Text

Issuance of Amendment Nos. 231, 268, and 261; Revise Technical Specifications for Reactor Pressure Vessel Water Inventory Control Following Adoption of TSTF-542, Revision 1
	ML19351D750
Person / Time
Site:	Dresden, Clinton ; (DPR-019, DPR-025, NPF-062)
Issue date:	05/28/2020
From:	Haskell R; Plant Licensing Branch III
To:	Bryan Hanson; Exelon Generation Co
	Haskell R
References
	EPID L-2019-LLA-0124
	Download: ML19351D750 (55)
	v • d • e

May 28, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1, AND DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - ISSUANCE OF AMENDMENT NOS. 231, 268, AND 261, TO CHANGE TECHNICAL SPECIFICATIONS FOR REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL FOLLOWING ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-542, REVISION 2 (EPID L-2019-LLA-0124)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed amendments in response to the Exelon Generation Company, LLC (Exelon, the licensee) application dated June 18, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19169A146), as supplemented by letter dated December 5, 2019 (ADAMS Accession No. ML19339G992). Specifically, the enclosures include Amendment No. 231 to Facility Operating License No. NPF-62 for the Clinton Power Station (Clinton),

Unit No. 1, and Amendment Nos. 268 and 261 to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for the Dresden Nuclear Power Station (Dresden), Units 2 and 3, respectively.

The amendments revise the Clinton, Unit No. 1, and Dresden, Units 2 and 3, technical specifications (TSs) associated with TS 3.5.2, RPV [Reactor Pressure Vessel] Water Inventory Control [WIC], and TS 3.8.2, AC [Alternating Current] Sources - Shutdown, surveillance requirements considered no longer necessary following NRC-approved licensing activity at these sites. For each site, TS 3.3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation, is modified to support instrumentation functions. Additionally, edits are made to various RPV WIC-related TSs to add consistency and clarity. For Dresden, Units 2 and 3 only, a change to TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), supports Modes 4 and 5 operations.

A copy of the NRC staffs Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Russell S. Haskell II, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-461, 50-237, and 50-249

Enclosures:

1. Amendment No. 231 to NPF-62

2. Amendment No. 268 to DPR-19

3. Amendment No. 261 to DPR-25

4. Safety Evaluation cc: Listserv

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-461 CLINTON POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 231 License No. NPF-62

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 18, 2019, as supplemented by letter dated December 5, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-62 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 231, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: May 28, 2020 Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2020.05.28 16:11:36 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 231 FACILITY OPERATING LICENSE NO. NPF-62 CLINTON POWER STATION, UNIT NO. 1 DOCKET NO. 50-461 Replace the following page of Facility Operating License No. NPF-62 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert Page 3 Page 3 Replace the following pages of Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

TS TS 3.3-43a 3.3-43a 3.5-1 3.5-1 3.5-7 3.5-7 3.5-8 3.5-8 3.5-10 3.5-10 3.8-19 3.8-19

(4)

Exelon Generation Company, pursuant to the Act and to 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)

Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

Mechanical disassembly of the GE14i isotope test assemblies containing Cobalt-60 is not considered separation; and (7)

Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, to intentionally produce, possess, receive, transfer, and use Cobalt-60.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 231, are hereby incorporated into this license.

Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 231

RPV Water Inventory Control Instrumentation 3.3.5.2 CLINTON 3.3-43a Amendment No. 231216 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

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.2-1 for the channel.

Immediately B. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Initiate action to place channel in trip.

OR B.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately C. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

ECCS Operating 3.5.1 CLINTON 3.5-1 Amendment No. 231 216 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 low pressure coolant 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 injection/spray subsystem inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

7 days B.

HPCS System inoperable.

B.1 Verify by administrative means RCIC System is OPERABLE when RCIC is required to be OPERABLE.

AND B.2 Restore HPCS System to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 14 days (continued)

RPV Water Inventory Control 3.5.2 CLINTON 3.5-7 Amendment No. 231 216 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

C.1 Verify secondary containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 4 hours 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (continued)

RPV Water Inventory Control 3.5.2 CLINTON 3.5-8 Amendment No. 231 216 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

D.1

NOTE --------

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

Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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

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

AND D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

Immediately Immediately Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 CLINTON 3.5-10 Amendment No. 231 216 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In Accordance with the Surveillance Frequency Control Program

AC Sources Shutdown 3.8.2 CLINTON 3.8-19 Amendment No. 231 95 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 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and SR 3.8.1.18.

For AC sources required to be OPERABLE, the SRs of 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, and SR 3.8.1.20 are applicable.

In accordance with applicable SRs

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-237 DRESDEN NUCLEAR POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 268 Renewed License No. DPR-19

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 18, 2019, as supplemented by letter dated December 5, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-19 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 268, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: May 28, 2020 Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2020.05.28 16:12:11 -04'00'

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-249 DRESDEN NUCLEAR POWER STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 261 Renewed License No. DPR-25

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 18, 2019, as supplemented by letter dated December 5, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-25 is hereby amended to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 261, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: May 28, 2020 Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2020.05.28 16:12:53 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NOS. 268 AND 261 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249 RENEWED FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Replace the following pages of Renewed Facility Operating License Nos. DPR-19 and DPR-25 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove Insert Page 3 (DPR-19)

Page 3 (DPR-19)

Page 4 (DPR-25)

Replace the following pages of the Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

TS TS 3.3.5.2-1 3.3.5.2-1 3.3.5.2-2 3.3.5.2-2 3.5.1-3 3.5.1-3 3.5.2-2 3.5.2-2 3.5.2-3 3.5.2-3 3.5.2-5 3.5.2-5 3.6.1.3-1 3.6.1.3-1 3.8.2-3 3.8.2-3

(2)

Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear materials as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3)

Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2957 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 268, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3)

Operation in the coastdown mode is permitted to 40% power.

Renewed License No. DPR-19 Amendment No. 268

f.

Surveillance Requirement 4.9.A.10 - Diesel Storage Tank Cleaning (Unit 3 and Unit 2/3 only)

Each of the above Surveillance Requirements shall be successfully demonstrated prior to entering into MODE 2 on the first plant startup following the fourteenth refueling outage (D3R14).

3.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A.

Maximum Power Level The licensee is authorized to operate the facility at steady state power levels not in excess of 2957 megawatts (thermal), except that the licensee shall not operate the facility at power levels in excess of five (5) megawatts (thermal), until satisfactory completion of modifications and final testing of the station output transformer, the auto-depressurization interlock, and the feedwater system, as described in the licensees telegrams; dated February 26, 1971, have been verified in writing by the Commission.

B.

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 261, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

C.

Reports The licensee shall make certain reports in accordance with the requirements of the Technical Specifications.

D.

Records The licensee shall keep facility operating records in accordance with the requirements of the Technical Specifications.

E.

Restrictions Operation in the coastdown mode is permitted to 40% power.

Renewed License No. DPR-25 Amendment No. 261

RPV Water Inventory Control Instrumentation 3.3.5.2 Dresden 2 and 3 3.3.5.2-1 Amendment No. 268/261256/2499 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

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more channels inoperable.

A.1 Enter the Condition referenced in Table 3.3.5.2-1 for the channel.

Immediately B.

As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Initiate action to place channel in trip.

OR B.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately C. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

C.1 Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

RPV Water Inventory Control Instrumentation 3.3.5.2 Dresden 2 and 3 3.3.5.2-2 Amendment No. 268/261 256/249 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

D.1 Restore channel to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months E. Required Action and associated Completion Time of Condition C or D not met.

E.1 Declare associated low pressure ECCS injection/spray subsystem inoperable.

Immediately SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

ECCSOperating 3.5.1 Dresden 2 and 3 3.5.1-3 Amendment No. 268 / 26133/226 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME J.

Two or more ADS valves inoperable.

J.1 Be in Mode 3.

AND J.2 Reduce reactor steam dome pressure to

< 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours K.

Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition C or E.

OR HPCI System and one or more ADS valves inoperable.

OR One or more low pressure ECCS injection/spray subsystems inoperable and one or more ADS valves inoperable.

OR HPCI System inoperable and either one low pressure ECCS injection/spray subsystem is inoperable or Condition C entered.

K.1 Enter LCO 3.0.3 Immediately

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-2 Amendment No. 268/26156/249 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months DQGKRXUV

C.1 Verify secondary containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 4 hours 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (continued)

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

'5$,17,0(KRXUV

D.1

NOTE --------

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

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

KRXUV

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

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

AND D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

Immediately Immediately Immediately Immediately (continued)

Amendment No. 268 / 261 256/249

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-5 Amendment No. 268 / 261 256/249 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.4

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray subsystem IRU 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Dresden 2 and 3 3.6.1.3-1 Amendment No. 268 / 261 185/180 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.

ACTIONS

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

1.

Penetration flow paths may be unisolated intermittently 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.

AC SourcesShutdown 3.8.2 Dresden 2 and 3 3.8.2-3 Amendment No. 268 / 261 256/249 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

One required DG inoperable.

B.1 Suspend CORE ALTERATIONS.

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

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

Immediately Immediately Immediately 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 3.8.1.18.

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are applicable.

In accordance with applicable SRs

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 231 TO FACILITY OPERATING LICENSE NO. NPF-62 AMENDMENT NO. 268 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-19 AMENDMENT NO. 261 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-25 EXELON GENERATION COMPANY, LLC CLINTON POWER STATION, UNIT NO. 1 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-461, 50-237, AND 50-249

1.0 INTRODUCTION

By application dated June 18, 2019 (Reference 1), as supplemented by letter dated December 5, 2019 (Reference 2), Exelon Generation Company, LLC (the licensee) requested to revise technical specifications (TSs). The changes are administrative in nature to improve the implementation of Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 (Reference 3), which changed the TSs for Clinton Power Station (Clinton), Unit No. 1 and Dresden Nuclear Power Station (Dresden),

Units 2 and 3, that has been previously approved by the NRC. The final safety evaluation (SE) of TSTF-542, Revision 2, was issued by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (Reference 4). Changes to the TSs related to TSTF-542, Revision 2, for Clinton, Unit No. 1 and Dresden, Units 2 and 3 were previously approved by the NRC in 2018 (References 5 and 6, respectively).

Traveler TSTF-542, Revision 2, is related to operations with a potential for draining the reactor vessel (OPDRVs), which revised TSs by providing an alternative for Reactor Pressure Vessel (RPV) Water Inventory Control (WIC). These alternative requirements protect Safety Limit 2.1.1.3, which requires RPV water level to be greater than the top of active irradiated fuel (TAF).

The supplemental letter dated December 5, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 29, 2019 (84 FR 45542).

2.0 REGULATORY EVALUATION

2.1

System Description

The boiling-water reactor (BWR) RPV design has numerous penetrations located below the TAF. These penetrations provide entry for control rods, recirculation flow, reactor water cleanup, and shutdown cooling. These penetrations are below the TAF, creating a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During BWR operation in Mode 4 (Cold Shutdown1 - Reactor Mode Switch in Shutdown and average reactor coolant temperature 200° F (Clinton) or 212° F (Dresden)) and Mode 5 (Refueling1 - Reactor Mode Switch in Shutdown or Refuel), the TS for RPV WIC instrumentation (TS 3.3.5.2) and emergency core cooling systems (ECCS) (TS 3.5.2) require operability of sufficient equipment to ensure that water can be manually injected into the RPV should level decrease.

TS 3.5.2 requires at least one ECCS injection/spray subsystem (Clinton) or at least one low pressure ECCS injection/spray subsystem (Dresden) to be operable. For Clinton, one ECCS injection/spray subsystem is defined as either one of the three low pressure coolant injection (LPCI) subsystems (LPCI A, LPCI B, or LPCI C), one low pressure core spray system (LPCS),

or one high pressure core spray (HPCS) system. An LPCI subsystem and a LPCS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool to the RPV. The HPCS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or reactor core isolation cooling storage tank to the RPV. For Dresden, one low pressure ECCS injection/spray subsystem is defined as either of one core spray (CS) subsystem or LPCI subsystem. A CS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or contaminated condensate storage tanks (CCSTs) to the RPV. An LPCI subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or CCSTs to the RPV.

The ECCS pumps are high-capacity pumps, with flow rates of thousands of gallons per minute.

In contrast, most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gallons per minute. The manual alignment/start of an ECCS pump would provide the necessary water to replace inventory loss from expected drain rates.

2.2 Proposed TS Changes

2.2.1 Clinton, Unit No. 1 The proposed TS changes for Clinton, Unit No. 1 include:

Revise TS 3.3.5.2, RPV WIC Instrumentation, Condition B; Correct several editorial errors in TSs 3.5.1, ECCS-Operating, and 3.5.2, RPV WIC; Revise TS 3.5.2, RPV WIC; 1 One or more reactor vessel head closure bolts less than fully tensioned.

Delete TS Surveillance Requirement (SR) 3.5.2.5; Revise TS SR 3.5.2.6 and renumber to SR 3.5.2.5; Renumber TS SRs 3.5.2.7 and 3.5.2.8 to SRs 3.5.2.6 and 3.5.2.7, respectively; and Revise SR 3.8.2.1.

2.2.1.1 TS 3.3.5.2, RPV WIC Instrumentation The proposed change to TS 3.3.5.2, Condition B is shown below (proposed changes are in bold):

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Initiate action to place channel in trip.

OR B.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately 2.2.1.2 TS 3.5.1, ECCS-Operating The proposed change to TS 3.5.1 is to correct editorial items as shown below.

ACTIONS note: HPCS is changed to High Pressure Core Spray (HPCS).

CONDITION B: High Pressure Core Spray (HPCS) is changed to HPCS.

2.2.1.3 TS 3.5.2, RPV WIC The proposed change to TS 3.5.2 is to correct two editorial items and one technical item, as shown below. Bold text below shows the addition of automatically or.

REQUIRED ACTION C.3: standby gas treatment is changed to standby gas treatment (SGT);

REQUIRED ACTION D.3: Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room is replaced with Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room; and REQUIRED ACTION D.4: standby gas treatment is changed to SGT.

2.2.1.4 TS 3.5.2, RPV WIC SRs The proposed change to TS 3.5.2 is to correct SRs (including deletion of SR 3.5.2.5) as shown below.

Existing SR 3.5.2.5 through SR 3.5.2.8:

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

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

Verify, for the required ECCS injection/

spray subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.8

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In Accordance with the Surveillance Frequency Control Program Proposed change (shown in bold) to SRs (includes the deletion of SR.3.5.2.5 as shown above):

SURVEILLANCE FREQUENCY SR 3.5.2.5

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

1. Operation may be through the test return line.

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

Operate the required ECCS injection/

spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In Accordance with the Surveillance Frequency Control Program 2.2.1.5 TS 3.8.2, AC Sources - Shutdown The proposed change to TS 3.8.2 is to correct SR 3.8.2.1.

Existing SR 3.8.2.1:

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, SR 3.8.1.18, and SR 3.8.1.19.

For AC sources required to be OPERABLE, the following SRs are applicable.

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 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 In accordance with applicable SRs Proposed change to SR 3.8.2.1 (proposed changes are in bold):

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.

For AC sources required to be OPERABLE, the SRs of 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, and SR 3.8.1.20 are applicable.

In accordance with applicable SRs 2.2.2 Dresden, Units 2 and 3 The proposed TS changes for Dresden, Units 2 and 3 include:

Revise TS 3.3.5.2, RPV WIC Instrumentation, Condition B; Correct several editorial errors in TSs 3.5.1, ECCS - Operating, and 3.5.2, RPV WIC; Revise TS 3.5.2, RPV WIC; Delete TS SR 3.5.2.4; Revise TS SR 3.5.2.5 and renumber to SR 3.5.2.4; Renumber TS SRs 3.5.2.6 and 3.5.2.7 to 3.5.2.5 and 3.5.2.6, respectively; Revise TS 3.6.1.3, PCIVs; and Revise SR 3.8.2.1 2.2.2.1 TS 3.3.5.2, RPV WIC Instrumentation The proposed change to TS 3.3.5.2 CONDITION B is shown below.

Existing TS 3.3.5.2:

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME.

Immediately Immediately Proposed changes to TS 3.3.5.2 (proposed changes are in bold):

CONDITION REQUIRED ACTION COMPLETION TIME B. As required by Required Action A.1 and referenced in Table 3.3.5.2-1.

B.1 Initiate action to place channel in trip.

OR B.2.1 Declare associated penetration flow path(s) incapable of automatic isolation.

AND B.2.2 Initiate action to calculate DRAIN TIME.

Immediately Immediately Immediately 2.2.2.2 TS 3.5.1, ECCS-Operating The proposed change to TS 3.5.1 is to correct an editorial item as shown below.

CONDITION K (fourth paragraph): ECS is changed to ECCS.

2.2.2.3 TS 3.5.2, RPV WIC The proposed change to TS 3.5.2 is to correct two editorial items and one technical item, as shown below. Bold text below shows the addition of automatically or.

REQUIRED ACTION C.3: standby gas treatment is changed to standby gas treatment (SGT);

REQUIRED ACTION D.3: Initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room is replaced with, Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room; and REQUIRED ACTION D.4: standby gas treatment is deleted and replaced with SGT.

2.2.2.4 TS 3.5.2, RPV WIC SRs The proposed change to TS 3.5.2 is to correct SRs (including deletion of SR 3.5.2.4) as shown below.

Existing SR 3.5.2.4 through SR 3.5.2.7:

SURVEILLANCE FREQUENCY SR 3.5.2.4

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

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

Verify for the required ECCS injection/

spray subsystem each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5 Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.7

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program Proposed change (shown in bold) to SRs (includes the deletion of SR 3.5.2.4 as shown above):

SURVEILLANCE FREQUENCY SR 3.5.2.4

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

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/

spray subsystem for 10 minutes.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.6

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

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can be manually operated.

In accordance with the Surveillance Frequency Control Program 2.2.2.5 TS 3.6.1.3, PCIVs Existing APPLICABILITY of TS 3.6.1.3:

APPLICABILITY:

MODES 1. 2. and 3, When associated instrumentation is required to be OPERABLE per LCO [Limiting Condition for Operation] 3.3.6.1, Primary Containment Isolation Instrumentation.

The proposed change to TS 3.6.1.3 is to remove from APPLICABILITY the following:

When associated instrumentation is required to be OPERABLE per LCO [Limiting Condition for Operation] 3.3.6.1, Primary Containment Isolation Instrumentation.

2.2.2.6 TS 3.8.2, AC Sources-Shutdown The proposed change to TS 3.8.2 is to correct SR 3.8.2.1.

Existing SR 3.8.2.1:

SURVEILLANCE FREQUENCY SR 3.8.2.1

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

1. 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 3.8.1.19.

2. SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, RPV Water Inventory Control.

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.20, and SR 3.8.1.21 are applicable.

In accordance with applicable SRs Proposed change to SR 3.8.2.1 (proposed changes are in bold):

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 3.8.1.18.

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are applicable.

In accordance with applicable SRs 2.3 Applicable Regulatory Requirements The regulation at 10 CFR 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must include in the application a summary statement of the bases or reasons for such specifications, other than those covering administrative controls. However, per 10 CFR 50.36(a)(1), these TS bases shall not become part of the technical specifications.

As required by 10 CFR 50.36(c)(1), TSs will include items in the category of safety limits, limiting safety system settings, and limiting control settings. 10 CFR 50.36(c)(1)(i)(A) describes this category by stating, in part:

Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 10 CFR 50.36(c)(2), TSs will include items in the category of limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation at 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria. Specifically, Criterion 4, A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety, supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide reasonable assurance that the health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

As part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STS) for each of the light-water reactor (LWR) nuclear designs. NUREG-1434, Revision 4, Volumes 1 and 2 (References 7 and 8), contains the STS and Bases for BWR/6 plants and is applicable to Clinton. NUREG-1433, Revision 4, Volumes 1 and 2 (Reference 9 and Reference 10), contains the STS and Bases for BWR/4 plants and is applicable to Dresden, Units 2 and 3.2 TS changes described in TSTF travelers are incorporated into future revisions of the NUREGs.

The NRC staffs guidance for review of TSs is in Chapter 16, Revision 3, Technical Specifications, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP) (Reference 11).

2.3.1 Applicable Design Requirements (Clinton)

The Clinton Updated Safety Analysis Report (USAR), Section 3.1, Conformance with NRC General Design Criteria [GDC] (Reference 12), describes an evaluation of the Clinton design bases as measured against the NRC GDC in Appendix A to 10 CFR Part 50. The following Clinton design bases are related to this license amendment request (LAR).

Criterion 13 - Instrumentation and Control Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Criterion 14 - Reactor Coolant Pressure Boundary The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.

Criterion 30 - Quality of Reactor Coolant Pressure Boundary Components which are part of the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

Criterion 33 - Reactor Coolant Makeup A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided. The system safety 2 Dresden, Units 2 and 3 are BWR/3 Mark 1 designs that have previously adopted the BWR/4 improved STS.

function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary. The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 35 - Emergency Core Cooling A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that:

a. fuel and cladding damage that could interfere with continued effective core cooling is prevented, and

b. cladding metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished, assuming a single failure.

2.3.2 Applicable Design Requirements (Dresden, Units 2 and 3)

The Dresden, Units 2 and 3 Updated Final Safety Analysis Report (UFSAR), Section 3.1.2, Compliance with Final Design Criteria (Reference 13), describes an evaluation of the Dresden, Units 2 and 3 design bases as measured against the NRC GDC in Appendix A to 10 CFR Part 50.

The following Dresden, Units 2 and 3 design bases are related to this LAR.

Criterion 9 - Reactor Coolant Pressure Boundary The reactor coolant pressure boundary shall be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime.

Criterion 12 - Instrumentation and Control Systems Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribed operating ranges.

Criterion 13 - Fission Process Monitors and Controls Means shall be provided for monitoring and maintaining control over the fission process throughout core life and for all conditions that can be reasonably be anticipated to cause variations in reactivity of the core, such as indication of position of control rods and concentration of soluble reactivity control poisons.

Criterion 16 - Monitoring Reactor Coolant Pressure Boundary Means shall be provided for monitoring the reactor coolant pressure boundary to detect leakage.

Criterion 33 - Reactor Coolant Pressure Boundary Capability The reactor coolant pressure boundary shall be capable of accommodating without rupture, and with only limited allowance for energy absorption through plastic deformation, the static and dynamic loads imposed on any boundary component as a result of any inadvertent and sudden release of energy to the coolant. As a design reference, this sudden release shall be taken as that which would result from a sudden reactivity insertion such as a rod ejection (unless prevented by positive mechanical means), rod dropout, or cold-water addition.

Criterion 37 - Engineered Safety Features Basis for Design Engineered safety features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. As a minimum, such engineered safety features shall be designed to cope with any size reactor coolant pressure boundary break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

Criterion 41 - ESF [Engineered Safety Feature] Performance Capability Engineered safety features such as emergency core cooling and containment heat removal systems shall provide sufficient performance capability to accommodate partial loss of installed capacity and still fulfill the required safety function. As a minimum, each engineered safety feature shall provide this required safety function assuming a failure of a single active component.

Criterion 44 - Emergency Core Cooling System Capability At least two emergency core cooling systems, preferably of different design principles, each with a capability for accomplishing abundant emergency core cooling, shall be provided. Each emergency core cooling system and the core shall be designed to prevent fuel and clad damage that would interfere with the emergency core cooling function and to limit the clad metal-water reaction to negligible amounts for all sizes of breaks in the reactor coolant pressure boundary, including the double-ended rupture of the largest pipe. The performance of each emergency core cooling system shall be evaluated conservatively in each area of uncertainty. The systems shall not share active components and shall not share other features or components unless it can be demonstrated that: (a) the capability of the shared feature or component to perform its required function can be readily ascertained during reactor operation, (b) failure of the shared feature or component does not initiate a loss-of-coolant accident, and (c) capability of the shared feature or component to perform its required function is not impaired by the effects of a loss-of-coolant accident and is not lost during the entire period this function is required following the accident.

3.0 TECHNICAL EVALUATION

3.1 Staff Evaluation of Proposed TS Changes (Clinton)

Refer to Section 2.2.1 above for proposed changes.

3.1.1 TS 3.3.5.2 Required Action B is related to TS Table 3.3.5.2-1, RPV Water Inventory Control Instrumentation, for the isolation of the residual heat removal (RHR) system and reactor water cleanup system.

For automatic isolation of RPV penetration flow paths below the TAF on a Reactor Vessel Water Level-Low Low, Level 2 signal, 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, the licensee 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. The existing Clinton TS Required Action B was to declare associated penetration flow path(s) incapable of automatic isolation.

Placing the inoperable channel in trip would restore capability to automatically isolate the penetration flow path(s) on a Reactor Vessel Water Level-Low Low, Level 2 signal, and allow activities to continue with no further restrictions. If the operable 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 proposed Required Action B.1 was selected to be consistent with the existing Required Actions. Joining unequal Completion Times with an OR logical connector would have 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. In this case, the acceptable presentation is for Required Action B.2.2 to begin Initiate action to....

The NRC staff reviewed the licensees proposed changes to the TS 3.3.5.2 Required Actions under Condition B. The NRC staff finds the addition of Required Action B.1 (to immediately initiate action to place the inoperable channel in trip) is acceptable because it is a compensatory action that allows the required function of detecting a low water level to be maintained, consistent with design criterion 13 requirements for instrumentation. The NRC staff finds the renumbering of current Required Actions B.1 and B.2 to B.2.1 and B.2.2, respectively, is an acceptable editorial change to maintain consistency and order within the TS 3.3.5.2 Actions Table. The NRC staff finds proposed Required Action B.2.2 to be consistent with the current licensing basis (i.e., other Clinton TS actions that have an Immediately completion time), and that it clarifies the requirement. Therefore, the NRC staff finds the changes to the Required Actions in TS 3.3.5.2 Condition B acceptable.

3.1.2 TSs 3.5.1 and 3.5.2 Editorial and Technical Changes Related to the four proposed editorial changes, 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, the full phrase should be used followed by the acronym or initialism set off by parentheses. The abbreviation should be used on all subsequent references in that Specification or Bases. Therefore, the NRC staff finds that these editorial corrections to TS 3.5.1 and TS 3.5.2, as shown above, are acceptable.

Related to the one proposed technical change, TS 3.5.2, Condition D, which applies when Drain Time is less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , requires immediate action to isolate each secondary containment penetration flow path or verification that it can be manually isolated from the main control room (MCR). In some scenarios, the Clinton secondary containment isolation dampers (SCIDs) may be operable in accordance with LCO 3.6.4.1, Secondary Containment, and LCO 3.6.4.2, Secondary Containment Isolation Dampers (SCIDs), during periods when LCO 3.5.2 is applicable during Modes 4 and 5. Therefore, the licensee proposes to modify Required Action D.3 to state (proposed changes are in bold), Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room. This change addresses the possibility that the Clinton SCIDs may close automatically and provides an alternative to the requirement to verify that the dampers are capable of being manually isolated from the control room. Automatic closure of the SCIDs provides protection equivalent to manual isolation from the MCR.

Based on the above technical discussion related to Drain Time, the NRC staff finds that it is acceptable to allow automatic isolation as an alternative to manual isolation of the associated secondary containment penetration flow paths and isolation dampers.

3.1.3 TS SRs 3.5.2.5 - 3.5.2.8 The NRC staff finds that there is no longer a specified correct position, as that term is used in SR 3.5.2.5, for the subsystem valves to support initiation from the ECCS instrumentation.

Proposed changes to TS 3.5.2 no longer credit the use of automatic valves that respond to an ECCS signal. The proposed TS 3.5.2 permits the use of operator action to align power operated valves. Licensee control of manual valves will be needed to support manual alignment and initiation of the ECCS subsystem from the control room. Therefore, the NRC staff finds that the deletion of SR 3.5.2.5 is acceptable.

Because of the deletion of SR 3.5.2.5, existing SRs 3.5.2.6, 3.5.2.7, and 3.5.2.8 are proposed to be renumbered as SRs 3.5.2.5, 3.5.2.6, and 3.5.2.7, respectively. These changes are editorial and consistent with the deletion of SR 3.5.2.5 and, therefore, acceptable.

Existing SR 3.5.2.6 (Proposed SR 3.5.2.5)

As discussed in Section 2.2.1 above, Clinton existing SR 3.5.2.6 (proposed SR 3.5.2.5) currently requires operating the required ECCS injection/spray 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 RHR or shutdown cooling 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 would remove the phrase through the recirculation line from the SR and add two notes. The first Note would state 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 would state that credit may be taken for normal system operation that satisfies the SR.

The NRC staff finds that the SR, as revised, will continue to ensure that the ECCS injection/spray subsystem can inject water into the RPV if needed, as a defense-in-depth measure, while eliminating unnecessary testing. Also, the test line noun name is changed for simplification, adopting to the Clinton design, which adds clarity to the TS. Therefore, the NRC staff finds the proposed change to be acceptable.

Existing SR 3.5.2.7 (Proposed SR 3.5.2.6)

With the proposed deletion of SR 3.5.2.5, SR 3.5.2.7 would be renumbered as SR 3.5.2.6. The NRC staff finds this editorial change in renumbering to be necessary for alignment of the SRs and, therefore, acceptable.

Existing SR 3.5.2.8 (Proposed SR 3.5.2.7)

With the proposed deletion of SR 3.5.2.5, SR 3.5.2.8 would be renumbered as SR 3.5.2.7. The NRC staff finds this editorial change in renumbering to be necessary for alignment of the SRs and, therefore, acceptable.

3.1.4 TS SR 3.8.2.1 LCO 3.8.2, AC Sources - Shutdown, requires the operability of one offsite circuit and one diesel generator (DG) to support the Division 1 or 2 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, Distribution Systems - Shutdown, and one offsite circuit or the Division 3 DG to support the Division 3 Class 1E AC electrical power distribution subsystem(s) when the High Pressure Core Spray System is operable for compliance with LCO 3.5.2. LCO 3.8.2 is applicable in shutdown conditions (i.e., in Modes 4 and 5 and during movement of irradiated fuel assemblies in the primary or secondary containment). The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions.

The following additional TS 3.8.1 SRs are proposed to be excluded from applicability in Modes 4 and 5 shutdown conditions. These two SRs test the ability of the DGs to start automatically on an ECCS initiation signal and are no longer required in Modes 4 and 5, consistent with TSTF-542.

SR 3.8.1.12 - DG automatic start from standby from an ECCS initiation signal SR 3.8.1.19 - DG automatic start from standby from an ECCS initiation signal with a loss of offsite power signal In Modes 4 and 5, one ECCS injection/spray subsystem is required to be operable by LCO 3.5.2. The required ECCS injection/spray subsystem must be capable of being manually started as a defense-in-depth measure against an unexpected draining event. The changes associated with the adoption of TSTF-542 for Clinton did not assume automatic actuation of the ECCS subsystem. TS 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, TS 3.5.2 for Clinton does not assume that the onsite standby electrical power source will start automatically on an ECCS initiation signal. Since the ECCS automatic initiation is not required to mitigate a draining event in Modes 4 and 5, the NRC staff finds that automatic start of the DG, which supports the required ECCS injection/spray subsystem, is not required in Modes 4 and 5 for Clinton.

During movement of irradiated fuel assemblies in the primary or secondary containment, the postulated fuel handling accident event does not assume automatic DG start on an ECCS initiation signal.

The following SRs are presently excluded since these SRs are not listed in the existing SR 3.8.2.1:

SR 3.8.1.8 - Automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit SR 3.8.1.17 - DG operating in test mode and connected to its bus, an actual or simulated ECCS initiation signal overrides the test mode SR 3.8.1.20 would be added to the exception list because starting independence is not required with the DG(s) that is not required to be operable.

The purpose of the SR 3.8.2.1 Note is to preclude requiring the operable DGs from being paralleled with the offsite power network or otherwise rendered inoperable during the performances of SRs, and to preclude de-energizing a required 4.16 kilovolt ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. Since SR 3.8.1.19 is proposed for addition to the exception within the SR 3.8.2.1, the NRC staff finds the deletion of SR 3.8.1.19 from the SR 3.8.2.1 Note to be acceptable.

In summary, testing of DG automatic starts on an ECCS initiation signal (SRs 3.8.1.12 and 3.8.1.19) are no longer required in Modes 4 and 5 with respect to TSTF-542. The remaining SRs will continue to ensure that the AC power sources are adequately tested, which includes SR 3.8.1.1, SR 3.8.1.2, and SRs 3.8.1.4 through 3.8.1.7. Therefore, based on the discussion above, the NRC staff finds the proposed changes to SR 3.8.2.1 to be acceptable.

3.

1.5 NRC Staff Conclusion

s (Clinton)

As stated above in Section 2.2.1.1 of this SE, TSTF-542 (adopted by Clinton) included new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during Modes 4 and 5 operations. Clinton Safety Limit 2.1.1.3 requires that the RPV water level shall be greater than the TAF. Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions.

The proposed changes for Clinton include TS LCOs 3.3.5.2, 3.5.1, and 3.5.2. In addition, the proposed changes include SRs within TSs 3.5.2 and 3.8.2. The proposed TS changes are associated with Modes 4 and 5 conditions.

The NRC staff reviewed the proposed changes to LCOs 3.3.5.2, 3.5.1, and 3.5.2 and concludes that these LCOs continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff reviewed the proposed changes to SRs 3.5.2.5 (deleted), 3.5.2.6 (revised),

3.5.2.7 (revised), 3.5.2.8 (revised), and 3.8.2.1 (revised). The NRC staff finds that the proposed SRs are acceptable because they support TS 3.5.2 drain time requirements. Specifically, the proposed SRs ensure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, that ECCS injection/spray subsystems are adequately filled with water (mitigates the effects of gas accumulation or voiding), that the subsystems have verified valve positions to support RPV injection, that the pumps provide adequate flow to support drain time and RPV injection, that automatic isolation is verified, and that the ECCS injection/spray subsystems can be manually operated. The NRC staff finds that the proposed changes to SR 3.8.2.1 and the remaining SRs will continue to ensure that the AC power sources are adequately tested, which includes SR 3.8.1.1, SR 3.8.1.2, and SRs 3.8.1.4 through 3.8.1.7. The changes to the SRs are sufficient and adequate, because they ensure that the TS Functions are capable of performing their specified safety functions in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in Modes 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed Clinton changes against each of the applicable design requirements listed above in Section 2.3.1 of this SE. The NRC staff finds that the proposed changes for Modes 4 and 5 operations, as they relate to the Drain Time definition (removal of OPDRV references), remain consistent with the GDCs in that the Clinton design requirements for instrumentation, reactor coolant leakage detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected.

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing Clinton requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with TSTF-542, Revision 2 (Reference 4) and Chapter 16 of the SRP (Reference 11) and are therefore acceptable.

3.2 Staff Evaluation of Proposed TS Changes (Dresden, Units 2 and 3)

Refer to Section 2.2.2 above for proposed changes.

3.2.1 TS 3.3.5.2 Required Action B is related to TS Table 3.3.5.2-1, RPV Water Inventory Control Instrumentation, for the isolation of the RHR system and reactor water cleanup system.

For automatic isolation of RPV penetration flow paths below the TAF on a Reactor Vessel Water Level-Low signal, 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, the licensee 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. The existing Dresden TS Required Action B was to declare associated penetration flow path(s) incapable of automatic isolation.

Placing the inoperable channel in trip would restore capability to automatically isolate the penetration flow path(s) on an Reactor Vessel Water Level-Low signal, and allow activities to continue with no further restrictions. If the operable 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 proposed Required Action B.1 was selected to be consistent with the existing Required Actions. Linking 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 inappropriate to require the completion of the action within a specific time. In this case, the acceptable presentation is for Required Action B.2.2 to state Initiate action to....

The NRC staff reviewed the licensees proposed changes to the TS 3.3.5.2 Required Actions under Condition B. The NRC staff finds the addition of Required Action B.1 (to immediately initiate action to place the inoperable channel in trip) is acceptable because it is a compensatory action that allows the required function of detecting RPV low water level to be maintained, consistent with design criterion 12 requirements for instrumentation. The NRC staff finds the renumbering of current Required Actions B.1 and B.2 to B.2.1 and B.2.2, respectively, is an acceptable editorial change to maintain consistency and order within the TS 3.3.5.2 Actions Table. The NRC staff finds proposed Required Action B.2.2 to be consistent with the current licensing basis (i.e., other Dresden TS actions that have an Immediately completion time), and that it clarifies the requirement. Therefore, the NRC staff finds the changes to the Required Actions in TS 3.3.5.2 Condition B acceptable.

3.2.2 TSs 3.5.1 and 3.5.2 Editorial and Technical Changes Related to the three proposed editorial changes, according to the TS Writers Guide, upon the first reference in each Specification or Bases to a phrase for which an abbreviation is desired to be used, the full phrase should be used followed by the acronym or initialism set off by parentheses. The abbreviation should be used on all subsequent references in that Specification or Bases. Therefore, the NRC staff finds that these editorial corrections to TS 3.5.1 and TS 3.5.2, as shown above, are acceptable.

Related to the one proposed technical change, TS 3.5.2, Condition D, which applies when Drain Time is less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , requires immediate action to isolate each secondary containment penetration flow path or verification that it can be manually isolated from the MCR. In some scenarios, the Dresden secondary containment isolation valves (SCIVs) may be operable in accordance with LCO 3.6.4.1, Secondary Containment, and LCO 3.6.4.2, Secondary Containment Isolation Valves (SCIVs), during periods when LCO 3.5.2 is applicable during Modes 4 and 5. Therefore, the licensee proposes to modify Required Action D.3 to state (proposed changes are in bold), Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room. This change addresses the possibility that the Dresden SCIVs may close automatically and provides an alternative to the requirement to verify that the valves are capable of being manually isolated from the control room. Automatic closure of the SCIVs provides protection equivalent to manual isolation from the MCR.

Based on the above technical discussion related to Drain Time, the NRC staff finds that it is acceptable to allow automatic isolation as an alternative to manual isolation of the associated secondary containment penetration flow paths and isolation valves.

3.2.3 TS SRs 3.5.2.4 - 3.5.2.7 The NRC staff finds that there is no longer a specified correct position, as that term is used in SR 3.5.2.4, for the subsystem valves to support initiation from the ECCS instrumentation.

Proposed changes to TS 3.5.2 no longer credit the use of automatic valves that respond to an ECCS signal. The proposed TS 3.5.2 permits the use of operator action to align power operated valves. Licensee control of manual valves will be as needed to support manual alignment and initiation of the ECCS subsystem from the MCR. Therefore, the NRC staff finds that the deletion of SR 3.5.2.4 is acceptable.

Because of the deletion of SR 3.5.2.4, existing SRs 3.5.2.5, 3.5.2.6, and 3.5.2.7 are proposed to be renumbered as SRs 3.5.2.4, 3.5.2.5, and 3.5.2.6, respectively. These changes are editorial and consistent with the deletion of SR 3.5.2.4 and, therefore, acceptable.

Existing SR 3.5.2.5 (Proposed SR 3.5.2.4)

Dresden existing SR 3.5.2.5 (proposed SR 3.5.2.4) currently requires operating the required ECCS injection/spray 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 RHR or shutdown cooling 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 would remove the phrase through the recirculation line from the SR and add two notes. The first Note would state 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 would state that credit may be taken for normal system operation that satisfies the SR.

Based on this discussion, the NRC staff finds that the SR, as revised, would continue to ensure that the ECCS injection/spray subsystem can inject water into the RPV if needed, as a defense-in-depth measure, while eliminating unnecessary testing. Also, the test line noun name is changed for simplification, adopting to the Dresden design, which adds clarity to the TS.

Therefore, the NRC staff finds the proposed change to be acceptable.

Existing SR 3.5.2.6 (Proposed SR 3.5.2.5)

With the proposed deletion of SR 3.5.2.4, SR 3.5.2.6 would be renumbered as SR 3.5.2.5. The NRC staff finds this editorial change in renumbering to be necessary for alignment of the SRs and, therefore, acceptable.

Existing SR 3.5.2.7 (Proposed SR 3.5.2.6)

With the proposed deletion of SR 3.5.2.4, SR 3.5.2.7 would be renumbered as SR 3.5.2.6. The NRC staff finds this editorial change in renumbering to be necessary for alignment of the SRs and, therefore, acceptable.

3.2.4 TS 3.6.1.3 The proposed change to TS 3.6.1.3 is to remove from APPLICABILITY the following:

When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, Primary Containment Isolation Instrumentation.

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 Dresden, Units 2 and 3 Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System Isolation, Reactor Vessel Water 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.

Consistent with this, the Applicability of Dresden, 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 the adoption of TSTF-542.

The NRC staff finds that this change is consistent with the treatment of other primary containment isolation instruments as discussed in Section 3.4.1.2, TS 3.3.6.1a and 3.3.6.1b, Primary Containment Isolation Instrumentation, and in Section 3.4.2, Other Proposed Changes - Containment, Containment Isolation Valves, and Standby Gas Treatment Requirements, of the Justification for TSTF-542, Revision 2 (Reference 3). Therefore, the NRC staff concludes that the proposed change is acceptable.

3.2.5 TS SR 3.8.2.1 LCO 3.8.2, AC Sources-Shutdown, requires one offsite circuit and one DG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Distribution Systems-Shutdown, to be operable in shutdown conditions (i.e., Modes 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment). The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions with some listed exceptions.

The following additional TS 3.8.1 SRs are proposed to be excluded from applicability in shutdown conditions. These two SRs test the ability of the DGs to start automatically on an ECCS initiation signal SR 3.8.1.13 - DG automatic start from standby from an ECCS initiation signal SR 3.8.1.19 - DG automatic start from standby from an ECCS initiation signal with a loss of offsite power signal In Modes 4 and 5, one ECCS injection/spray subsystem is required to be operable by LCO 3.5.2. The required ECCS injection/spray subsystem must be capable of being manually started as a defense-in-depth measure against an unexpected draining event. The changes associated with the adoption of TSTF-542 for Dresden Units 2 and 3 did not assume automatic actuation of the ECCS subsystem. TS 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, TS 3.5.2 for Dresden does not assume that the DG will start automatically on an ECCS initiation signal to mitigate a draining event in Modes 4 and 5. Since the ECCS automatic initiation is not required to mitigate a draining event in Modes 4 and 5, the NRC staff finds that automatic start of the DG, which supports the required ECCS injection/spray subsystem, is not required in Modes 4 and 5.

During movement of recently irradiated fuel assemblies in the secondary containment, the postulated fuel handling accident event does not assume automatic DG start on an ECCS initiation signal.

Additionally, existing SR 3.8.2.1 Note 1, which states, in part SR 3.8.1.14 through SR 3.8.1.19, would be changed to state SR 3.8.1.14 through SR 3.8.1.18.

The purpose of this existing SR 3.8.2.1 Note 1 is to preclude requiring the operable DGs from being paralleled with the offsite power network or otherwise rendered inoperable during the performances of SRs, and to preclude de-energizing a required 4.16 kilovolt ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. Since SR 3.8.1.19 is proposed for addition to the exception within the SR 3.8.2.1, the NRC staff finds the deletion of SR 3.8.1.19 from the existing SR 3.8.2.1 Note 1 to be acceptable.

The NRC staff finds the proposed deletion of SR 3.8.2.1 Note 2 associated with SR 3.8.1.13 and SR 3.8.1.19, acceptable because these two SRs are now added to the SR 3.8.2.1 exceptions.

In summary, testing of DG automatic starts on an ECCS initiation signal (SRs 3.8.1.13 and 3.8.1.19) are no longer required in Modes 4 and 5 with respect to TSTF-542. The remaining SRs will continue to ensure that the AC power sources are adequately tested, which includes SR 3.8.1.1, SR 3.8.1.2, and SRs 3.8.1.4 through 3.8.1.8. Therefore, based on the discussion above, the NRC staff finds the proposed changes to SR 3.8.2.1 to be acceptable.

3.

2.6 NRC Staff Conclusion

s (Dresden)

The previously adopted TSTF-542 TS changes to the Dresden TSs included new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during Modes 4 and 5 operations. Dresden Safety Limit 2.1.1.3 requires that the RPV water level shall be greater than the TAF. Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions.

The proposed changes for Dresden, Units 2 and 3 include TS LCOs 3.3.5.2, 3.5.1, 3.5.2, and 3.6.1.3. In addition, the proposed changes include SRs within TSs 3.5.2 and 3.8.2. The proposed TS changes are associated with Modes 4 and 5 conditions.

The NRC staff reviewed the proposed changes to LCOs 3.3.5.2, 3.5.1, 3.5.2, and 3.6.1.3 and concludes that these LCOs continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff reviewed the proposed changes to SRs 3.5.2.4 (deleted), 3.5.2.5 (revised),

3.5.2.6 (revised), 3.5.2.7 (revised), 3.6.1.3 (revised), and 3.8.2.1 (revised). The NRC staff finds that the proposed SRs are acceptable because they support TS 3.5.2 Drain Time requirements.

Specifically, the proposed SRs ensure that water inventory is available for ECCS injection/spray subsystem RPV injection and pump performance, that the ECCS injection/spray subsystems are adequately filled with water (mitigates the effects of gas accumulation or voiding), that the subsystems have verified valve positions to support RPV injection, that the pumps provide adequate flow to support Drain Time and RPV injection, that automatic isolation is verified, and that the ECCS injection/spray subsystems can be manually operated. The NRC staff finds that the proposed changes to SR 3.8.2.1 and the remaining SRs will continue to ensure that the AC power sources are adequately tested, which includes SR 3.8.1.1, SR 3.8.1.2, and SRs 3.8.1.4 through 3.8.1.8. The changes to the SRs are sufficient and adequate, because they ensure that the TS Functions are capable of performing their specified safety functions in support of TS 3.5.2, Drain Time, and the protection from a potential drain down of the RPV in Modes 4 and

5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed Dresden changes against each of the applicable design requirements listed above in Section 2.3.2 of this SE. The NRC staff finds that the proposed changes for Modes 4 and 5 operations, as they relate to the Drain Time definition (removal of OPDRV references), remain consistent with the GDCs in that the Dresden design requirements for instrumentation, reactor coolant leakage detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected.

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing Dresden requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with TSTF-542, Revision 2 (Reference 4) and Chapter 16 of the SRP (Reference 11) and are therefore acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Illinois State official was notified of the proposed issuance of the amendments on March 9, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration on August 29, 2019 (84 FR 45542), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

Simpson, Patrick R., Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory Commission, Application to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control, dated June 18, 2019, Agencywide Documents Access and Management System (ADAMS)

Accession No. ML19169A146.

2.

Simpson, Patrick R., Exelon Generation Company, LLC, letter to U.S. Nuclear Regulatory Commission, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control, dated December 5, 2019, ADAMS Accession No. ML19339G992.

3.

Technical Specifications Task Force, letter to U.S. Nuclear Regulatory Commission, Response to NRC Request for Additional Information Regarding TSTF-542, Revision 1, Reactor Pressure Vessel Water Inventory Control and Submittal of Revision 2, dated March 14, 2016, ADAMS Accession No. ML16074A448.

4.

Klein, Alexander R., U.S. Nuclear Regulatory Commission, letter to Technical Specifications Task Force, Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control, dated December 20, 2016, ADAMS Accession No. ML16343B008.

5.

Rankin, Jennivine, U.S. Nuclear Regulatory Commission, letter to Bryan C. Hanson, Exelon Generation Company, LLC, 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, ADAMS Accession No. ML18043A505.

6.

Haskell II, Russell S., U.S. Nuclear Regulatory Commission, letter to Bryan C. Hanson, Exelon Generation Company, LLC, Dresden Nuclear Power Station, Unit Nos. 2 and 3 -

Issuance of Amendments to Renewed Facility Operating Licenses Nos. DPR-19 and DPR-25 to Revise Technical Specifications to Adopt Technical Specification Traveler Force 542, Revision 2, Reactor Pressure Vessel Water Inventory Control, dated January 8, 2018, ADAMS Accession No. ML17272A783.

7.

U.S. Nuclear Regulatory Commission, NUREG-1434, Revision 4.0, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Specifications, dated April 2012, ADAMS Accession No. ML12104A195.

8.

U.S. Nuclear Regualtory Commission, NUREG-1434, Revision 4.0, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 2, Bases, dated April 2012, ADAMS Accession No. ML12104A196.

9.

U.S. Nuclear Regulatory Commission, NUREG-1433, Revision 4.0, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 1, Specifications, dated April 2012, ADAMS Accession No. ML12104A192.

10.

U.S. Nuclear Regulatory Commission, NUREG-1433, Revision 4.0, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 2, Bases, dated April 2012, ADAMS Accession No. ML12104A193.

11.

U.S. Nuclear Regulatory Commission, NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 16, Revision 3, Technical Specifications, dated March 2010, ADAMS Accession No. ML100351425.

12.

Exelon Generation Company, LLC, Revision 20 to Clinton Power Station Updated Safety Analysis Report, Chapter 3, Design of Structures, Components, Equipment, and Systems, dated October 24, 2018, ADAMS Accession No. ML18304A397.

13.

Exelon Generation Company, LLC, Revision 13 to Dresden Updated Final Safety Analysis Report, Chapter 3, Design of Structures, Components, Equipment, and Systems, dated June 21, 2019, ADAMS Accession No. ML19177A191.

Principal Contributors: L. Wheeler, NRR F. Forsaty, NRR K. West, NRR A. Foli, NRR Date of issuance: May 28, 2020

AMD: ML19351D750

by e-mail OFFICE NRR/DORL/LPL3/PM*

NRR/DORL/LPL3/LA*

NRR/DSS/SNSB/BC(A)*

NAME RHaskell SRohrer (JBurkhardt for)

JBorromeo DATE 02/12/2020 02/11/2020 12/10/2019 OFFICE NRR/DSS/STSB/BC*

NRR/DEX/EICB/BC*

NRR/DEX/EEOB/BC*

NAME VCusumano (SKrepel for)

MWaters BTitus DATE 02/10/2020 02/26/2020 01/07/2020 OFFICE OGC-(NLO)*

NRR/DORL/LPL3/BC*

NRR/DORL/LPL3/PM*

NAME JWachutka NSalgado RHaskell DATE 03/03/2020 05/27/2020 05/28/2020

v t e Letter Sequence Approval
EPID:L-2019-LLA-0124, TSTF-542 (Open)
Initiation Request, Request Acceptance... Administration Questions 25 November 2019 Answers 5 December 2019 Results Approval Other:
MONTHYEAR2019-06-18 [Table View]

Person / Time
ML19351D750
Site:	Dresden, Clinton (DPR-019, DPR-025, NPF-062)
Issue date:	05/28/2020
From:	Haskell R Plant Licensing Branch III
To:	Bryan Hanson Exelon Generation Co
Haskell R
References
EPID L-2019-LLA-0124
Download: ML19351D750 (55)
v • d • e

ML19351D750

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

System Description

2.2 Proposed TS Changes

3.0 TECHNICAL EVALUATION

1.5 NRC Staff Conclusion

2.6 NRC Staff Conclusion

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

Navigation menu

Search