ML20137C240

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Proposed Tech Specs,Deleting Authority to Operate Unit & Sys Requirements & Surveillances No Longer Applicable
ML20137C240
Person / Time
Site: Dresden Constellation icon.png
Issue date: 01/07/1986
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20137C229 List:
References
NUDOCS 8601160247
Download: ML20137C240 (47)


Text

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Dresden I DPR-2

. .- Amendmant No.

Appendix A 4

to Amended Facility License DPR-2 Technical Specifications 'and Bases For Dresden Nuclear Power Station Unit 1 Grundy County. Illinois Commonwealth Edison Company Docket No. 50-10 Date:

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Drosd:n I DPR-2 Amendmint No.

TABLE OF CONTEPTS Page 1.0 Definitions . . . . . . . . . . . . . . . . . . . . . . . .. . . 1-1 2.0 Design Features. . . . . . . . . . . . . . . . . . . . . . .. . . 2-1 2.1 Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 2-1 2.2 Fuel Storage . . . . . . . . . . . . . .. .. . . . . . . ... . 2-1 s

LIMITING CONDITION FOR REOUIRED EOUTPNENT

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3.0 Radioactive Materials . . . . . . . . . . . . . . . . . . . .. . 3/4.0-1 A. Airborne Effluents . . . . . . . . . . . . . . . . . . . . . 3/4.0-1 B. Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . 3/4.0-2 C. Radioactive Waste Storage. . .. . . . . . . . . . . . . . .3/4.b-3 D. General. . . . . . . . . . . . . .. . . . . . . . . . .. . 3/4.0-3

'N E. Radioactive Effluent Monitoring Availabflity . . . . . .. . 3/,4.0-3 F. Miscellaneous Radioactive Materials Souecos. t

. . . . . .. . 3/4.0-4 3.1 Auxiliary Electrical Systems. . . . . . . . . . . . ., . . . . . . 3/4.1-1 3.2 Fuel Handling and Storage . . . . . . . . . . . . . . . . . .. . 3/ .2-1 A. Fuel Storage Pool Water Level. . . . . . . . . . . . . . . . 3/4.2-1 B. Nuclear Fuel . . . . . . . . . . .. . . . . . . . . . . . . 3/4.2-1 3.3 Fire Protection Systems . . . . . . . . . . . . . . . . . . . . 3/4.3-1 A. Fire Suppression Water System. . . . .. . . . . . . . .. . 3/4.3-1 B. Fire Hose Stations . . . . . . . . . . . . . . . . . . . . . 3/4.3-1 C. Fire Pump Diesel Engine. . . . . . . . . . . . . . . . .. . 3/4.3-2 11 i

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Drosd:n I DPR-2

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Amenda nt No.

TABLE OF CONTENTS (Cont'd) Page SURVEILLANCE REOUIREMENT 4.0 Radioactive Materials . . . . . . . .. . . . . . . .. . ... . 3/4.0-1 A. Airborne Effluents . . . . . . . . . . . . . . . . . . . . . 3/4.0-1 B. Liquid Effluents . . . . . . . . .. . .. . . . . . . . . . 3/4.0-2 C. Radioactive Waste Storage . . . ... . . . .. . . .. . . 3/4.0-3 D. ~eneral . . . . . . . . . . . ..... . . .. . . . . . . 3/4.0-3 E. Radioactive Effluent Monitoring Availability . . . . . . . . 3/4.0-3 F. Miscellaneous Radioactive Materials Sources . . . . . . . . 3/4.0-4 4.1 Auxiliary Electrical Systems . . . ... . . . . .. . .. . . . 3/4.1-1 4.2 Fuel Handl'ing and Storage . . . . ... . . . .. .. .. . . . . 3/4.2-1 A. Fuel Storage Pool Water Level . . . . . . .. . . . . . . . 3/4.2-1 B. Nuclear Fuel . . . . . . . . ... . . . . . . . .. . . . . 3/4.2-1 4.3 Fire Protection Systems . . . . . . ..... .. . . .. . . . . 3/4.3-1 A. Fire Suppression Water System . .. . .. . .. . . . . . . 3/4.3-1 B. Fire Hose Stations . . . . . ..... . ... . . . . . . . 3/4.3-1 C. Fire Pump Diesel Engine . . . ... . . . . ... .. . . . 3/4.3-2 BASES FOR SECTIONS 3 AND 4 3.0/4.0 Radioactive Materials . . . . . . .. . . . . . . . . . . B.3/4.0-5 3.1/4.1 Auxiliary Electrical . . . . .. . . . . . . . . . . . . . B.3/4.1-2 3.2/4.2 Fuel Handling and Storage . . .. . . . . . . .. . . . . B.3/4.2-2 3.3/4.3 Fire Protection Systems . . . .. . . . . .. .. . . . . B.3/4.3-5 ADNINISTRATIVE CONTROLS

. 5.0 Administrative Controls . . . . . . . . . . . . . . . . . . . . . . 5-1 5.1 Organization, Review, Investigation and Audit . . . . . . . . . . . . 5-1 5.2 Plant Operating Procedures . . . . .... . .... . . .. . . . . 5-11 5.3 Action To Be Taken in the Event of a Reportable Event in Plant Operation . . . . . ... . .. . . . . . 5-13 5.4 Plant Operating Records . . . . . ................ . 5-13 5.5 Reporting Requirements . . . . . . . . . .. . .. . . .. . . . . . 5-14 111 i i

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Drosd:n I DPR-2 Amendment No.

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LIST OF TABLES Page Table 3.3-1 ,

Fire Hose Stations . . . . . . . . . . . . . . . . . . 3/4.3-4 LIST OF FICURES Figure 5.1-1 Corporate and Station organization . . . . . . . . . . . . 5-3 I

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Dresden I DPR-2 '

Amendment No.

. 1.0 Definitions The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

A. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.

B.

Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it corresponds, within acceptable range, and accuracy, to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm, or trip.

C.

Instrument Functional Test - An instrument functional test means the injection of a simulated signal into the instrument primary sensor to verify the proper instrument response, alarm, and/or initiating action. The primary sensors of radiation monitors are excepted from

+ this definition. For these monitors the functional test will consist of injecting a simulated electrical signal into the measurement chancel.

D. Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during cperation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.

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E. Operable - A system, subsystem, train, component, or device shall be operable when it is capable of performing its specified function (s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s).

F. Operatina - Operating means that a system, subsystem, train, component or device is performing its intended functions in its

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required manner.

G. Surveillance Interval - Rach surveillance requirement shall be performed within the specified surveillance interval with: '

a. A maximum allowable extension not to exceed 25% of the f

surveillance interval.

b. A total maximum combined interval time for any 3 consecutive ,

intervals not to exceed 3.25 times the specified surveillance ,

I interval.

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Dessdsn I DPR-2 Amendment No.

2.0 Deslan Features 2.1 gitt Dresden Unit 1 is located at the Dresden Nuclear Power Station which consists of a tract of land of approximately 953 acres located in the Northwest quarter of the Morris 15-minute quadrangle (as designated by the U.S. Geological Survey), Goose Lake Township. Grundy County, Illinois. The tract is situated in portions of Sections 25, 26, 27, 34, 35, and 36 of Township 34 North, Range 8 East of the Third Principal Meridian.

2.2 Fuel Storate The K gg of the spent fuel storage pool shall be less than or equal to 0.90.

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Decsdsn I DPR-2 Amendsent N3.

3.0 Limitinz Condition For Required Equipment 4.0 Surveillance Requirement 3.0 Radioactive Materials 4.0 Radioactive Materials' Applicability: Applicability:

Applies to the radioactive affluents from Applies to the periodic monitoring and the plant. recording of radioactive effluents.

Objective: Obiective:

To assure that radioactive effluents are To ascertain that radioactive releases are kept as low as practicable, and, in any kept as low as practicable and are within event, are not released to the environment allowable values.

in an uncontrolled manner and to assure that any material released is within the '

limits of 10 CFR 20.

Specification: Specification:

A. Airborne Effluents A. Airborne Effluents

1. Radioactive gases released from 1. The plant chimney monitoring system the Dresden Unit 1 chimney shall shall have a daily instrument be continuously monitored. To . check, monthly source check, accomplish this, the chimney quarterly function test and once monitoring system shall be per 18 month calibration.

operable at all times except as noted in Specification 3.0.E.

2. Airborne effluents from Unit 1 2. Main Chimney activity analysis shall be added to those from shall be performed at the specified Units 2 and 3 with the applicable frequencies.

limits for the total to be those listed in sections 3.8/4.8 of a. Main chimney noble 1/ month DPR-19 and DPR-25. gas (tritium and principal gamma emitters),

b. Main chimney parti- 1/ month
  • culate (principal gamaa emitters).
c. Main chimney iodine. 1/ month *
d. Main chimney parti- 1/qtr.

culate composite (Se-89, Sr-90, gross alpha).

Note

  • Analysis frequency shall be increased to 1/ week if release rates exceed 1% of any applicable limit referenced in Section 3.0.A.2. ,

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Dresdan I DPR-2 Amendment N3.

3.0 Limitina Condition For Required Eauloment 4.0 Surveillance Requirement (Cont'd)

(Cont'd)

B. Liquid Rffluents B. Liquid Effluents

1. Radioactive affluents shall not 1. a. The service water radiation be released from Unit 1 storage monitor shall have an inst-tanks directly to the environment rument check performed daily, (release can be made through D2/3 a functional check performed Radwaste System). Radioactive quarterly,. and a source check effluents may be released from and calibration performed Units 2 and 3 by way of the Unit once every 18 months.

1 discharge canal only when dis-charges are controlled on a b. The operability of the radionuclide basis in accordance discharge canal sampler shall with Appendix B. Table II, Column be verified prior to 2 of 10 CFR 20 and all applicable performing and once a day

. limits listed in DPR-19 and during planned discharge.

DPR-25. Additionally, the discharge canal sampler shall be c. Station reeveds of batch operable at any time a radio- releases from Units 2 and 3 active discharge is occurring via shall be maintained in this pathway or the radioactive accordance with the specifi-discharge shall be immediately cations of DPR-19 and DPR-25.

suspended. .,

2. The service water discharge shall 2. a. Activity analysis of conti-be continuously monitored and the nuous service water discharge concentration (above background) shall be performed monthly in the condenser cooling water for I-131, principal gamma discharge canal shall not exceed emitters dissolved and on-the limits stated below unless trained gases, H-3, and gross the discharge is controlled on a alpha activity. Additional radionnelide basis in accordance analysis for Sr-89, Sr-90 and with Appendix B. Table II, Column Fe-55 shall be performed 2 of 10 CFR 20 and Note 1 thereto: quarterly.

Maximum Concentration b. In the event of failure of the service water monitor, 1 x 10-7 pC1/mi effluents may continue to be released via this pathway if a service water grab sample is taken once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and analyzed.

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, Drasdsn I DPR-2 Amindment No.

3.0 Limitina Condition For Required Equipment 4.0 Surveillance Requirement (Cont'd)

(Cont'd)

C. Radioactive Waste Storage C. Radioactive Waste Storage The maximum amount of radioactivity in A sample from each of the above-grade 11guld storage in all Dresden Stations 11guld waste tanks shall be taken,

, . above grade tanks shall not exceed 90 analyzed, and recorded every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

curies. If these conditions cannot be If no additions to a tank have been met the stored liquid shall be made since the last sample, the tank recycled within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to below need not be sampled until the next grade tanks. All tanks located within addition.

the seismic portion of the Chemical Cleaning Building are not considered above grade storage.

D. General D. General It is expected that releases of 1. Operating procedures shall be radioactive material in effluents will developed and used, and equipment be kept at small fractions of the which has been installed to main-limits specified in Section 20.106 of tain control over radioactive 10 CFR Part 20. The licensee will materials in gaseous and liquid exert his best efforts to keep levels effluents produced during normal of radioactive material in effluents activity shall te maintained and as low as is reasonably achievable. used, to keep levels of radio-active material in effluents released to unrestricted areas as low as is reasonably achievable.

The environmental monitoring program given in DPR-19 and DPR

  • shall be conducted.

E. Radioactive Effluent Monitoring- E. Radioactive Effluent Monitoring Availability Availability

1. The entire plant chimney 1. a. The main chimney noble gas monitoring system, including the monitor may be out-of-particulate filters and charcoal service for calibration and cartridges, may be out of service maintenance provided that a for calibration or maintenance noble gas grab sample is provided that the requirements taken daily and analyzed, listed in 4.0.E. are satisfied.
b. The main chimney particulate and lodine sampling system may be out-of-service for maintenance provided that l particulate and iodine samples may be collected using alternate filter holders and pumps connected to the main chimney sample stream.

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Decsdsn I DPR-2

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Am:ndment No.

3.0 Limitinx Condition For Required Equipment 4.0 Surveillance Requirement (Cont'd)

(Cont'd)

F. Miscellaneous Radioactive Materials F. Miscellaneous Radioactive Materials Sources l Sources 1

Source Leakare Test Each sealed source shall be tested for '

leakage and/or contamination by the Speelfication licensee or by other persons specifi-cally authorized by the Commission or Each sealed source containing an Agreement State. The test method radioactive material in excess of 100 shall have a detection sensitivity of microcuries of beta and/or gamma at least 0.005 microcuries per test emitting material or 5 microcuries of sample.

alpha emitting material shall be free of 1 0.005 microcuries of removable Each category of sealed sources shall contonination. be tested at the frequency described below.

Each sealed source with removable contamination in excess of the above 1. Sources in use (excluding startup limit shall be immediately withdrawn sources previously subjected to from use and either decontaminated and core flux) - At least once per six repaired or disposed of in accordance months for all sealed ' sources with Commission regulations. containing radioactive material:

A complete inventory of radioactive a. With a half-life greater than materials in the licensee's possession 30 days (excluding Hydrogen shall be maintained current at all 3), and times.

b. In any form other than gas.
2. Stored sources not in use - Each sealed source shall be tested prior to use or transfer to another licensee unless tested within the previous six months.

Sealed sources t.ansferred without a certificate indicating the last test date shall be tested prior to being placed into use.

l A Special Report shall be prepared and submitted to the Commission pursuant to Specification 5.5.C.3 if source loakage l

tests reveal the presence of 1 0.005 microcuries of removable contamination.

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Dresdsn I DPR-2 Am3ndmint No.

BASES

, A. Airborne Effluents - The basis for airborne effluents from the site are contained in DPR-19 and DPR-25 as well as the off-Site Dose calculation Manual.

B. Llauld Effluents - Liquid effluent release rate will be controlled in terms of the concentration in the discharge canal. In the case of unidentified mixtures, such concentration limit is based on assumption that the entire centent is made up of the most restrictive isotope in accordance with 10 CFR 20. Such a limit assures that even if a person obtained all of his daily water intake from such a source, the resultant dose would not exceed that specified in 10 CFR

20. Since no such use of the discharge canal is made and considerable natural dilution occurs prior to any location where such doses could occur, this assures that off-side doses from this source will be far less than the limits specified in 10 CFR 20.

C. Radioactive Liquid Weste Storane - The maximum gross radioactivity in

, liquid storage in the specified tanks has been limited on the basis of an accidental spill from all stated tanks due to a seismic event great enough to damage them. The Chemical Cleaning Building is seismically designed and designed to contain a simultaneous spill from all the contaminated liquid storage tanks housed within.

Assuming a low river flow of 3100 ft 3/sec, a day period over which the radioactive liccid wastes are diluted in the river, and consumption of the water by individuals at standard man consumption rate (3000 al/ day), the single intake by an individual would not exceed one-third the yearly intake allowable by 10 CFR 20 for I

' , unidentified radioisotopes (1 x 10-7 pC1/ml). The factor of 3 was applied to 10 CFR 20 limits as recommended for situations in j which population groups could be exposed.

The sampling frequency has been established so that if the maximum amount of gross radioactivity is exceeded, action can be taken to

reduce the radioactivity to a level below the specified limit.

D. Environmental Radioloalcal Monitorina Program - The bases for the

environmental monitoring program are contained in DPR-19 and DPR-25.

l E. Radioactive Effluent Monitorina Availability F. Miscellaneous Radioactive Materials Sources ,

The objective of this specification is to assure that leakage from byproduct, source and special nuclear material sources does not exceed allowable limits. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is

, based on 10 CFR 70.39(c) limits for plutonium.

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Dessd3n I DPR-2 Amendment Ns.

3.1 Limitina Condition For Required Equipment 4.1 Surveillance Requirement 3.1 Auxiliary Electrical Systems 4.1 Auxiliary Electrical Systems Anolicability Applicability Applies to the auxiliary electrical power Applies to the periodic testing system. requirements of the auxiliary electrical system.

Ob3ective obiective To ensure an adequate supply of electrical To verify the operability of the auxiliary power. electrical system.

Specification Specification A. The Unit 1 125 volt battery, the two A. Station Batteries Unit 1 Diesel Fire Pump 12v batteries, and a battery charger for each 1. Every week the specific gravity,

, required battery shall be operable. voltage and temperature of the pilot cell and overall battery voltage shall be measurod.

2. Every three months the i

measurements shall be made of

voltage of each cell to nearest 0.01 volt, specific gravity of each cell, and temperature of every fifth cell.
3. Once every 18 months the Unit 1 125v battery shall be subjected to a rated load discharge test.

Determine specific gravity and voltage of each cell after the discharge.

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Dresdan I DPR-2 Amenda:nt No.

BASES A. D-C Supolv -

The d-c supply is required for control and motive power for switchgear.

Although station batteries will deteriorate with time, utility experience indicates there is almost no possibility of precipitous failure. The type of surveillance described in this specification is that which has been demonstrated over the years to provide an indication of a cell becoming irregular or unserviceable long before it becomes a failure.

In addition the checks described also provide adeq'nate indication that the batteries have the specified ampere hour cepability.

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Dresdsn I DPR-2 Am:ndment No.

3.2 Limitina Condition For Required Equipment 4.2 Surveillance Requirement Fuel Handlina and Storare Fuel Handling and Storaq, Apolicability Acolicability Applies to fuel handling and fuel storage. Applies to the recceding of the fuel pool water level.

Ob3ective oliective To prohibit fuel from being loaded into the To verify the fuel pool water level is reactor core and ensure adequate fuel pool maintained as specified in 3.2.A.

water level.

specification Specification A. Fuel Storage Pool Water Level A. Fuel Storage Pool Water Level whenever irradiated fuel is stored in Whenever irradiated fuel is stored in the fuel storage pool, the pool water the fuel storage pool, the pool water level shall be maintained at a level level shall be recorded daily.

of at least 18 feet.

B. Nuclear Fuel gha},1 not be loaded into the reactor core.

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Dresd:n I DPR-2 Amendment No.

BASES A. Fuel Storare Pool Water Level -

To assure that there is adequate water to shield and cool the irradiated fuel assemblies stored in the pool, a minimum pool water level is established. The minimum water level of 18 feet is established because it would be a significant change from the normal level, well above a 7.evel to assure adequate cooling (just above active fuel) and above the level at which the CSEP action is initiated (5' uncontrolled loss of level with lovel decreasing).

B. Reactor Core To assure that a critical assembly of nuclear fuol is no longer possible in the reactor core, the placement of nuclear fuel into the reactor core is specifically prohibited.

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Dresdsn I DPR-2 t .

Amendment N3.

- 3.3 Limitina condition For Required Eauloment 4.3 Surveillance Requirement Fire Protection Systems Fire Protection Systems Acolicab111tr Acolicability Applies to the fire protection systems Applies to the periodic testing whenever the equipment or systems being requirements of the fire protection systems protect.ed are required to be operable, whenever the fire protection systems are required to be operable.

Objective obiective To ensure that adequate protection against To verify operability of the fire fires is maintained. protection systems.

Specification Specification A. Fire Suppression Water System A. Fire Suppression Water System Reference DPR-19 and DPR-25, Section Reference DPR-19 and DPR-25. Section 3.12.B. 4.12.B.

B. Fire Hose Stations B. Fire Hose Stations

1. The Fire Mose Stations given in 1. At least once per 31 days, a Table 3.3.1 shall be operable at visual inspection of each fire 3 all times when the equipment in hose station shall be made to the area is required to be assure all equipment is available operable, at the station.
2. With a hose station inoperable 2. At least once per 18 months the route an additional equivalent hose will be rewaved for capacity hose to the unprotected inspection and repacked, area from an operable hose Degraded gaskets in the couplings station within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. will be replaced.
3. When a hose station becomes
  • 3. At least once per 3 years, each inoperable, restore to operable hose station valve will be status within 14 days or report partially opened to verify valve to the Commission pursuant to operability and no blockage.

specification 5.5.5 within the next 30 days outlining the cause of inoperability, action taken, and plans for restoring the hose station to operability.

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Dresdsn I DPR-2 f~ .

Amendment N3.

3,3 Lt=4 tina condition For Required Eauipment 4.3 Surveillance Requirement (Cont'd)

(Cont'd)

C. Fire Pump Diesel Ragine C. Fire Pump Diesel Engine Reference DPR-19 and DPR-25 section 1. The fire pump diesel engine shall 3.12.3. .

be demonstrated OPERABLE:

a. At least once por 31 days by verifying:
1) The fuel storage day tank contains at least 150 gallons of fuel, and
2) The diesel stsets from ambient conditions and operates for at least 20 minutes.
b. At least once per month, a sample of diesel fuel shall be check for gus11ty. The procedures will be consistent with existing station procedures used to check diesel fuel in the main storage tanks.
c. At least once per 18 months by:
1) Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recom-mondations for the class of service, and
2) Verifying the diesel starts from ambient conditions on the auto-start signal and operates for greater than oc equal to 20 minutes while loaded with the fire pump.

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Decsd:n I DPR-2 t .

Amendment Ns.

'3.3 Limitina Condition For Recuired Eaulpment 4.3 Surveillance Recuirement (Cont'd)

(Cont'd)

2. The fire pump diesel starting 24-volt battery bank charger shall be demonstrated OPERABLE:
a. At least once per 7 days by verifying that:
1) The electrolyte level of each battery is above the plates, and
2) The overall battery voltage is greater than or equal to 24 volts.
b. At least once per 92 days by verifying that the specific gravity is appropriate for continued service of the battery.
c. At least once per 18 months by verifying that:
1) The batteries, cell plates and battery racks show no visual indication of physical damage or abnormal deterioration, and
2) The battery-to-battery and terminal connee-i- tions are clean, tight, free of corrosion and coated with anti-corrosion material.

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Dessd:n I DPR-2 Amendm:nt No.

BASES Fire Protection Systems -

The operability of the fire suppression systems insures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where required equipment is located. The fire suppression system consists of the water system, sprinklers, and is adequate to minimize potential damage to required equipment, and is a major element in the facility fire protection program.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the affected equipment can be restored to service.

A fire suppression water system shall consist of a water source, pumps, and distribution piping with associated valves. Such valves chall include yard hydrant curb valves, and the first valve ahead of the water flow alarm device on each sprinkler or hose standpipe riser.

In the event that the fire suppression water e stem j becomes inoperable, immediate corrective measures must be taken since this system provides the major fire suppresslon capability of the plant. The requirement for a 24-hour report to the Ccamission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability,for the continued protection of the nuclear plant.

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Dr:sd:n I DPR-2 Amendment to.

TABLE 3.3-1 FIRE HOSE STATIONS No. Location F-11 Celb House - Ground Level South F-21 Turbine Building - Makeup Domins F-29 Turbine Building - South Stairway to Control Room 9

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Dresd:n I DPR-2 Amendment No.

5.0 ADMINISTRATIVE CONTROLS 5.1 0*aanization. Review. Investiaation and Audit A. The Station Manager shall have overall full-time responsibility for safe operation of the facility. During periods when the Station Manager is unavailable, he shall designate this responsibility to an established alternate who satisfies the ANSI N18.1 of March 8, 1971 experience requirements for plant manager.

B. The organization chart of the corporate management which relates to the operation of this station and the normal functional organization chart for operation of the station are shown in Figure 5.1,1.

C. The shift manning for the station shall be as shown in Section 6.0, Table 6.1.1 of DPR-19 and DPR-25.

D. Qualifications of the station management and operating staff shall meet minimum acceptable levels as described in ANSI N18.1,

" Selection and Training of Nuclear Power Plant Personnel," dated March 8, 1971, with the exception of the Radiological-Chemical Supervisor who shall meet or exceed the qualifications of Radiation Protection Manager of Regulatory Guide 1.8, September, 1975, and the Shift Technical Advisor shall have a bachelor's degree or equivalont in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant for transients and accidents. The individual filling the porltion of Assistant Superintendent - Technical Services shall meet the minimum acceptable level for " Technical manager" as described in 4.2.4 of ANSI N18.1 - 1971.

R. Retraining and replacement training of Station personnel shall be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant Forsonnel " dated march 8, 1971.

A training program for the fire brigade shall be maintained under the direction of the Operating Engineer and shall meet or exceed the requirements of.Section 27 of the NFPA code - 1975, except for fire brigade training sessions which shall be held at least quarterly.

F. Retraining shall be conducted at intervals not exceeding two years.

C. The Review and Investigative Function and the Audit Function of activities affecting quality during facility operations shall be consti*.uted and have the responsibilities and authorities outilned below:

1. The Supervisor of the off-site Review and Investigative Function shall be appointed by the Vice President-Nuclear
Oporttions. The Audit Function shall be the responsibility of the htnager of Quality Assurance and shall be independent of operations.

> l

i.

l 5-1 l l

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' . - - - - - . - - . , 2.'~ ~:Kr:- ~ * ~~ ~ ~ r : K 2 L - - - -

Dresd:n I DPR-2 Amanda:nt No.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

a. Off-Site Review and Investlantive Function The Supervisor of the off-Site Review and Investigative Function shall: (1) provide directions for the review and investigative function and appoint a senior participant to provide appropriate direction. (ii) select each participant for this function, (111) select a complement of more than one participant who collectively possess background and qualifications in the subject matter under review to provide comprehensive interdisciplinary review coverage under this function, (iv) independently review and approve the findings and recommendations developed by personnel performing the review and investigative function (v) approve and report in a timely manner all findings of noncompliance with NRC requirements and provide recommendations to the Station Manager, Assistant Vice President and General Manager - Nuclear Stations, Manager of Quality Assurance, and the Vice President-Nuclear Operations. During periods when the Supervisor of the off-Site Review and Investigative Function is unavailable, he shall designate this '

responsibility to an established alternate who satisfies the formal training and experience requirements for the Supervisor of the Off-Site Review and Investigative

, Function.

The responsibilities of the personnel performing this

,' function are stated below. The Off-Site Review and Investigative Function shall review:

(1) The safety evaluations for 1) changes to procedures, equipment or systems as described in the safety analysis report and 2) tests or experiments completed

+

under the provision of 10 CFR Section 50.59 to verify thet such actions did not constitute unreviewed safet; questions. Proposed changes to the Quality Assurance P-ogram description shall be reviewed and approved by the Manager of Quality Assurance.

' (2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR Section 50.59.

(3) Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR Section 50.59.

(4) Proposed changes in Technical Specifications or NRC l Amended licenses.

5-2  !

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E Dessd n I DPR-2 Amendment N3.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

(5) Noncompliance with NRC requirements, or of internal procedures or instructions having nuclear safety significance.

(6) Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety as referred to it by the On-Site Review and Investigative Function.

(7) Reaortable events reportable under 10 CFR 50.73.

(8) All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety related structures', systeme or components.

(9) Review and report findings and recommendations regarding all changes to the Generating Stations Emergency Plan prior to implementation of such changes. 1 (10) Review and report findings and recommendations regarding all items referred by the Technical Staff Supervisor, Station Manager, Assistant Vice President and General Manager - Nuclear Stations and Manager of Quality Assurance.

b. Audit Function The Audit Function shall be the responsibility of the Manager of Qus11ty Assurance independent of the Production Department. Such responsibility is delegated to the Director of Quality Assurance (Operations) and the Director of Quality Assurance (Maintenance).

Rither of the above, or designated Corporate Staff or Supervision approved by Manager of Quality Assurance, shall approve the audit agenda and checklists, the findings and the report of each audit. Audits shall be performed in accordance with the Company Quality Assurance Program and Procedures. Audits shall be performed to assure that safety-related functions are coverod within the period designated below:

(1) Audit of the Conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per year.

(2) Audit of the adherence to procedures, training and gtalification of the station staff at least once per year.

5-4 4

3

Dessd:n I DPR-2 Amendment No.

5.0 ADNINISTRATIVE CONTROLS (Cont'd)

(3) Audit of the results of actions taken 'to correct deficiencies occurring in facility equipment, structures, systems or methods of operation that affect nuclear safety at least once per six months.

(4) Audit of the performance of activities required by the Quality Assurance Program to meet the Criteria of Appendix "B", 10 CFR 50.

(5) Audit of the Facility Emergency Plan and implementing procedures at least once per 12 months.

(6) Audit of the Facility Security Plan and implementing procedures at least once per 12 months.

(7) Audit On-Site and Off-Site reviews.

(8) Audit of Facility Fire Protection Program and implementing procedures at least once per 24 months.

(9) The radiological environmental monitoring program and the results thereof at least once per 12 months.

(10) The ODCM and implementing procedures at least once per 24 months.

(11) Report all findings of noncompliance with NRC requirements and recommendations and results of each audit to the Station Manager, the Assistant Vice President and General Manager-Nucleer Stations, Manager of Quality Assurance, the General Superintendent of Production Systems Analysis, and to the Vice President-Nuclear Operations,

c. Authority The Manager of Quality Assurance reports to the Chairman and President. The Supervisor of the Off-Site Review and Investigative Function reports to the Manager of Nuclear Safety who reports to the Chairman and President. Either the Manager of quality Assurance or the Supervisor of the Off-Site Review and Investigative Function has the authority to request any action which he deems necessary ,

to avoid unsafe plant conditions,

d. Records t

(1) Reviews, audits and recommendations shall be k g

documented and distributed as covered in 5.1.C.1.a and 5.1.C.1.b. i 5-5

s .

Decsd:n I DPR-2 Amendment Ns.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

(2) Copies of documentation, reports, and correspondence shall be kept on file at the station.

e. Procedures Written administrative procedures shall be prepared and maintained for the Off-Site Review and Investigative Functions described in specifications 5.1.G.1.a. These procedures shall cover the following:

(1) Content and method of submission of presentations to the Supervisor of the off-Site Review and Investigative Function.

(2) Use of committees and consultants.

(3) Review and approval.

(4) Detailed listing of items to be reviewed.

(5) Method of (a) appointing personnel, (b) performing reviews, investigations, (c) reporting findings and recommendations of reviews and investigations, (d) approving reports, and (e) distributing reports.

(6) Determining satisfactory completion of action required based on approved findings and recommendations reported by personnel performing the review and investigative function.

f. Personnel (1) The persons, including consultants, performing the review and investigative function, in addition to the Supervisor of the off-Site Review and Investigative Function, shall have expertise in one or more of the following disciplines as appropriate for the subject or subjects being reviewed and investigated.

(a) nuclear power plant technology (b) reactor operations (c) utility operations (d) ,, power plant design (e) reactor engineering (f) radiological safety (g) reactor safety analysis I

(h) instrumentation and control (1) metallurgy (j) any other appropriate disciplines required by unique characteristics of the facility.

I 5-6

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~*+-.-****'~~-'*"-***-+-Q

Drosdan I DPR-2 1 -

Amendment Ns.

5.0 ADNINISTRATIVE CONTROLS (Cont'd)

(2) Individuals perfceming the Review and Investigative Function shall possess a minimum formal training and experience as listed below for each discipline.

(a) Nuclear Power Plant Technolony Engineering graduate or equivalent with 5 years experience in the nuclear power field design and/or operation.

(b) Eeactor operations Engineering graduate or equivalent with 5 years experience in nuclear power plant operations.

(c) Utility Operations Engineering graduate or equivalent with at least 5 years of experience in utility operation

. and/or engineering.

(d) Power Plant Deslan Engineering graduate or equivalent with at least 5 years of experience in power plant design and/or operation.

(e) Reactor Engineerinz Engineering graduate or equivalont. In addition, at least 5 years of experience in nuclear plant engineering, operation, and/or graduate work in nuclear engineering or equivalent in reactor physics is required.

(f) Eadiolomical Safety Engineering graduate or equivalent with at least 5 years of experience in radiation control and safety.

(g) Safety Analysis Engineering graduate or equivalent with at least 5 years of experience in nuclear engineering.

(h) Instrumentation and Control Engineering graduate or equivalent with at least 5 years of experience in instrumentation and control design and/or operation.

I 8,

5-7 .

__. . . . . . . _ . . _ . . . __ __. . _ _ . - . _ . _.-_m

  • . Dessdsn I DPR-2 Amendment No.

5.0 FMINISTRATIVE CONTROLS (Cont'd)

(1) Meta 11uray Engineering graduate or equivalent with at least 5 years of experience in the metallurgical fleid.

(3) The Supervisor of the Off-Site Review and Investigative Function shall have experience and training which satisfy ANSI N18.1 - 1971 requirements for plant. managers.

2. The On-Site Review and Investigative Function shall be super-vised by the Station Manager. The Station Manager can desig-nate this responsibility to an alternate who satisfies the ANSI N18.1 (March 8, 1971) experience requirements for Plant Manager.
a. On-Site Review and Investiaative Function The Station Manager (or designee) shall: (1) provide direction for the Review and Investigative Function and appoint the Technical Staff Supervisor, or other comparably qualified individual as a senior participant to provide appropriate direction; (ii) approve participants for this function; (iii) assure that a complement of more than one participant who collectively possess background

,' and qualifications in the subject matter under review are selected to provide comprehensive inter-disciplinary 5 review coverage under this function; (iv) Independently review and approve the findings and recommendations developed by personnel performing the Review and Investigative Function; (v) report all findings of noncompliance with NRC requirements, and provide recommendations to the Assistant Vice President and General Manager-Nuclear Stations and the Supervisor of the off-site Review and Investigative Function; and (vi) submit to the Off-Site Review and Investigative Function for concurrence in a timely manner, those items described in Specification 5.1.G.1.a which have been approved by the On-Site Review and Investigative Function.

The responsibilities of the pe; sonnel performing this function are stated below:

(1) Review of: 1) procedures required'by Technical

Specification 5.2 and changes thereto, 2) any other proposed procedures or changes thereto as determined by the Station Manager (or designee) to affect nuclear safety.

(2) Review of all proposed tests and experiments that 1

affect nuclear safety.

5-8  !

e eme es ee- e . . ,es-+..

O

Drosd n I DPR-2 Amendment N2.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

(3) Review of all proposed changes to the Technical specifications.

(4) Review of all proposed changes or modificationc to plant systems or equipment that affect nuclear safety.

(5) Investigation of all noncompliance with NRC requirements and shall prepare and forward a report covering evaluation and recommendations to prevent recurrence to the Assistant Vice President and General Manager-Nuclear Stations and to the supervisor of the off-site Review and Investigative Function.

(6) Review of facility operations to detect potential safety hazards.

(7) Forformance of special reviews and investigations and reports thereon as requested by the Supervisor of the off-site Review and Investigative Function.

~

(8) Review the Station Security Plan and shall submit recommended changes to the Assistant Vice President and General Nanager-Nuclear Stations.

(9) Review the Emergency Plan and station implementing procedures and shall submit recommended changes to the Assistant Vice President and General Manager-Nuclear Stations.

(10) Review of reportablo events and actions taken to prevent recurrence.

(11) Review of any unplanned on-site release of

, esdioactive material to the environs including the preparation and forwarding of reports covering ,

evaluation recommendations and disposition of the corrective action to prevent recurrence to the Assistant Vice President and General Nanager-Nuclear Stations, and to the supervisce of the off-site Review and Investigative Function.

(12) Review of changes to the ODCM and major changes to the radweste treatment systems.

5-9 a

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5 Desadsn I DPR-2 i' Amendment No.

s 5.0 ADMINISTRATIVg CONTROLS (Cont'd)

b. Authority The Technical Staff Supervisor is responsible to the Station Manager (or designee) and shall make recommendations in a timely manner in all areas.of

+

review, investigation, and quality control phases of plant maintenance, operation and administrative procedures relating to facility operations. The Technical Staff E1pervisor sha,11 have the authority to

- request the action necessery to ensure compliance with '

rules, regulations, and procedures when in his opinion such action is necessary. The Station Managar (or designee) shall follow such recommendations or select a course of action that is more conservative regarding safe operation of the facility. All such disagreements shall be reported immediately to the Assistant Vice Prec1 dent and General Manager-Nuclear Stations and the Supervisor of the Off-site Review and Investigative Function. s s  %

. c. Records t (1) Reports, reviews, investigations, and recom-mandations shall be documented with copies to the Assistant Vice President and General Manager-Nuclear

, Stations, the Supervisor of the off-site Review and Investigative Function, the Station Manager (o'r

., designee) and the Manager of Quality Assuranc'e; ,

(2) Coples of all records and documentation sha'11 be kept on file at the station. -

N d.* Procedures s, .

(

Written administrative procedures shall be prepared and maintained for conduct of the on-site Review and Investigative Function. These procedures shall include the following:

(1) Content and method of submission and presentation to the Station Manager (or designee). Assistant Vice

, . President and General Manager-Nuclear Stations and the Supervisor of the Off-Site Review and -

Investigative Function. ,

(2) Use of committees.

(3) keview and approval.

(4) Detailed listing of items to be reviewed.

5-10 i

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Dresdan I DPR-2

. '

  • Amendment N3.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

(5) Procedures for administration of the quality control activities.

(6) Assignment of respons1bilities.

e. Personnel (1) The personnel performing the On-Site Review and Investigative Function, in addition to the Station Manager (or designee), shall consist of persons having expertise in:

(a) nuclear power plant technology (b) reactor operations (c) reactor engineering (d) radiologleal safety (e) chemistry (f) instrumentation and control (g) mechanical and electric systems.

(2) Personnel performing the On-Site Review and Investi-gative Function shall meet minimum acceptable levels as described in ANSI N18.1-1971 Sections 4.2 and 4.4 M. Fire Protection.

1. An independent fire prote: tion and loss prevention program inspection and audit shall be performed at least once per 12 months utilizing either quallfled off-site licensee personnel or an outside fire protection firm.
2. An inspection and audit of the fire protection and loss prevention program shall be performed by a qualified outside fire consultant at least once per 36 months.

5.2 Plant Operatina Procedures A. Detailed written procedures including aggk1ceble checkoff lists covering items listed below shall be prepared, approved, and adhered tot

1. Normal startup, operation, and shutdown of systems and components involving nuclear safety of the facility.
2. Accions to be taken to correct specific and foreseen potential 9alfunctions of systems or components including responses to alarms.
3. Emergency conditions involving potential or actual release of i radioactivity " Generating Stations Emergency Plan" and station emergency and abnormal procedures.

I 5-11 j'

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  • Decedsn I DPR-2 Amsndment Ns. 1 5.0 ADMINISTRATIVE CONTR0t.S (Cont'd) 4 Instrumentation operation which could have an effect on the safety of the facility.
5. Preventive and corrective maintenance operations which could have an effect on the safety of the facility.
6. Surveillance and testing requirements.
7. Tests and experiments.
8. Station Security Plan and implementing procedures.
9. Fire Protection Program implementation.
10. ODCM implementation.
11. Working hours of the Shift Engineer, Station Control Room l Engineer, Shift Foreman, and Nuclear Station Operator job classifications such that the heavy use of overtime is not ,

routinely required.

B. Radiation control procedures shall be maintained, made available to all station personnel and adhered to. These procedures shall show permissible radiation exposure and shall be consistent with the requirements of 10 CFR 20. This radiation protection program shall be organized to meet the requirements of 10 CFR 20.

C. 1. Procedures for items identified in Specification 5.2.A and any changes to such procedures shall be reviewed and approved by

- the operating Engineer and the Technical Staff Supervisor in the areas of operation, fuel handling, or instrument maintenance, and by the Assistant Superintendent-Maintenance and Technical Staff Supervisor in the areas of plant maintenance and plant inspection. Procedures for items identified in Specification 5.2.5 and any changes to such procedures shall be reviewed and approved by the Radiological Chemical Supervisor. At least one person approving each of the above procedures shall hold a valid senior operator's license for Dresden Units 2 and 3. In addition, these procedures and changes thereto must have authorization by the Production or Services Superintendent before being implemented.

2. Werk and instruction ty'pe procedures which implement approved maintenance or modification procedures shall be approved and authorized by the Assistant Superintendent-Maintenance where the written authority has been provided by the Production ,

Superintendent. The " Maintenance /Nodification Procedure" utillzed for safety related work shall be so approved only if procedures referenced in the " Maintenance /Nodification  !

Procedure" have been approved as required by 5.2.A. Procedures which do not fall within the requirements of 5.2.A or 5.2.B may be approved by the Department Heads.

5-12

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    • Drosd:n I DPR-2 Am:ndment No.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

D. Temporary changes to procedures 5.2.A and 5.2.B above may be made provided:

1. The intent of the original procedure is not altered.
2. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License for Dresden Units 2 and 3.

2

3. The change is documented, reviewed by the on-site Review and Investigative Function and approved by the Production or Services Superintendent within 14 days of implementation.

R. Drills of the emergency procedures described in Specification 5.2.A.3 shall be conducted at the frequency specified in the Generating Station Emergency Plan. These drills will be planned so that during the course of the year, communication links are tested and outside agencies are contacted.

5.3 Action to be Taken in the Event of a Reportable Event in Plant Operation Any reportable event shall be promptly reported to the Assistant Vice President and General Manager-Nuclear Stations or his designated alternate. The incident shall be promptly reviewed pursuant to Specification 5.1.C.2.a(5) and a separate report for each reportable event shall be prepared in accordance with the requirements of specification 5.5.8.

5.4 Plant Operating Records A. Records and/or loss relative to the following items shall be kept in a manner convenient for review and shall be retained for at least five years.

1. Records of normal. plant operation, including power levels and periods of operation at each power level.
2. Records and reports of reportable events.
3. Records and periodic checks, inspection and/or calibrations performed to verify the Surveillance Requirements (See Section 4 of these Specifications) are being met. All equipment l

falling to meet surveillance requirements and the corrective action taken shall be recorded.

4. Records of changes made to the equipment or reviews of tests aLd experiments to comply with 10 CFR 50.59.

i 5. Records of physics tests and other tests pertaining to nuclear safety.

I 1

i 5-13 l

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_ _ _ _ - _ _ __. v v~ ~ ~ - - - - - - -m----~- ----

Dessd:n I DPR-2 Amendment No.

5.0 ADMINISTRATIVE CONTROLS (Cont'd)

6. Records of changes to operating procedures.
7. Shift Engineers Logs.
8. By-product material inventory records and source leak test results.

B. Records and/or logs relative to the following items shall be recorded in a manner convenient for review and shall be retained for the life of the plant.

1. Substitution or replacement of principal items of equipment pertaining to nuclear safety.
2. Changes made to the plant as it is described in the Safety Analysis Report.
3. Records of spent fuel inventory and assembly histories.
4. Updated, corrected, and as-bu11t drawings of the plant.
5. Records of plant radiation and contamination surveys.
6. Records of off-site environmental monitoring surveys.
7. Records of radiation exposure for all plant personnel, including all contractors and visitors to the plant in accordance with 10 CFR 20.
8. Records of radioactivity in liquid and gaseous wastes released to the environment.
9. Records of individual staff members indicating qualifications, experience, training and retraining.
10. Minutes of meetings and results of reviews performed by the Off-site and On-Site Review Functions.

5.5 REPORTING REOUIREMENTS In addition to the applicable reporting requirements of Title 10, code of Federal Regulations, the following identified reports shall be submitted to the Regional Administrator of the appropriate Regional Office of the NRC unless otherwise noted.

m 9

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  • Decsden I DPR-2 Amendment No.

)

l 5.0 ADMINISTRATIVR CONTROLS (Cont'd)  ;

A. Routine Reports A tabulation shall be submitted on an annual basis of the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 meen/hr and their associated man rem exposure according to work and job functions, (See Note); i e.g., routine maintenance, special maintenance (describe maintenance) and waste processing. The dose assignment to various duty functions may be estimates based on pocket dosimeter. TLD, or film badge measurements. Small exposures totaling less than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of'the total whole body dose received from external sources shall be assigned to specific major work.

B. Reportable Events Reportable events will be submitted as required by 10 CFR 50.73.

C. Unione Reportina Requirements

1. Radioactive Effluent Release Report (Semi-Annual)

A report shall be submitted to the Commission within 60 days after January 1 and Jlaly 1 of each year specifying the quantity of each of the princ1' pal radionuelldes released to unrestricted

~

areas in liquid and gaseous effluents during the previous 6 months. The format and content of the report shall be in accordance v'th Regulatory Guide 1.21 (Revision 1) dated June 1974.

2. Environmental Radioactivity Data (Annual Report)

Reference DPR-19 and DPR-25, Section 6.6.C.2.a.(1) and Section 6.6.C.2.a.(2).

3. Special Reports '

A specfs1 report shall be submitted for Radioactive Source Leak Testing only if the tests reveal the presence of 0.005 micro-curies or more of removable contamination. Specification 3.0.F.

Note: This tabulation supplements the requirements of 20.407 of 10 CFR Part 20.

5-15 ML

P 1

ATTACHMENT 2

SUMMARY

OF PROPOSED CHANGE f

a 1078K

l l

l SUMMAPY OF CHANGES Due to the retirement of Dresden Unit 1, the Operating License and Technical Specifications are being revised to reflect the non-operating status. Major portions of the License and Technical Specifications are being deleted as they deal with reactor operation and/or are obsolete for a defueled unit. Sections pertaining to Definitions, Site, Radioactive Materials, Fuel Storage, Fire Protection, Auxiliary Electric Power and Administrative Controls are being retained and revised where necessary to reflect the status of the facility. The revised Technical Specifications are being put in the DPR-19 and DPR-25 format and are being renumbered. The following pages summarize the changes. Note that the page numbers referenced relate to the existing Dresden Unit 1 License and Technical Specifications, not the revised page numbering in the enclosed amendment.

1078K

. - - ^

MM hh ge_. r CPERATING LICENSE Pame/Section Chante Page 1 Change the Amendment No. to 36, delete the Page 1. Title word " Operating" from the title.

Page 1, Paragraph 15 Delete - pertains to construction of Unit 1.

Paga 1 Paragraph IC Change the word " operate" to "be maintained". Renumber to paragraph 18.

Page 1 Paragraph 1D Change the word " operating" to " amended".

Renumber to paragraph IC.

Page 1. Paragraph II Change the word " operating" to " amended".

Renumber to paragraph ID.

Page 2 Paragraph 1G Change the word " operating" to " amended".

Renumber to paragraph IF.

Page 2. Paragraph 2 Delete the words " Operating".

Page 2, Paragraph 2.B.(1) Insert the words " maintain but not to" before the word " operate".

Page 2, Paragraph 2.B.(2) Delete the words " receive" and "and use" with regard to special nuclear materials and delete the words "and enounts required for operation".

Page 2 Paragraph 2.B.(3) Delete the words " receive" and "and use" with regard to plutonium. Change the words "for use in connection with operation of the facility" to " utilized in previous operations of the facility".

Page 2 Paragraph 2.B.(4) Delete the words " receive" and "and use" with regard to by-product source and-special nuclear materials. Break up sentence so that the words " receive possess

, and use" precede " sealed sources for reactor instrumentation and radiation monitoring equipment calibration".

Page 2, Paragraph 2.B.(6) Insert the word " receive" before

" possess". Change the word "be" to "have been" before the words " produced by the operation of the facility".

Page 3. Paragraph 2.C.(1) Delete - pertains to reactor power operation.

0071a

l Pame/Section chanae Page 3, Paragraph 2.C.(2) Delete the reference to Appendix B, which no longer exists. Change the word

" operate" to " maintain" in the second sentence. Renumber to paragraph 2.C.(1).

Change the Amendment No. to 36.

Page 3. Paragraph 2.C.(3) Delete - pertains to modifications commitments that were required to return Unit I to service in November, 1978.

Page 3. Paragraph 2.C.(4) Delete - pertains to exemption of 10CFR 50.46, Appendix K, that involves emergency systems.

Page 4. Paragraph 2.C.(5) Delete - pertains to reactor power operation.

Page 5. Paragraph 2.C.(6) Delete'- pertains to the diesel generator which no longer exists.

Page 5. Paragraph 2.E. Delete - pertains to Security which is covered by 10CFR.

Page 6, Paragraph 2.F. Delete - pertains to Fire Protection Bodifications.

D. L. Ziemann lettee to Delete - pertains to modifications required R. L. Bolger, dated June 23 to return Unit 1 to service in 1977.

1976 (with attachment) 0071a 1

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TECHNICAL SPECIFICATIONS Pase/Section Chaame Title Page Change the word " Operating" in the title to

" Amended Fa-ility".

page 1. Table of Contents Eenumbcr the following sections:

, Section 5.0 becomes 2.0 Section 6.0 becomes 5.0 Section 6.1 becomes 5.1 Section 6.2 becomes 5.2 Section 6.3 becomes 5.3, and change

" Occurrence" to " Event".

Section 6.5 becomes 5.4 Section 6.5 becomes 5.5 Delete the following sections:

2.1, 1.2, 2.1, 2.2, 3.0 page 11. Table of Contents Delete the following sections:

3.1, 3.2, 3.3, 3.4, 3.5 page 11~1. Table of Contents Delete the following sections:

3.6. 3.7, 3.8.B 3.10.A 3.10.B, 3.10.D, 3.10.E, 3.11, 3.13 Renumber the following sections:

33ction 3.8 becomes section 3.0 Section 3.8.C becomes 3.0.5 Section 3.8.D becomes 3.0.C Section 3.8.E becomes 3.0.D section 3.8.F become's 3.0.E Section 3.8.C becomes 3.0.F section 3.9 becomes 3.1 Section 3.10 becomes 3.2, and heading is changed to " Fuel Handling and Storage".

Section 3.10.C becomes 3.2.A Add new section 3.2.8 Nuclear Fuel Section 3.12 becomes 3.3 Add Surveillance Requirement Sections:

4.0, 4.1, 4.2, 4.3, to correspond to 3.0, 3.1, 3.2, 3.3, limiting condition #

for Required Equipment.

Add List of Tables and List of Figures 1

0071a

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Pane /Section Chanze Definitions Pages 1 thru 6 Delete - A, B, C, J, H, I, K, L L1, L2, L3, L4, O, P, Q, Ql, Q2, Q3,- Q4, R. R1, R2, R3, R4, S T, U, V, W I, Y, Yl, Y2, AA.

The definitions deleted refer to refueling, reactor operations and instrumentation required for reactor operstions. These are no longer applicable.

Renumber:

Definition D becomes H Definition R becomes B Definition F becomes C Definition G becomes D Definition M becomes E Definition N becomes F Definition BB becomes G Pages 7 thru 15 Delete - pertains to Fuel Cladding Sections 1.1, 2.1 Integrity safety limits. These limits protect the fuel cladding during power opecation; since reactor operation will no longer occur this section is not needed.

i l Pages 16 thru 19 Delete - pertains t; Reactor Coolant System Sections 1.2, 2.2 safety limits. Because no fuel will be in the reactor and reactor operations will no longer occur, limits on the coolant system are not required.

Pages 19a, 19b, Delete - pertains to Limited condition for section 3.0 Operation. Actions to shutdown the reactor are no longer applicable since the reactor will not be operated.

Pages 20 thru 37, Delete - pertains to Reactor Protection Sections 3.1, 4.1 System. With no fuel in the reactor there is no need for a control rod drive system or reactor scram.

Pages 38 thru 46, Delete - pertains to Protective Instrumen-Sections 3.2, 4.2 tation. This type of instrumentation referred to in this section was needed to mitigate the effects of a reactor accident. Since the reactor will not be operated, accidents of this nature are not 1

possible.

Pages 47 thru 54A, Delete - pertains to Reactivity Control.

Sections 3.3, 4.3 With no fuel in the reactor there is no reactivity to control; hence, this section is no longer applicable.

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Pano/Section Chante Pages 55 thru 59, Delete - pertains to Standby Liquid Control Sections 3.4, 4.4 System. This system provided a back-up method to shutdown the reactor. Since there is no fuel in the reactor it is no longer needed.

Pages 60 thru 64, Delete - pertains to Core and Containment Sections 3.5, 4.5 Cooling Systems. With the core unloaded there is no possibility of a Loss of Coolant Accident; hence, this section is not needed.

Pages 65 thru 76c, Delete - pertains to Primary System sections 3.6, 4.6 Boundary. This section ensured the integrity of the Primary System. Since the reactor will not be fueled nor operated there is no need to ensure this boundary is maintained.

Pages 86 thru 93 Delete - pertains to Containment Systems.

Sections 3.7. 4.7 Primary containment is not needed when the reactor is defueled; hence, it is being deleted.

Pages 94 thru 110, Revised sections to update radioactive sections 3.8, 4.8 effluent monitoring that remains applicable to the unit without reactor operation. New section numbers 3.0 and 4.0.

Pages 111 thru 116, Revised sections to address the Unit 1 125 sections 3.9, 4.9 volt battery which provides switching to 138 K7 yard, and to address the Unit 1 Diesel Pire Pump batteries required to be operable for fire protection. New section numbers 3.1 and 4.1.

I Pages 117 thru 122 Revised sections to change the title to j sections 3.10, 4.10 " Fuel Handling and Storage", and to l restrict fuel loadin; into the reactor l

core. New section cambers 3.2 and 4.2.

Pages 122A thru 122c, Delete - pertains to integrity of piping

, Sections 3.11, 4.11 necessary for safe shutdown. The reactor l is shutdown and will not be operated; hence, safe shutdown concerns are no longer applicable.

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Pano/Section Eggggg Pages 122d thru 122-la, Revised sections to address those Fire Hose Sections 3.12, 4.12 Stations required to be operable due to their location in the plant, and the Fire Pump Diesel Engine required to be I operable. New section numbers 3.3 and 4.3.  !

Pages 122m, 122n, Delete - pertains to Fuel Cladding

  • Integrity required during reactor operation.

Sections 3.13, 4.13  !

Page 123, Section 5.0 Revised section to only address ' site' infoenation and the Fuel Storage Pool. New section number 2.0.

Pages 124 thru 146, Revised section to reflect the recent Section 6.0 station organization changes, as in DPR 19 and 25, Jection 6.0. Delete sections referring to reactor operation, refueling operations, obsolete reporting requirements, and the shift manning chart.

New section number 5.0.

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The following additional changes to the Technical Specifica-tions reflect recent organizational and administrative changes. Page number references relate to the enclosed, revised Technical Specifica-tions, agi to the paging convention in the current Technical .

Specifications.

The " Radiological Safety and Chemistry" discipline for the On-Site Review and Investigative Function has been split into two separate disciplines, " Radiological Safety" and " Chemistry", because some participants possessing this discipline were not qualified in both .

Radiological Safety and Chemistry.

Sections referring to persons holding a Senior Reactor Operator's License have been changed to persons holding a Senior Reactor Operator's License for Dresden Units 2 and 3 because Senior Reactor Operator's Licenses for Unit i vill no longer be issued, are presently held by very few persons remaining at Dresde~n Station and are no longer required for a non-operating unit.

The following Te hnical Specification pages have been changed:

Page 5-2/ Paragraph 5.1.G.I.a. Changed the title " Division Page 5-4/ Paragraph 5.1.G.I.a.(10) Vice President and General Page 5-5/ Paragraph 5.1.G.1.b. (11) Manager-Nuclear Stations" to Page 5-8/ Paragraph 5.1.G.2.a. " Assistant Vice President Page 5-9/ Paragraphs 5.1.G.2.a.(5) and General Manager-Nuclear 5.1.G.2.a.(8) Stations".

5.1.G.2.a.(9)

.~ 5.1.G.2.a.(11)

Page 5-10/ Paragraphs 5.1.G.2.b.

5.1.G.2.c.

5.1.G. 2. d. (1)

Page 5-13/Section 5.3 Page 5-4/ Paragraph S.I.G.1.b. Changed the title " General Supervisor of Quality Assurance (Maintenance)" to

" Director of Quality Assurance (Maintenance)".

f Page 5-11/ Paragraph 5.1.G.2.e. (1) Split the (d) radiological safety and chemistry disci-pline into (d) radiological safety and (e) chemistry.

Page 5-12/ Paragraph 5.2.C.1. Added the words "for Dresden Page 5-13/ Paragraph 5.2.D.2. Units 2 and 3" following

" Senior Reactor Operator's License".

5 ATTACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION 1078K

, a SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF AMENDMENT REQUEST

' The proposed amendments to the Operating License and Technical Specifications for Dresden Station Unit I reflect the nonoperating status of the recently retired unit. Several sections of the License and Techni-cal Specifications pertaining to reactor operation have been deleted for the above stated reason. Since nuclear fuel still remains in the fuel storage pool, radioactive materials exist throughout Unit 1, and fire protection equipment and auxiliary electrical power remain necessary to i support the site which is common also to Dresden Units 2 and 3, other sections of the License and Technical Specifications are being revised and retained. These revised sections comprise the proposed Unit 1 License and Technical Specifications.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION Commonwealth Edison has performed an evaluation of the hazards consideration associated with the proposed License and Technical Specifica-tion amendments utilizing the criteria in 10CFR 50.92. Our evaluation is provided below and specifically addresses the three criteria of 10CFR 50.92(c) i for the change described above.

The proposed amendments do not involve a significant increase in the probability or consequence of an accident previously evaluated. In .

fact, the amendments reflect the present swd 04ture nonoperating status of Unit I which considerably reduces the .likelinool of an accident and generally ,

i the consequences, also. The Final Hazards Summary Report, FHSR, addressed numerous design basis accidents all of which originated from a fueled and.

operating reactor. The proposed amendments specifically prohibit operation i of the reactor and the loading of fuel into the reactor. Therefore, acci-dents such as loss-of-coolant, overpressurization, failure to scram, loss of reactor recirculation pumps, etc. are no longer possible. The FHSR also briefly addressed off site doses from gaseous and liquid effluents. The nonoperating status of the unit has reduced the production of such radio-active materials thus significantly reducing release of such material to the environmaat. The retained and amended portions of the Technical l Specifications ensure radioactive effluents are monitored and controlled such that 10CFR 20 limitations and DPR-19 (Unit 2) and DPR-25 (Unit 3) limitations are not exceedad. Fire protection, auxiliary power, security i

and spent fuel pool water level are all maintained as needed. Thus, no new accident scenarios are created, but rather the number of accident scenarios are significantly reduced.

The proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated. Restrictions in the proposed Technical Specifications prohibit the loading of fuel into the

reactor which then eliminates all of the design basis accidents described in the FRSR. Retention end changes to Technical Specification sections d

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pertaining to the spent fuel pool, fire protection systems,' auxiliary power, radioactive effluents and administrative controls ensure that l no new accident scenarios will be created. The overall effect of not l I

operating and not fueling Unit I significantly reduces the number of accident scenarios and does not create any new ones. 1 The proposed amendments do not involve a significant reduction in the margin of safety because adequate controls are placed on prohibiting reactor operation, on maintaining spent fuel pool water level and monitor-ing and restricting radioactive effluents from Unit 1. Also, portions of the auxiliary electrical system and fire protection system necessary to provide protection for Units 2 and 3 are required to be operable and to be monitored. Administrative controls are also retained and updated to pro-vide reviews and approvals of procedures, operation, tests, experiments, etc. commensurate with the status of the facility.

For the reasons stated above, Commonwealth Edison finds that the proposed amendments do not involve a significant hazards consideration based on the criteria of 10 CFR 50.92(c). We therefore request approval of the proposed amendments under the provisions of 10 CFR 50.91(a)(4).

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