC. That change was based on the fact that a draining event in Mode 4 or 5 would progress slowly when compared to a design basis loss of coolant accident (LOCA), which is assumed to occur at full power, and thus there is adequate time to take manual actions (i.e. , hours versus minutes). Adequate time to take action is assured since Technical Specification 3.5.2, Condition E, prohibits plant conditions that result in DRAIN TIMEs that are less than one hour. Therefore, there is sufficient time for the licensed operators to take manual action to respond to an unanticipated draining event through manually starting and stopping required ECCS injection/spray subsystem pump(s) or the additional method of water injection, and to manipulate valves to start, stop, and control RPV makeup flow, as required . These manual operator actions preclude any need to provide automatic ECCS initiation signals for the automatic initiation of ECCS injection/spray subsystems. Likewise, there is no need to automatically start EDGs on ECCS initiation signals to support ECCS injection/spray subsystems that are manually controlled. Licensed operators have sufficient time to identify the need to start an EOG utilizing the indications and manual controls that are available to them in the Main Control Room, if required.

3.1. Proposed Changes to CPS. Unit 1. and DNPS. Units 2 and 3. Technical Specification 3.3.5.2 For automatic isolation of RPV penetration flow paths below the TAF on RPV water level, crediting the automatic isolation of the associated RPV penetration flow paths is only acceptable if the associated Function is maintaining the automatic isolation capability for the affected RPV penetration flow path(s). If a channel credited for automatically isolating an RPV penetration flow path below the TAF is inoperable, EGC proposes an alternative Required Action that imposes the immediate initiation of action to place the channel in the tripped condition in accordance with proposed Required Action B.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to automatically isolate the penetration flow path(s) on lowering RPV level, and allow activities to continue with no further restrictions. If the remaining channel receives a trip signal , the penetration would be isolated automatically. Additionally, if both required channels were inoperable, placing both channels in trip would isolate the associated penetration(s). Alternatively, if it is not desired to place the channel(s) in trip (e.g., if placing the inoperable channel(s) in trip would result in an undesirable isolation of the associated penetration flow path(s)), Required Actions B.2.1 and B.2.2, as proposed, would require the immediate initiation of actions to declare the penetration flow path(s) incapable of automatic isolation and to include the affected penetration flow path(s) in the calculation of DRAIN TIME.

The Completion Time of "Immediately" for Required Action B.1 as proposed was selected to be consistent with the existing Required Actions . Joining unequal Completion Times with an "OR" logical connector is discouraged as it has the undesired effect of permitting the use of the longer Completion Time for any of the joined Required Actions .

With regard to the timing of calculating the DRAIN TIME, given the potential surrounding circumstances , it is desired to accomplish this action without delay, but the time necessary to complete the action may vary widely based on a number of unknowns. Thus , it may be Page 6of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT inappropriate to require the completion of the action within a specific time. In this case the acceptable presentation is for the Required Action to state "Initiate action to .. .,"

To be consistent with the TS Writer's Guide and similar Required Actions in the TS, Required Action B.2 (i.e., proposed Required Action B.2.2) is revised to state, "Initiate action to calculate DRAIN TIME ," and state its Completion Time as "Immediately." This corrects an error in TSTF-542.

3.2. An Operating ECCS Subsystem Satisfies CPS SR 3.5.2.6 (i.e .. DNPS SR 3.5.2.5)

CPS SR 3.5.2.6 currently requires operating the required ECCS subsystem for at least 10 minutes through the recirculation line. As described in the SR Bases, the purpose of the SR is to demonstrate that the subsystem is available to mitigate an event. One low pressure ECCS subsystem is typically in operation when in Mode 4 or Mode 5 to remove residual heat.

Operation of the low pressure ECCS injection/spray subsystem in the Residual Heat Removal (RHR) or Shutdown Cooling (SOC) mode for greater than 10 minutes can satisfy the TS requirement since normal system operation demonstrates that it is capable of injecting water into the RPV to mitigate an event.

The proposed change removes the phrase "through the recirculation line" from the SR and adds two notes. The first Note states that operation may be through the "test return line." The term "test return line" is more generic than "recirculation line," but otherwise provides the same intent. The second note states that credit may be taken for normal system operation that satisfies the SR The revised SR continues to ensure the ECCS injection/spray subsystem can inject water into the RPV if needed for defense-in-depth, while eliminating unnecessary testing .

3.3. Provide Optional Required Actions for Secondary Containment TS 3.5.2, Condition D, which applies when DRAIN TIME is less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, requires immediate action to isolate each secondary containment penetration flow path or verification that it can be manually isolated from the Main Control Room. In some scenarios, the CPS secondary containment isolation dampers (SCIDs) or DNPS secondary containment isolation valves (SCIVs) may be operable in accordance with LCO 3.6.4.1 and LCO 3.6.4.2 during periods when LCO 3.5.2 is applicable during Modes 4 and 5. Therefore , EGC proposes to modify Required Action D.3 to state, "Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room." This acknowledges the possibility that the CPS SCIDs or DNPS SCIVs may close automatically and provides an alternative to the requirement to verify that the valves or dampers are capable of being manually isolated from the control room. Automatic closure of the SCIDs or SCIVs provides protection equivalent to manual isolation of the SCIVs from the Main Control Room .

3.4. Correct the DNPS. LCO 3.6.1.3 Applicability and Related Changes The current Applicability of LCO 3.6.1.3, "Primary Containment Isolation Valves (PCIVS)," is Modes 1, 2, and 3, and when the associated instrumentation is required to be operable per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation." TSTF-542 revised the DNPS, Units 2 and 3 Table 3.3.6.1-1, Function 6.b, "Shutdown Cooling Isolation, Reactor Vessel Water Page 7of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT Level - Low" to relocate the Modes 4 and 5 applicability to LCO 3.3.5.2. As a result, all instruments required by LCO 3.3.6.1 are only applicable in Modes 1, 2, or 3. This effectively makes the LCO 3.6.1 .3 Applicability Modes 1, 2, and 3 for BWR/4 plants. For BWR/6 plants, certain Table 3.3.6.1 functions may be applicable in Modes 4 and 5.

The Applicability of DNPS , Units 2 and 3 LCO 3.6.1.3 is proposed to be revised to remove the phrase, "When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation," as the phrase no longer has any effect and LCO 3.6.1.3 is only applicable in Modes 1, 2, and 3. This change does not affect the application of the TS following adoption of TSTF-542.

3.5. Editorial Changes Related to the Correct Use of Acronyms According to the TS Writer's Guide, upon the first reference in each Specification or Bases to a phrase for which an abbreviation is desired to be used, use the full phrase followed by the acronym or initialism set off by parentheses. The abbreviation should be used on all subsequent references in that TS or TS Bases.

In order to be consistent with the Writer's Guide, the following changes are proposed :

• The CPS Technical Specification 3.5.1 Actions Note is proposed to be revised to define the acronym "HPCS" at the first reference to the high pressure core spray system. Further, the definition is proposed to be removed from Condition B. This error existed prior to TSTF-542 .

In CPS and DNPS Technical Specification 3.5.2, the acronym "SGT" is introduced for "Standby Gas Treatment," and the acronym is used in Required Action 0.4 .

3.6. Editorial Correction for DNPS. Technical Specification 3.5.1. Actions Condition K EGC proposes an editorial change to DNPS, Technical Specification 3.5.1, Actions Condition K.

Specifically, the ECCS acronym is incorrectly shown as ECS in the fourth Condition K scenario.

This proposed change is shown in detail in Attachment 3 on Page 3.5.1-3.

3.7. Correct Automatic Start Requirements for Diesel Generators The required ECCS injection/spray subsystem required to be operable by LCO 3.5.2 must be capable of being manually started as defense-in-depth against an unexpected draining event.

The changes associated with the adoption of TSTF-542 for CPS, Unit 1 and DNPS, Units 2 and 3 did not assume automatic actuation of the ECCS subsystem . Technical Specification 3.5.2, Required Action D.1 requires an additional method of water injection and that the required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. However, Technical Specification 3.5.2 for CPS and DNPS does not assume that the onsite standby electrical power source will start automatically on an ECCS initiation signal.

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ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT LCO 3.8.2 requires one offsite circuit and one diesel generator to be operable in Modes 4 and 5, and SR 3.8.2.1 lists the Technical Specification 3.8.1 SRs that are applicable in Modes 4 and 5.

In an oversight in TSTF-542, the TS 3.8.1 SRs that test automatic start and loading of a diesel generator on an ECCS initiation signal were not excluded from SR 3.8.2.1. The following additional Technical Specification 3.8.1 SRs are proposed to be excluded from applicability in Modes 4 and 5:

• CPS SR 3.8.1.12 (i.e., SR 3.8.13 for DNPS) and

• SR 3.8.1.19 for both CPS and DNPS These SRs test the ability of the EDGs to start automatically on an ECCS initiation signal.

These SRs are added to the list of Technical Specification 3.8.1 SRs that are not required to be met under SR 3.8.2.1. The remaining SRs will continue to ensure the AC Power sources are adequately tested.

4.0 REGULATORY EVALUATION

4.1 No Significant Hazards Consideration Analysis Exelon Generation Company, LLC (EGC) requests amendments to the Clinton Power Station (CPS), Unit 1 and the Dresden Nuclear Power Station (DNPS), Units 2 and 3, Technical Specifications (TS). The proposed amendments modify the existing requirements in the TS related to recent adoptions of Technical Specifications Task Force (TSTF) Traveler TSTF-542 ,

"Reactor Pressure Vessel Water Inventory Control (RPV WIC)." The proposed changes account for the fact that for CPS, Unit 1 and DNPS, Units 2 and 3, automatic actuation of emergency core cooling systems (ECCS) is not credited for maintaining RPV inventory in Modes 4 (i.e., cold shutdown) and Mode 5 (i.e. , refueling) and provide an alternative for responding to the failure of instruments credited for automatically isolating RPV penetrations below the top of active irradiated fuel (TAF).

Since ECCS actuation signals for maintaining RPV inventory in Modes 4 and 5 are not credited, EGC proposes to eliminate certain Surveillance Requirements associated with verifying emergency diesel generators (EDGs) start automatically on ECCS actuation signals in Modes 4 and 5.

Additionally, EGC proposes several editorial changes that do not affect the manner in which CPS, Unit 1, and DNPS, Units 2 and 3, are operated.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50 .92, "Issuance of amendment," as discussed below:

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

Response: No Page 9of11

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT The proposed change modifies existing TS requirements related to the maintenance of RPV inventory in Modes 4 and 5. Draining of RPV water inventory in Modes 4 and 5 is not an accident previously evaluated and , therefore , replacing the existing TS controls to prevent or mitigate such an event with a modified set of controls has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated . The existing and the proposed RPV WIC controls are not mitigating actions assumed in any accident previously evaluated.

The proposed changes do not affect the probability of an unexpected draining event (which is not a previously evaluated accident) or the limiting time in which an unexpected draining event could result in the reactor vessel water level dropping to the TAF . The current TS requirements are only mitigating actions and impose no requirements that reduce the probability of an unexpected draining event.

The proposed changes do not affect the consequences of an unexpected draining event (which is not a previously evaluated accident) or the current requirement to maintain an operable ECCS subsystem at all times in Modes 4 and 5. The proposed changes do not significantly affect the consequences of an unexpected draining event because the proposed Actions continue to ensure equipment is available within the limiting DRAIN TIME, and are equivalent to the current requirements.

The proposed changes reduce or eliminate some requirements that were determined to be unnecessary to manage the consequences of an unexpected draining event, such as the automatic starting of EDGs on ECCS initiation signals. These changes do not affect the consequences of any accident previously evaluated since a draining event in Modes 4 and 5 is not a previously evaluated accident and the requirements proposed for elimination are not needed to adequately respond to a draining event.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated .

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

Response: No The proposed changes replace existing TS requirements related to RPV WIC with modified requirements that will continue to protect Safety Limit 2.1 .1.3. The proposed changes will not alter the design function of the equipment involved .

The event of concern under the current requirements and the proposed changes is an unexpected draining event. The proposed changes do not create new failure mechanisms, malfunctions, or accident initiators that would cause an RPV or refueling cavity draining event or a new or different kind of accident not previously evaluated or included in the design and licensing bases.

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ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated .

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

Response: No The proposed changes modify certain existing TS requirements related to RPV WIC. The safety basis for the current RPV WIC requirements is to protect Safety Limit 2.1.1 .3. The new TS requirements continue to meet this safety basis in all respects .

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.2 Conclusion Based on the above, EGC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified .

5.0 ENVIRONMENTAL CONSIDERATION

The proposed changes would change certain requirements with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed changes do not involve: (i) a significant hazards consideration , (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

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Clinton Power Station, Unit 1, Application to Revise Technical Specifications Following the Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 2 -

PROPOSED TECHNICAL SPECIFICATIONS CHANGES FOR CLINTON POWER STATION (MARK-UP) 3.3-43a 3.5-1 3.5-7 3.5-8 3.5-10 3.8-19

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV ) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2 - 1 shall be OPERABLE.

APPLICABILITY : According to Table 3 . 3 . 5 . 2 - 1 .

ACTIONS

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

Separa te Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A. l Enter the Condition Immediately inoperable. referenced in Table 3 . 3 . 5 . 2 - 1 for the channel.

B. As required by B.1 Initiate action to Immediately Required Action A . l place channel in trip .

and referenced in Table 3 . 3 . 5 . 2 - 1. OR B . 2 . l+ Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND B.2 .2 Initiate action to Immediately Gcalculate DRAIN TIME .

C. As required by c.1 Place channel in trip . l hour Required Action A . l and referenced in Table 3 . 3 . 5 . 2 - 1.

(continued)

CLINTON 3 . 3- 43a Amendment No . ~

ECCS - Operating 3.5 . 1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS ), REACTOR PRESSURE VESSEL (RPV )

WATER INVENTORY CONTROL , 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 .

---

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

One l ow pressure coo l ant injection (LPCI ) subsystem may be inoperable during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure.

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 High Pressure Core Spray (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. l!:i: Ej'fl Pressure Core B.1 Verify by 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Spray (HPCS-t- 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 . ~

RPV Water I nventory Control 3.5.2 ACTIONS (continued )

COND I TION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> c.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and~ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> . containment boundary is capab l e of being estab l ished in l ess than the DRA I N TIME .

AND C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration f l ow path is capable of being iso l ated in less than the DRA I N TIME .

AND C.3 Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment ( SGT )

subsystem i s capable of be i ng p l aced in operat i on i n l ess than the DRA I N TI ME.

(continued )

CL I NTON 3 . 5- 7 Amendment No . .;g..e.

RPV Water I nventory Control 3.5.2 ACTIONS (continued )

COND I TION REQUIRED ACTION COMPLETION TIME D. DRA I N TI ME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D. 1 ------- NOTE --------

Required ECCS injection/spray subsystem or add i tiona l met h od of water injection s h all be capab l e of operat i ng wi t h out offsite e l ectrical power.

Initiate action to I mmed i ate l y establish an additional method of water injection wi th water sources capab l e of maintaining RPV water level > TAF for

~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> .

AN D D.2 I n i tiate action to I mmed i ate l y estab li sh secondary containment boundary .

AN D D.3 I n i tiate action to I mmed i ate l y iso l ate each secondary containment penetration f l ow path or ver i fy i t can be automatically or manua ll y iso l ated from the control room.

AND D.4 I nitiate action to I mmediate l y verify one standby gas treatmentSGT subsystem is capable of being p l aced in operation.

(continued )

CL I NTON 3 . 5- 8 Amendment No . .;g..e.

RPV Water I nventory Control 3.5.2 SURVE I LLANCE REQU I REMENTS (continued )

SURVEILLANCE FREQUENCY rn -:> c: '> c:

Not required to be met for system vent flow paths opened under administrative control.

Verify, for the required EGGS In accordance injection/spray subsystem, each manual, "*'ith the power operated, and automatic valve in the SuP1eillanee flm" path, that is not locked, sealed, or Frequency othen"ise secured in position, is in the Control Program correct position.

SR 3.5.2. 56 -------------------NOTES-------------------

1. Operation may be through the full flow test return line .

2. Credit may be taken for normal system operation that satisfies this SR .

Operate the required ECCS injection/spray I n accordance subsystem through the recirculation line with the for ~ 10 minutes . Survei ll ance Frequency Contro l Program SR 3. 5. 2 . 6:+ Verify each va l ve credited for I n accordance automatica ll y i solating a penetration flow with the path actuates to the isolation position on Survei ll ance an actua l or s i mulated isolation signal . Frequency Contro l Program L ~ ' - ' ..L .L..J Vessel inj eetion/spray may be eiwluded.

Verify the required EGGS injection/spray In l'ieeordanee subsystem ean be manually operated. with the Surveillanee Frequeney Control Program CL I NTON 3.5 - 1 0 Amendment No. ~

AC Sources ~ Shutdown 3.8.2 SURVE I LLANCE REQU I REMENTS SURVEILLANCE FREQUENCY SR 3.8.2 .1 -------------------NOTE --------------------

The following SRs are not required to be performed : SR 3 . 8 . 1 . 3 , SR 3 . 8 . 1 . 9 through SR 3 . 8 . 1 . 11 , SR 3 . 8 . 1 . 13 through SR 3 . 8 . 1 . 16 , and SR 3.8 . 1.18,---frftl:

SR 3. 8. 1. 19 .

For AC sources required to be OPERABLE , the In accordance following SRs of Specification 3. 8 . 1 , with applicab l e except SR 3 . 8 . 1 . 8 , SR 3 . 8 . 1 . 12 , SRs SR 3 . 8 . 1 . 17 , SR 3 . 8 . 1 . 19 , and SR 3 . 8 . 1 . 20 are applicable .-:-

SR 3.8.1.1 SR 3.8.1.7 SR 3.8.1.H SR 3.8.1.2 SR 3.8.1.9 SR 3.8.1.15 SR 3.8.1.3 SR 3.8.1.10 SR 3.8.1.16 SR 3.8.1.4 SR 3.8.1.11 SR 3.8.1.18 SR 3.8.1.5 SR 3.8.1.12 SR 3.8.1.19 SR 3.8.1.6 SR 3.8.1.13 CLINTON 3 . 8 - 19 Amendment No . .§.

Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications Following the Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 3 -

PROPOSED TECHNICAL SPECIFICATIONS CHANGES FOR DRESDEN NUCLEAR POWER STATION (MARK-UP) 3.3.5.2-1 3.5.1-3 3.5.2-2 3.5.2-3 3.5.2-5 3.6.1.3-1 3.8.2-3

RPV Wa t er I nven t ory Con t rol I ns t rumen t ati on

3. 3. 5. 2 3.3 INSTRUMENTATION 3 . 3 . 5. 2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3 . 3 . 5. 2 The RPV Water Inventory Contro l instrumentation for each Function in Tab l e 3 . 3 . 5. 2- 1 sha l l be OPERABLE .

APPLICABILITY : According to Tab l e 3 . 3 . 5. 2- 1.

ACTIONS NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Separate Condition entry is al l owed for each channel .

CONDITION REQUIRED ACT ION COMPLETION TIME A. One or more channels A. 1 Enter the Condition Immediate l y inoperable . referenced in Table 3 . 3 . 5. 2- 1 for the channel .

B. As required by Required 8.1 Initiate action to Immediately Action A. land place channel in trip.

referenced in Tab l e 3 . 3 . 5. 2- 1. OR B. 2. 1 Declare associated Immediate l y penetration flow path(s) incapable of automatic isolation .

AND B. 2. 2 Initiate action to Immediate l y Cbalcu l ate DRAIN TIME .

C. As required by Required C. l Place channe l in trip . 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Action A. land referenced in Table 3 . 3 . 5. 2- 1.

D. As required by 0. 1 Restore channe l t o 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Required Ac t ion A.1 OPERAB LE sta t us .

and re f erenced i n Table 3.3 . 5.2 -1.

(con ti nued)

Dresden 2 and 3 3.3.5.2 -1 Amendmen t No . 256 / 249

ECCS-Op era ti ng 3 . 5 .1 AC TIO NS CON DITIO N REQUIRED AC TI ON COMPLETIO N TI ME J. Two or more ADS J .1 Be in Mo de 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> valves in operable.

AN D J .2 Red uce reactor steam 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> dome pressure t o

.::: 150 ps i g .

K. Two or more low K.1 Ent er LCO 3 . 0 . 3 Immed i at el y pressure ECCS in j ec ti on/spray subsys t ems i noperable f or reasons ot her th an Cond i t i on C or E.

OR HP CI Sys t em and one or more ADS valves in operable .

OR One or more low pressure ECCS i nj ec ti on/spray s ubsys t ems inoperable and one or more ADS valves in operable .

OR HP CI Sys t em in operable and eit her one low press u re ft£ ~

inj ec ti on/spray subsys t em i s ECCS in operable or Co nditi on C en t ered .

Dresden 2 and 3 3.5. 1- 3 Amen dmen t No . 233 / 226

RPV Water Inventory Control

3. 5. 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C.l Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and~ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. containment boundary is capable of being established in le ss than the DRAIN TIME.

C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in le ss than the DRAIN TIME.

C.3 Verify one standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment (SGT) subsys tem is capable of being placed in operation in le ss than the DRAIN TIME.

(con tinued )

Dresden 2 and 3 3.5.2 -2 Amendment No. 256 / 249

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.l ------- NOTE --------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for

~ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

D.2 Initiate action to Immediately establish secondary containment boundary.

D.3 Initiate action to Immediately isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

D.4 Initiate action to Immediately verify one standby gas treatmentSGT subsystem is capable of being placed in operation.

(continued)

Dresden 2 and 3 3.5.2-3 Amendment No. 256 / 249

RPV Water Inventory Control

3. 5. 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY C' n ') c ') ~

~lot required to be met for system vent fl O'n' paths opened under administrative control.

Verify for the required EGGS In accordance injection/spray subsystem each manual, with the power operated, and automatic valve in the Surveillance flow path, that is not locked, sealed, or F"requency otherwise secured in position, is in the Control Program correct position.

SR 3.5.2. 4~ ------------------NOTES------------------

1. Operation may be through the full flow test return line.

2. Credit may be taken for normal system operation that satisfies this SR.

Operate the required ECCS injection /spray In accordance subsystem throug h t he rec i rcu l at i oA liA e with the for ~ 10 minutes. Surveillance Frequency Control Program SR 3.5.2. 5 Verify each va l ve cred ited for In accordance automatically i solat ing a penetration flow with the path actuates to the i solat ion position on Surveillance an actual or s imulated i solat ion s ignal . Frequency Control Program C' n ') c ') 7 ~l()TC Vessel injection/spray may be excluded.

Verify the required EGGS injection/spray In accordance subsystem can be manually operated. with the Surveillance F"requency Control Program Dresden 2 and 3 3.5.2 -5 Amendmen t No. 256/ 249

PC I Vs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3. 6. 1. 3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, WheA assoc i ated i AstrumeAtat i oA i s requ i red to be OPERA BLE per LCO 3 . 3 . 6 . 1, "Primary CoAtaiAmeAt I solatioA IAstrumeAtatioA . ~

ACTIONS

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

1. Penetration flo w paths may be unisolated intermittentl y under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

Dresden 2 and 3 3.6.1.3-1 Amendment No. 185/ 180

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. AL TERA TI ONS.

B.2 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

B.3 Initiate action to Immediately restore required DG to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 - - - - - - - - - - - - - - - - - - - NOTE.£ - - - - - - - - - - - - - - - - - - -

+.----The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.1 8~ .

2. SR 3.8.1.13 and SR 3.8.1.19 are not required to be met .Jhen associated1 EGGS subsystem(s) are not required to be OPERfd~LE per LCO 3.5.2, 11 RPV ':.'ater Inventory Control. 11 For AC sources required to be OPERABLE the In accordance SRs of Specification 3.8.1, except with applicable SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.19, SRs SR 3.8.1.20, and SR 3.8.1.21 are applicable.

Dresden 2 and 3 3.8.2-3 Amendment No. 256 / 249

Clinton Power Station, Unit 1, Application to Revise Technical Specifications Following the Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 4-PROPOSED CLINTON POWER STATION TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UP)-

For Information Only B 3.3-122h B 3.5-25 B 3.5-26 B 3.5-27 B 3.8-39

RPV Water I nventory Contro l I nstrumentation ~

B 3.3.5.2 BASES ACTIONS wi ll not resu l t in separate entry into the Condition .

(continued ) Section 1 .3 a l so specifies that Required Actions continue to app l y for each additiona l fai l ure , with Completion Times based on initia l entry into the Condition . However , the Required Actions for inoperab l e RPV Water I nventory Control instrumentation channe l s provide appropriate compensatory measures for separate inoperab l e Condition entry for each inoperab l e RPV Water I nventory Control instrumentation channe l .

A. l Required Action A. l directs entry into the appropriate Condition referenced in Tab l e 3.3 . 5 . 2 -1 . The app l icab l e Condition referenced in the Tab l e is Function dependent .

Each time a channe l is discovered inoperable , Condition A is immediate action to entered for that channe l and provides for transfer to the place the channel in appropriate subse uent Condition .

trip. With the , B.2.1, and B.2.2 inoperable channel in B. l a n d B 2 the tripped condition, RHR System I so l ation , Reactor Vessel Water Level - Low Leve l the remaining channel 3 , and Reactor Water Cl eanup System , Reactor Vessel Water will isolate the Leve l - Low Low , Leve l 2 functions are applicable when penetration flow path automatic iso l ation of the associated penetration f l ow path is credited in ca l cu l ating Drain Time . If the on low water level. If ---......' instrumentation is inoperab l e , Required Action B . l directs both channels are ..::::l.. a n i mm ed i ate de c l a r at i on t h at the associated penetration inoperable and placed f l ow path (s ) .a.LP. incapab l e of automatic isolation . Required Action dire s c a l c11 l at i on of DRAIN TIME . The in trip, the penetration ca l cu l ati cann t credit automat flow path will be affected p netra ion f l ow path~ .

....-~~~~~~ .........~~~~~~---.

isolated. Alternatively, B.2.2 initiating action to calculate Required Action B.2.1 c

• 1 to be immediately declared requires Low reactor vesse l pressure signa l s are used as permissives for the l ow pressure ECCS injection/spray subsystem manua l initiation functions. I f this permissive is inoperable ,

manua l initiation of ECCS is prohibited . Therefore , the permissive must be p l aced in the trip condition within l hour. With the permissive in the trip condition , manual initiation may be performed. Prior to p l acing the permissive in the tripped condition , the operator can take manua l contro l of the pump and the injection valve to inject water into the RPV.

The Comp l etion Time of l hour is intended to allow the operator time to eva l uate any discovered inoperabi l ities to p l ace the channe l in trip.

(continued )

CL I NTON B 3.3 -1 22h Revision No . .2..0..=.2.

RPV Water I nventory Contro l B 3.5.2 BASES SURVE I LLANCE SR 3.5.2.2 and SR 3.5.2.3 (continued )

REQU I REMENTS water l eve l is suff i cient to provide the required NPSH for the HPCS pump. Therefore , a verification that either the suppress i on poo l water l eve l is ~ 12 ft 8 i nches or the HPCS System i s a li gned to take suction from the RCIC storage tank and the RC I C storage tank contains ~ 125 , 000 avai l ab l e ga ll ons of water ensures that the HPCS System can supply makeup water to the RPV. Veri f icat i on t h at the RC I C storage tank contains ~ 125 , 000 avai l ab l e ga ll ons of water may be performed by ver i fying that the trip l ight for 1E5 1-N80 1 is on.

With regard to RC I C storage tank water level values obtained pursuant to this SR , as read from plant indication i nstrumentat i on , the specified l imit is considered to be a nomina l va l ue and therefore does not require compensation for i nstrument indication uncertainties (Ref . 2 ).

The Survei ll ance Frequency is controlled under the Survei ll ance Frequency Contro l Program .

SR 3.5.2.4 The Bases provided for SR 3.5. l . l are app l icab l e to SR 3.5.2.4.

The Survei ll ance Frequency is controlled under the Survei ll ance Frequency Contro l Program .

SR 3 5 2 5

) Te r i f ¥ i n g t h e c o rre c t a l i g nm e n t f o r ma nn a 1 1 powe r ope r ated 1 a n d a n tomat i c *ua l *ues i n t h e r eqn i r ed ECC S s nh s¥stem f l QJar pat h s p r a *u i des ass nr a nc e t h at t h e p r ope r fl ow pat h s wi 11 h e a v a i l a b l e for ECC S o pe r at i on Th is SR d o es no t app l l/ t o 1ra l *ues t h at a re l o ck ed sea l ed o r ot h e r wise sec nr ed i n r eq11 i r e aD'{ test i n g or v a l v e ma n i p 11 l at i on* r at h e r , i t i n*ua l *ues *ue r i f j c at i a n t h at t h ose v a 1 v es capa hl e o f pote n t i a ll ¥ b e i ng mi spos i t i o ned a r e i n t h e c o rre c t pos i t i o n Th i s SR does n ot app l ¥ to *ua l *ues t h at ca nn ot h e i n ad *ue r te n t l ¥ mi sa l i g n ed , s ncb as c h ec k v a lves Th e S nr*up j ll a nc p Freqn e nc ¥ i s c o n t r o ll ed nn de r t h e Snrvpj ll a n ce Freqn e nc ¥ Co n t r o l P r og r a m CL I NTON B 3.5 - 25 Revision No . .2..0..=.2.

RPV Water I nventory BASES SURVE I LLANCE SR 3 5 2 5 (c ont i nned )

REQU I REMENTS I p MODE S 4 and 5 t h e R HB Sj/stem m aj' ope r ate in t h e s hn tdown c oo l i ng mode to r e mo1 re de c a¥ heat and sensi b l e heat fr o m t h e r ea c to r Th e r e f o r e RHB 3r a l 1res t h at a r e r pqn i r ed f o r I p er s nh sj/Ste m ope r at i on maj/ h p a l i gned f o r de c aj' h eat r e mo v a l Th i s SB i s mod i f j ed h ¥ a Note Th e Note exempts Sj/Stem 1rent f l 0 1°r pat h s opened n nde r ad mi n i st r ati v e c ont r o l Th e ad mi n i st r at i *u e c o n t r o l s h o n l d h p p r o c ed nr a l i z ed a n d i n c ln de stat i o n i ng a ded i c ated i ndj-u j d n a l at t h e system v e n t fl ow pat h Jorb o i s j n c o n t j nn o n s c q mmnn ication wit h t h e ope r ato r s j n t h e c o n t r o l r oom Th i s i n d j *u jd n a l wi ll h a v e a met h od to r ap i d l ¥ c l ose t h e Sj'Stem *ue n t f l QJar pat h i f d i r e c ted This SR is modified 3.5.2 . .6. ~

by two Notes. Note 1 ing that the required ECCS injection/spray subsystem acknowledges that started and operate for at least 10 minutes testing of t the subsystem is available to mitigate a draining event. Test i n g the ECCS inject i on/spray subsystem through the fu ll f l ow test r pcj rc11 J at j on ine is adequate t conf i rm the operationa l read i ness of t h e uired ECCS i njection/spray subsystem . The minimum opera 'ng 1 0 mi nutes was based engineer i ng judgement .

Note 2 states that return credit for meeting this e Frequency is contro ll ed under the Frequency Contro l Program .

SR may be taken for normal system operation that SR 3.5.2 . .:Z. ~

satisfies this SR. Verifying that each va l ve credited for automatically i so l ating a penetrat i on f l ow path actuates to t h e isolation position on an actua l or simu l ated RPV water leve l iso l ation signa l is required to prevent RPV water inventory from dropping be l ow the TAF shou l d an unexpected draining event occur.

The Survei ll ance Frequency is controlled under the Survei ll ance Frequency Contro l Program .

(continued )

CL I NTON B 3 . 5 - 26 Revision No . .2.0.=.2.

RPV Water I nventory BASES SURVE I LLANCE SR 3 5 2 8 REQU I REMENTS (continued ) The r eqn i r ed ECC S s nh sj/Ste m s h a ll h e c apa b l e o f b e i n g man n a ll ¥ ope r ated fr om t he ma i n c ont r o l r oom Th i s Snr3rp j ll ao c e *u e r i f i es t h at t h e r eqn i r ed r c p r s nh sj/Stem Sj/Stem o r HPCS Sj/Stem (i nc l nd i ng t he asso c i ated p nmp and 1raLu e ( s )) c an h e man n a 11 ¥ ope r ated i n c l n d i ng t hr ott l i ng i nje c t i on 1ra l 1res as ne c essa r ¥ to p r o1 ri de add i t i ona l B p>r Ioiate r Tp3 rento r ¥ i f needed 1°d t h o n t de l AJl Th e S nr*u p j ll a nc p Freqn e nc ¥ i s c o n t r o ll ed nn de r t h e S nr*u p j l l a nc p Fr eqn e nc ¥ C o n t r o l Pr og r a m Th i s SR i s mod i f i ed h ¥ a Note t h at e x c ln des v esse l i n je c t i o n/ sp r a¥ d nr j n g t h e Snr*u pj ll a n ce Si n ce a ll acti v e c o mpo n e n ts a r e testa b l e a nd fn l l fl ow ca n h e demo n st r ated r p c j rcn l at i o n t hr o n g h t h e fn ll f l oJol test l i n e, c oo l a n t i n je c t i o n i n to t h e RP'U i s n ot r eqn i r ed d nr j n g t h e Snr*u e i l l a nc p REFERENCES 1. I nformation Notice 84 - 81 "I nadvertent Reduction in Primary Coo l ant I nventory in Boiling Water Reactors During Shutdown and Startup ," November 1 98 4 .

2. I nformation Notice 86 - 74 , " Reduction of Reactor Coolant Inventory Because of Misa l ignment of RHR Valves ," August 1986 .

3. Generic Letter 92 - 04 , " Reso l ution of the I ssues Related to Reactor Vessel Water Leve l I nstrumentation in BWRs Pursuant to 10 CFR 50 . 54 (f )," August 1992 .

4. NRC Bulletin 93 - 03 , " Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs ,"

May 1993 .

5. I nformation Notice 94 - 52 , "I nadvertent Containment Spray and Reactor Vessel Draindown at Mi ll stone l,"

July 1994 .

6. Genera l El ectric Service I nformation Letter No . 388 ,

" RHR Valve Misalignment During Shutdown Coo l ing Operation for BWR 3/4/5/6 ," February 1 983.

CL I NTON B 3.5 - 27 Revision No . .2..0..=.2.

AC Sources ~ Shutdown B 3.8.2 BASES ACTIONS C. l (continued )

I n the event a ll sources of power to Division 3 are l ost ,

Condition A wi ll a l so be entered and direct that t h e ACTIONS of LCO 3.8. 1 0 be taken. I f on l y the Division 3 additiona l required AC source is inoperab l e , and power is still supp l ied to HPCS , 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is a ll owed to restore the additiona l required AC source to OPERABLE . This is reasonab l e considering HPCS wi ll still perform its function ,

absent an additiona l sing l e fai l ure .

SURVE I LLANCE SR 3.8.2. 1 REQU I REMENTS SR 3.8.2. 1 requires the SRs from LCO 3.8. 1 that are necessary for ensuring the OPERABILITY of t h e AC sources in other than MODES 1, 2 , and 3. SR 3.8. 1 .8 is not required to be met s i nce on l y one offsite circuit is required to be OPERABLE. SR 3.8. 1 . 1 7 is not required to be met because t h e requ i red PERABLE DG (s ) i s not required to undergo periods of being s nchronized to the offsite circuit . SR 3.8. 1 .20 i s excepte because starting independence is not required with the D required to be OPERABLE . Refer for LCO 3.8. 1 for a d i scussion of each !reason for the I Th~ Note r:--:--1 ~ 11..o.t.e prec l ud requir i ng the from being

~ para ll e l ed w th the offs i te power network or ot h erwise rendered ino rab l e during the performance of SRs , and prec l ude de - e required 4. 1 6 kV ESF bus or disconnecting offsite circuit during performance of SRs. With sources available , a single event cou l d compromi e both the required circuit and the DG . It i s the intent hat these SRs must st ill be capab l e of be i ng met , but actua performance i s not required for any DG or offs i te circui t .

REFERENCES None .

In MODES 4 and 5 ECCS injection/spray subsystems are manually controlled in accordance with LCO 3.5 .2, "Reactor Pressure Vessel (RPV) Water Inventory Control." No ECCS initiation signals are credited for initiation of these subsystems. Adequate time is available to manually start and load DGs from the Main Control Room in support of RPV inventory control, if required .

Therefore, SR 3.8 .1.12 and SR 3 .8 .1.19, which verify the DG's capability to start automatically on actual or simulated ECCS initiation signals, are not required to be met in MODES 4 and 5.

CL I NTON B 3 . 8- 39 Revision No . ~

Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications Following the Adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 5 -

PROPOSED DRESDEN NUCLEAR POWER STATION TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UP) -

For Information Only B 3.3.5.2-7 B 3.3.5.2-11 B 3.5.2-12 B 3.5.2-13 B 3.6.1.3-4 B 3.8.2-6 B 3.8.2-7

RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES (continued)

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control 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 continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the table is Function dependent.

Each time a channel is discovered inoperable, Condition A is immediate action to entered for that channel and provides for transfer to the place the channel in appropriate subsequent Condition.

trip . With the inoperable channel in the tripped condition, B.1 aAd 8. 2 tj, B.2.1, and B.2.2 the remaining channel Shutdown cooling (SOC) system Isolation, Reactor Vessel will isolate the Water Level-Low, and Reactor Water Cleanup System, Reactor penetration flow path Vessel Water Level -Low functions are appl i cable when on low water level. If automatic isolation of the associated penetration flow path both channels are is credited in calculating Drain Time. If the inoperable and placed instrumentation is inoperable, Required Action B.1 directs aA immediate declaratioA that the associated penetration in trip, the penetration flow path(s) incapable of automatic isolation. Required flow path will be Action : dir ts calculatioA of DRAIN TIME. The isolated. Alternatively, calcul ion c nnot credit automat* isolation of the Required Action B.2.1 affect d pen tration flow path~}

requires (continued) initiating action to to be immediately declared calculate Dresden 2 and 3 B 3.3.5.2-7 Revision ~

RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.3 (continued)

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

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

R- 3. 5. 2.4 VerifyiAg the correct al igAmeAt for maAual , power operated ,

aAd au t oma ti c va l ves i A t he requ i re d EGGS subsystem f l ow path prov i des assuraAce t hat the proper flow path will be ava il ab l e for EGGS operat i oA . Th i s SR does Aot apply to va l ves that are l ocked , sea l ed , or otherwise secured iA pos i t i oA , s i Ace t hese va l ves were verified to be iA the correct pos i t i oA pr i or to l ock i Ag , sealiAg , or securiAg . A va l ve that rece i ves aA i Ai t i at i oA s i gAa l i s allowed to be iA a AOAaccideAt positioA provided the valve will automatically repos i t i oA i A t he proper stroke time . This SR does Aot requ i re aAy test i Ag or va l ve maAipulatioA ; rather , it i Avo l ves ver i ficatioA that those va l ves capab l e of poteAtia ll y beiAg mispositioAed are iA the correct positioA .

Thi s SR does Aot app l y to va l ves that caAAot be i AadverteAt l y mi sa li gAed , suc h as check valves . :i:fl.e Surve ill aAce FrequeAcy i s coAtrolled uAder the SurveillaAce FrequeAcy GoAtro l Program . The Survei ll aAce is modified by ~

a Note whi ch exempts system veAt flow paths opeAed uAder ~

(continued)

Dresden 2 and 3 B 3.5.2-11 Revision ~

RPV Water Inventory Control ~

B 3.5.2 BASES SURVEILLANCE -&R 3 . 5. 2. 4 (continued)

REQUIREMENTS administrative control . The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication 'ii'it h the operators in the control room . ffl-f-s.

individual will have a method to rapidly close the system vent flow path if directed .

SR 3.5.2. ~~

This SR is modified by two Notes. Note 1 "fying that the required ECCS injection/spray subsystem acknowledges that can be nually started and operated for at least 10 minutes testing of demonstrate hat the subsystem is available to mitigate a draining event. the ECCS injection/spray subsystem through the full flow test recirculation line is necessary to avoid overfilling the refueling cavi and adequate to Note 2 states that confirm the operational readiness of the r uired ECCS credit for meeting this injection/spray subsystem. The minimum oper ing time of SR may be taken for 10 minutes is based on eng1 eering judgement.

normal system t---------------~ return The Surveillance Frequency is controlled under operation that Survei 11 ance Frequency Control Program.

satisfies this SR.

SR 3.5.2. ~ k:--@J Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown these components usually pass the Surveillance when performed at the selected Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

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

(continued)

Dresden 2 and 3 B 3.5.2-12 Revision ~

RPV Water Inventory Control ~

B 3.5.2 BASES SURVEILLANCE -&R 3. 5. 2. 7 REQUIREMENTS (continued) Th e requ i red EGGS subsystem s hall be capab l e of be i ng manua ll y operated . Thi s Surve ill ance ver i f i es t hat t he re qui re d CS or LP CI su bsys t em (inc l ud i ng th e associa t ed pum p and va l ve(s)) can be manua ll y operated to prov i de additiona l RPV Water I nventory , i f needed .

The Surve ill ance Frequency i s contro ll ed under t he Surve ill ance Frequency Contro l Program .

Thi s SR i s mo difi ed by a Not e th at exc l udes vesse l i nject i on/spray dur i ng th e Surveillance . Si nce all act i ve components are testab l e , and fu ll f l ow can be demonstrated by recircu l at i on t hroug h t he fu ll f l ow test l ine , coo l ant i nj ec ti on i nt o th e RPV i s no t requ i re d dur i ng th e Surve ill ance .

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), "August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"

May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Dra i ndown at Mi 11 stone 1,"

July 1994.

6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6," February 1983.

Dresden 2 and 3 B 3.5.2-13 Revision ~

PC I Vs B 3.6.1.3 BASES LCO 10 CFR 50 Appendix R requirements) to be de-activated and (continued) closed, are considered OPERABLE when the valves are de-activated and closed. These passive isolation valves and devices are those listed in Reference 1.

MSIVs must meet additional leakage rate requirements. Other PCIV leakage rates are addressed by LCO 3.6.1.1, "Primary Containment," as Type B or C testing.

This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.

i APPLICABILITY In MODES 1, 2, and 3, a OBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, PCIVs are not required to be OPERABLE in MODES 4 and 5. CertaiA valves; however , are required to be OPERABLE wheA the associated iAstrumeAtatioA is required to be OPERABLE per LCO 3 . 3 . 5. 2 , "Reactor Pressure Vessel (RPV) Water IAveAtory CoAtrol IAstrumeAtatioA ." (This does Rot iAclude the valves that isolate the associated iAstrumeAtatioA . )

ACTIONS The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls. These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.

A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.

Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.

(continued)

Dresden 2 and 3 B 3.6.1.3-4 Revision ~

AC Sources-Shutdown B 3.8.2 BASES ACTIONS A.2.1. A.2.2. A.2.3. B.1. B.2. and B.3 (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power In MODES 4 and 5 ECCS to any required ESS bus, ACTIONS for LCO 3.8.8 must be injection/spray subsystems immediately entered. This Note allows Condition A to are manually controlled in provide requirements for the loss of the offsite circuit whether or not a division is de-energized. LCO 3.8.8 accordance with LCO provides the appropriate restrictions for the situation 3.5.2, "Reactor Pressure involving a de-energized division.

Vessel (RPV) Water Inventory Control." No ECCS initiation signals are SR 3.8.2.1 credited for initiation of SR 3.8.2.l requires the SRs from LCO 3.8.l that are these subsystems. necessary for ensuring the OPERABILITY of the AC sources in Adequate time is available other than MODES 1, 2, and 3 to be applicable. SR 3.8.1.9 to manually start and load is not required to be met since only one offsite circuit is EDGs from the Main required to be OPERABLE. Jt.5 R 3.8.1.20 is excepted because Control Room in support of starting independence is not required with the DG(s) that is RPV inventory control, if not required to be OPERABLE. SR 3.8.1.21 is not required to be met because the opposite unit's DG is not required to be required. Therefore, SR OPERABLE in MODES 4 and 5, and during movement of recently 3.8.1.13 and SR 3.8.1.19, irradiated fuel assemblies in secondary containment. Refer which verify the EDG's to the corresponding Bases for LCO 3.8.l for a discussion of capability to start each SR. ,.--@

automatically on actual or ¥- . ~ ~

simulated ECCS initiation This SR is modified by twe- Note~ . The reason for Note-+ is to preclude requiring the OPERABLE DG(s) from being signals, are not required to paralleled with the offsite power network or otherwise be met in MODES 4 and 5. rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESS bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event (continued)

Dresden 2 and 3 B 3.8.2-6 Revision 7-5

AC Sources-Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit are required to be OPERABLE.

Note 2 states that SRs 3 . 8 . 1. 13 and 3 . 8 . 1. 19 are not re qui re d t o be me t when it s assoc i ated EGGS su bsys t em(s) are not re qui red to be OPE RA BLE . These SRs demonstrate t he DC response to an EGGS i ni t i at i on s i gnal (e i t her alone or i n conjunction wit h a l oss of offsite power signal) . This is cons i st en t ;<i th th e EGGS i ns t rumentat i on re qui re ments t hat do not re qui re t he EGGS i ni t i at i on si gnals when the assoc i ated EGGS subsystem i s not re qui red to be OPE RA BLE. ~

REFERENCES None.

Dresden 2 and 3 B 3.8.2-7 Revision 7-5-