ML21179A047

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4 to Final Safety Analysis Report, Chapter 13, Conduct of Operations
ML21179A047
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 06/21/2021
From:
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML21179A042 List:
References
RS-21-066
Download: ML21179A047 (33)


Text

DRESDEN UFSAR Rev. 8 June 2009 13.0 CONDUCT OF OPERATIONS TABLE OF CONTENTS Page 13.0 CONDUCT OF OPERATIONS 13.1-1 13.1 ORGANIZATIONAL STRUCTURE 13.1-1 13.1.1 Corporate Management and Technical Support Organization 13.1-1 13.1.2 Plant Operating Organization 13.1-1 13.1.3 Plant Personnel Responsibility and Authority 13.1-1 13.1.4 Deleted 13.1-1 13.1.5 Deleted 13.1-1 13.1.6 Deleted 13.1-1 13.1.7 Operating Shift Crews 13.1-1 13.1.8 Qualifications of Nuclear Plant Personnel 13.1-2 13.1.9 References 13.1-2 13.2 TRAINING 13.2-1 13.2.1 Plant Training Programs 13.2-1 13.2.1.1 Training Programs for Licensed Personnel 13.2-1 13.2.1.2 Training Programs for Non-Licensed Personnel 13.2-2 13.2.1.3 Nuclear General Employee Training 13.2-4 13.2.1.4 Fire Brigade Training 13.2-4 13.2.2 Replacement Training and Retraining 13.2-4 13.2.3 Applicable NRC Documents 13.2-5 13.3 EMERGENCY PLANNING 13.3-1 13.3.1 References 13.3-1 13.4 REVIEW AND AUDIT 13.4-1 13.4.1 Onsite Review and Investigative Function 13.4-1 13.4.2 Onsite Review and Investigative Function 13.4-1 13.5 PLANT PROCEDURES 13.5-1 13.5.1 Administrative Procedures 13.5-1 13.5.1.1 Conformance with Federal Guidelines 13.5.1 13.5.1.2 Preparation of Procedures 13.5-1 13.5.1.3 Procedures 13.5-2 13-i

DRESDEN UFSAR Rev. 9 June 2011 13.0 CONDUCT OF OPERATIONS TABLE OF CONTENTS Page 13.5.2 Operating and Maintenance Procedures 13.5-3 13.5.2.1 Operating Procedures 13.5-3 13.5.2.2 Other Procedures 13.5-5 13.5.3 Surveillance Procedures 13.5-8 13.5.3.1 Chemistry Surveillances 13.5-8 13.5.3.2 Electrical Surveillances 13.5-9 13.5.3.3 Fire Protection Surveillances 13.5-9 13.5.3.4 Instrument Surveillance Procedures 13.5-9 13.5.3.5 Mechanical Surveillances 13.5-9 13.5.3.6 System Operating Surveillance Procedures 13.5-9 13.5.3.7 Radiation Protection Surveillances 13.5-9 13.5.3.8 Technical Staff Surveillance Procedures 13.5-10 13.5.3.9 Non-Station Work Group Procedures 13.5-10 13.5.4 Corporate Procedures 13.5-10 13.6 SECURITY 13.6-1 13.7 RECORDS 13.7-1 13.7.1 Control Room Records 13.7-1 13.7.2 Plant Operation Records 13.7-1 13.7.3 Procedure Changes 13.7-1 13.7.4 Review Committee Transaction 13.7-2 13.7.5 Radiological and Chemical Records 13.7-2 13.7.6 Maintenance Records 13.7-2 13.7.7 Records of Facility Description and Evaluation 13.7-2 13.7.8 Personnel Records 13.7-2 13-ii

DRESDEN UFSAR Rev. 9 June 2011 13.0 CONDUCT OF OPERATIONS LIST OF TABLES 13.1-1 Deleted 13.2.1 Unit 2 Personnel Training 13.5-1 Deleted 13.7-1 Requirements for Record Retention 13-iii

DRESDEN UFSAR Rev. 01A/Dec. 1995 13.0 CONDUCT OF OPERATIONS LIST OF FIGURES 13.1-1 Deleted 13.1-2 Deleted 13-iv

DRESDEN - UFSAR Rev. 7 June 2007 13.0 CONDUCT OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE 13.1.1 Corporate Management and Technical Support Organization EGC's corporate organization and its functions and responsibilities are described in Section 1.0 of Quality Assurance Program Topical Report NO-AA-10[1] as revised and filed with the NRC.

Organizational charts within this report reflect the current corporate structure and the departments which provide technical support for operation and backup support. Where appropriate, these services are provided by outside groups through contractual agreements.

13.1.2 Plant Operating Organization The overall organization of Dresden Station is in accordance with Chapter 1 of Quality Assurance Program Topical Report NO-AA-10[1] which describes the line of responsibility from the Chairman and Chief Executive Officer down through the station staff.

13.1.3 Plant Personnel Responsibility and Authority The basic job functions of Plant positions are described in QA Topical Report NO-AA-10[1] and Station Administrative Procedures.

13.1.4 Deleted 13.1.5 Deleted 13.1.6 Deleted 13.1.7 Operating Shift Crews Minimum shift manning requirements are listed in Technical Specification Section 5.2 and in the E-Plan.

13.1-1

DRESDEN - UFSAR Rev. 14 June 2021 13.1.8 Qualifications of Nuclear Plant Personnel The station positions requiring possession of an SRO License are described in Section 5 of the Technical Specifications.

Qualifications of the station management and operating staff meet minimum acceptable levels as described in ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants with exceptions and clarifications as noted in Section 5 of the Technical Specifications.

13.1.9 References

1. Quality Assurance Program Topical Report NO-AA-10, "Quality Assurance Program for Nuclear Generating Stations," (current revision).

13.1-2

DRESDEN - UFSAR Rev. 6 June 2005 13.2 TRAINING 13.2.1 Plant Training Programs Dresden Nuclear Station provides training formulated to develop and maintain an organization qualified to operate, maintain, and support the facility in a safe and reliable manner. Achievement of this goal is based on a philosophy of providing training developed from a systems approach to training (SAT). This philosophy is consistent with both Nuclear Regulatory Commission (NRC) requirements 10 CFR parts 50 and 55, as well as the Institute of Nuclear Power Operations (INPO) recommendations for the accreditation of training programs by the National Academy of Nuclear Training. Program descriptions are contained in sections 13.2.1.1 and 13.2.1.2.

Retraining and replacement training of station personnel is conducted in accordance with Technical Specification Section 5.3 Unit Staff Qualifications. The frequency of retraining and continuing training programs are determined by following the SAT-based training process.

13.2.1.1 Training Programs for Licensed Personnel 13.2.1.1.1 Replacement License Training Replacement license training will provide SAT-based training to reactor operator (RO) and senior reactor operator (SRO) candidates in accordance with 10 CFR 55. Replacement license training will comply with SAT-based training requirements by maintaining accreditation.

13.2.1.1.2 License Operator Requalification Training License operator requalification training will provide SAT-based training to ROs and SROs in accordance with 10 CFR 55. License operator requalification training will comply with SAT-based training requirements by maintaining accreditation.

13.2.1.1.3 Simulator Training ROs and SROs may perform control manipulations on the simulator required as part of the training in section 13.2.1.1.1 and 13.2.1.1.2. Training will maintain a certified simulator in accordance with the provisions in 10 CFR 55.

13.2-1

DRESDEN - UFSAR Rev. 5 January 2003 13.2.1.1.4 Training of Licensed Supervisor The shift supervisor training program will comply with the SAT-based training requirements and consists of training in those administrative duty areas above and beyond licensed duties.

13.2.1.1.5 Training for Shift Technical Advisors Shift Technical Advisors not meeting the dual-role SRO/STA requirements as described in section 13.2.1.1, will be trained and qualified in accordance with Option 2 of the Commission Policy Statement on Engineering Expertise (50 FR 43621 October 28, 1985). Shift technical advisor training will comply with the SAT-based training requirements.

13.2.1.2 Training Programs for Nonlicensed Personnel 13.2.1.2.1 Training for Mechanical Maintenance Personnel Mechanical maintenance training will provide SAT-based training to mechanical maintenance personnel in accordance with 10 CFR 50.120. Mechanical maintenance training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.2 Training for Electrical Maintenance Personnel Electrical maintenance training will provide SAT-based training to electrical maintenance personnel in accordance with 10 CFR 50.120. Electrical maintenance training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.3 Training for Instrument Maintenance Personnel Instrument maintenance training will provide SAT-based training to instrument maintenance personnel in accordance with 10 CFR 50.120. Instrument maintenance training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.4 Training for Radiation Protection Personnel Radiation protection training will provide SAT-based training to radiation protection personnel in accordance with 10 CFR 50.120. Radiation protection training will comply with the SAT-based training requirements by maintaining accreditation.

13.2-2

DRESDEN - UFSAR Rev. 5 January 2003 13.2.1.2.5 Training for Chemistry Personnel Chemistry training will provide SAT-based training to chemistry personnel in accordance with 10 CFR 50.120. Chemistry training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.6 Training for Non-licensed Operators Non-licensed operator training will provide SAT-based training to non-licensed operator personnel in accordance with 10 CFR 50.120. Non-licensed operator training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.7 Training for Engineering Support Personnel Engineering support training will provide SAT-based training to engineering support staff in accordance with 10 CFR 50.120. Engineering support training will comply with the SAT-based training requirements by maintaining accreditation.

13.2.1.2.8 Training for Fuel Handlers Fuel Handler Training ensures that Fuel Handlers are adequately trained in the area of systems, components, and task performances required to fulfill the duties and responsibilities of that position.

Fuel handler training will provide SAT-based training to fuel handler personnel.

13.2.1.2.9 Training for Emergency Preparedness Personnel Emergency Preparedness (EP) Training is required for all designated response personnel who may be called upon to assist in an emergency. Station personnel who could be affected by an emergency are provided with training on the Emergency Plan (E-Plan) in order to provide for health and safety of the public, including station employees, and to limit damage to the facility and property.

Emergency Preparedness Training typically consist of the following topics:

A. Generic E-Plan training B. Site-specific E-Plan training C. Emergency Plan Implementing Procedures D. Operating Experiences 13.2-3

DRESDEN - UFSAR Rev. 3 13.2.1.3 Nuclear General Employee Training 13.2.1.3.1 All employees (and others) who require unescorted access to the Protected Area of the station will receive training in the following areas:

a. General description of plant and facilities
b. Emergency Plan procedures
c. Fire Protection Program and Procedures
d. Security Requirements and Practices
e. Safety Program
f. Quality Assurance Program
g. Radiological Protection Program 13.2.1.3.2 All employees (and others) who have unescorted access to Radiation Controlled Areas of the station will receive in-depth instruction in all aspects of radiation protection and, as required, respiratory protection. Subject material will include but will not be limited to the following:
a. Handling radioactive material
b. Controls and access requirements
c. Biological effects of ionizing radiation 13.2.1.3.3 Some employees receive, as part of their specialty training a general plant information course. This course consist of overall plant description, thermodynamic fundamentals, nuclear physics fundamentals, and plant systems fundamentals.

13.2.1.3.4 Review of appropriate department and station procedures are specified in department specialty training programs.

13.2.1.4 Fire Brigade Training A training program for the fire brigade is maintained under the direction of Operating Engineer and meets or exceeds the requirements of Section 27 of the National Fire Protection Association (NFPA)

Code - 1975, except for the fire brigade training sessions which are held at least quarterly.

13.2.2 Replacement and Retraining 13.2.2.1 Licensed Operators - Requalification Training NOTE: All replacement and retraining are embedded within the accredited programs as described in sections 13.2.1.1 and 13.2.1.2.

13.2-4

DRESDEN - UFSAR Rev. 3 13.2.3 Applicable NRC Documents The following is a list of documents referenced in preparation of the Dresden training programs:

a. 10 CFR 50
b. 10 CFR 55
c. 10 CFR 19
d. Generic Letter 87-07
e. Regulatory Guide 1.120
f. Regulatory Guide 1.8
g. Regulatory Guide 8.2
h. Regulatory Guide 8.8
i. Regulatory Guide 8.10
j. Regulatory Guide 8.13
k. NUREG - 0737
l. 50 FR 43621, Option 2 13.2-5

DRESDEN - UFSAR Table 13.2-1 UNIT 2 PERSONNEL TRAINING Dresden Title Activity F BWRT ED OP ST OJ OS X X X Plant Supt. X X X X X X Ass't. Supt. X X X X X X Op. Engr. X X X X X X Shift Engr. & Train. X X X X X X X Supv.

Startup & Shift X X X X X X X Foreman NSO X X X X X X Equip. Oper. X X X X X X Equip Att. X X X X X Supv. Engr. X X X X Thermal Engr. X X X X Instr. Engr. X X X X Rad. Chem. Engr. X X X X Maint. Engr. & X X X X Master Mech.

Maint. Foreman X X X X Fuel Forman X X X X X Other plant X X X X personnel F - Fundamental Courses BWRT - Boiling Water Reactor ED - Equipment Description Course Technology Course ST - Simulator Training OP - Operating Procedure Course OS - On Site Training OJ - On the Job BWR Training (Sheet 1 of 1)

DRESDEN - UFSAR Rev. 5 January 2003 13.3 EMERGENCY PLANNING An Emergency Plan (E-Plan) has been developed which considers the consequences of radiological and non-radiological emergencies. The E-Plan provides for the protection of the health and safety of the public, including EGC employees, the limitation of damage to facilities and property, and the restoration of affected facilities in the event of an emergency. The E-Plan includes a site specific annex which contains additional information and guidance specific to each nuclear station.

The E-Plan describes the emergency organization, including assignments of authority and responsibility. The E-Plan provides for detection and evaluation of emergency situations and discusses protective measures, communications, coordination and notification of governmental authorities, document review and control, emergency preparedness assessment, and training of the participating personnel. Drills and Exercises to ensure readiness on the part of plant personnel are defined and described within the E-Plan.

13.3.1 References

1. Exelon Nuclear Radiological Emergency Plan (current revision).
2. Exelon Nuclear Radiological Emergency Plan Annex, Dresden Station (current revision).

13.3-1

DRESDEN - UFSAR Rev. 4 13.4 REVIEW AND AUDIT Review and Investigative Functions (committees) are established in accordance with the Quality Assurance Program. These functions include the Independent Technical Review, Plant Operations Review Committee, and the Nuclear Safety Review Board. Station Audits are performed as specified in the Quality Assurance Program described in Chapter 17.

In the event that a safety limit is exceeded, the reactor is shut down in accordance with the Technical Specifications and the conditions of shutdown are promptly reported to the Dresden Station Site Vice President or his designated alternate. Reactor operation is not resumed until authorized by the NRC. The incident receives onsite and offsite investigations and reviews pursuant to the Technical Specifications. For each occurrence, a separate report is submitted to the NRC as required by Technical Specifications and 10 CFR 50.73.

Any reportable occurrence is promptly reported to the Site Vice President or his designated alternate. Personnel performing the onsite review and investigative function will review investigation results and prepare a report covering the evaluation and recommendations to prevent recurrence. A separate report for each reportable occurrence is submitted to the NRC as required by Technical Specifications and 10 CFR 50.73.

13.4.1 Plant Operations Review Committee Personnel participating on the Plant Operations Review Committee are responsible for reviewing a variety of activities and documents as specified in the Quality Assurance Program. In accordance with Quality Assurance Program, certain of these reviews are reviewed by the Nuclear Safety Review Board.

13.4.2 Nuclear Safety Review Board Personnel participating on the Nuclear Safety Review Board are responsible for reviewing a variety of documents as specified in the Quality Assurance Program.

13.4-1

DRESDEN - UFSAR Rev. 9 June 2011 13.5 PLANT PROCEDURES The procedure manuals for Dresden Units 2 and 3 provide procedures and surveillances for administration, operation, and maintenance of the facility. Procedures and surveillances are reviewed periodically and revised as necessary in light of operating experience and plant modifications. Station procedure designations and categories are shown in Table 13.5-1.

Station procedures are identified by discipline and by departmental responsibility. Descriptions of the types of departmental procedures and the purposes for which they are implemented are described in this section.

Procedures call for suspension of any potentially unsafe operation and for investigation by station management of any incident resulting in unsafe operation. Appropriate authorities will be notified, and existing procedures will be changed or new procedures added to prevent a recurrence of the incident or occurrence of similar incidents.

With only a few exceptions, acronyms for procedure identification normally begin with the letter "D" for Dresden Station.

13.5.1 Administrative Procedures Administrative Procedures describe the station organization and position responsibilities, establish station policy, supplement the requirements and procedures of the Quality Assurance Topical Report, implement the requirements of the Technical Specifications, and supplement the electronic work control system (EWCS).

Administrative procedures shall be established, implemented, and maintained to limit the working hours of Facility Staff who perform safety related functions; e.g., Senior Reactor Operators, Reactor Operators, Health Physicists, Auxiliary Operators, and key maintenance personnel.

Administrative controls and managerial procedures assure that required record keeping, review of unit operation, and appropriate reporting are performed.

The administrative controls specify the administrative organizations and functions which provide for proper operation of the unit, including actions to be taken in the event prescribed limits are exceeded.

13.5.1.1 Conformance with Federal Guidelines Dresden Station procedures are written to conform to applicable federal guidelines. The contents of the procedure manuals follow Appendix A of Regulatory Guide 1.33 (Revision 2) and ANSI N18.7-1972 requirements.

13.5.1.2 Preparation of Procedures Detailed station procedures (i.e., plant procedures), administrative procedures, and safety-related operating procedures are prepared by members of the station management staff or by personnel whom they designate. The Technical 13.5-1

DRESDEN - UFSAR Rev. 6 June 2005 Specification provides a list of items for which written procedures are required to be established, implemented, and maintained. Planned safety-related operations are conducted in accordance with detailed station procedures.

The station Plant Operations Review Committee reviews applicable administrative procedures and emergency operating procedures, as required by the Quality Assurance Program.

Technical review and approval of procedures which affect nuclear safety (and changes thereto) are carried out per the requirements of the Quality Assurance Program.

All procedures described in this section are authorized by appropriate station management personnel before being implemented.

13.5.1.3 Procedures Brief descriptions of selected station administrative procedures which control specific tasks are provided in the following subsections. The descriptions of station positions, responsibilities, and qualification requirements are given in Section 13.1.

13.5.1.3.1 Daily Orders and Operating Orders Written orders are issued by the station to promulgate instructions and information to the operation and maintenance crews. These orders are issued as Daily Orders and Operating Orders. Operating Orders contain primarily administrative direction and are not a substitute of permanent or special procedures. A Daily Order cannot supersede any approved Operating Order or procedure.

13.5.1.3.2 Equipment Control Equipment control procedures provide for the necessary control of equipment to maintain plant equipment and personnel safety and to avoid unauthorized operation of equipment. These procedures provide a method to control and maintain labeling to secure and identify equipment.

They also describe the criteria for the selection of Operations Department-controlled equipment and valves which are to be locked. The locking of equipment and valves provides assurance that the components will be operated only by authorized personnel performing required activities.

13.5.1.3.3 Control of Maintenance and Modifications Control of maintenance and modifications is provided for in the Quality Assurance Topical Report.

Station administrative procedures have also been developed to control plant maintenance and modification activities.

13.5-2

DRESDEN - UFSAR Rev. 4 13.5.1.3.4 Master Surveillance Testing Schedule A surveillance schedule prescribes the surveillance to be performed, the performance frequency as outlined in the Technical Specifications, and the departments assigned to perform the surveillance.

This schedule is produced as part of the station surveillance and periodic task scheduling program.

A computerized system for tracking surveillance tasks has also been developed to augment the existing system.

13.5.1.3.5 Logbook Usage and Control Procedures for logbook usage and control ensure that adequate documentation of various unit operations and conditions is maintained. The procedure provides detailed instructions for maintenance of records and narrative logbooks to ensure that day-to-day shift activities are properly documented.

13.5.1.3.6 Temporary Changes to Procedures Temporary Changes to procedures may be provided:

a. The intent of the original procedure is not altered.
b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
c. The change is documented, reviewed and approved within 14 days of implementation.

13.5-2a

DRESDEN - UFSAR Rev. 9 June 2011 13.5.2 Operating and Maintenance Procedures The various operating and maintenance procedures that have been developed for Dresden Station are described in the following subsections.

13.5.2.1 Operating Procedures The procedures described in this section are performed primarily by or with the knowledge of licensed operators.

13.5.2.1.1 System Operating Procedures System Operating Procedures detail steps necessary for startup, operation, and shutdown of individual systems or subsystems as well as steps necessary to troubleshoot system problems. These procedures also detail actions required to correct abnormal conditions for which time is not an element of concern and for 13.5-3

DRESDEN - UFSAR Rev. 9 June 2011 which the basic question is not what action is required to correct the condition but rather how to accomplish a desired action or achieve a desired condition.

13.5.2.1.2 General Operating Procedures General Operating Procedures detail steps required to conduct unit startup and shutdown, actions to be taken following a reactor scram, steps essential for routine power changes, and guidance for control rod movement.

13.5.2.1.3 General Abnormal Procedures General Abnormal Procedures describe actions to be taken by personnel either in the control room or in the plant during accident conditions to preclude violation of Technical Specification safety limits, core damage, degradation of primary containment integrity, or a threat to the health and safety of the public. These procedures are oriented toward a symptomatic response rather than a scenario response to accident conditions.

13.5.2.1.4 System Operating Abnormal Procedures System Operating Abnormal Procedures describe actions to be taken during system transients (analyzed or expected) that require immediate operator actions to protect personnel and equipment or to avoid a plant transient. Immediate operator actions are those actions that can be performed from the control room and that must be accomplished within the first 2 or 3 minutes following initiation of a transient.

13.5.2.1.5 Emergency Operating Procedures Emergency Operating Procedures govern plant operation during conditions of uncertainty and prescribe actions to return the plant to a safe and stable condition. These procedures include incorporation of human factors principles, precision limits of installed instrumentation, consistent format of support procedures, and multi-disciplinary involvement and maintenance of DEOPs.

13.5.2.1.6 Annunciator Procedures Annunciator Procedures detail setpoints, automatic actions, and operator actions necessary for response to a condition annunciated at an alarm panel.

13.5-4

DRESDEN - UFSAR Rev. 9 June 2011 13.5.2.1.7 Temporary Changes to Operating Procedures Temporary changes to procedures are addressed in section 13.5.1.3.6.

13.5.2.2 Other Procedures This section describes certain other operating and maintenance procedures, including the general objectives and characteristics of each class of procedure.

13.5.2.2.1 Radiation Protection Procedures Radiation Protection Procedures detail steps necessary to comply with policies established by the Radiation Protection Department, operation and surveillance of radiation protection instrumentation, methods of conducting surveys and collecting samples, and steps necessary to meet Technical Specification and Code of Federal Regulation requirements.

13.5.2.2.2 Emergency Plan Implementing Procedures Emergency Plan Implementing Procedures detail the steps necessary to implement the Generating Station Emergency Plan.

13.5.2.2.3 Instrument Procedures Instrument Procedures detail control of instrument surveillance, steps for calibrations and checks performed, instrument maintenance performed during refueling outages, and control of instrument records.

13.5.2.2.4 Chemistry Procedures Chemistry procedures detail analyses and calibrations performed at the station, specifications and limitations for such analyses, and actions required if conditions are found to be outside specifications.

13.5-5

DRESDEN - UFSAR Rev. 9 June 2011 13.5.2.2.5 Radiological Control Procedures Radiological Control Procedures prescribe the methods and modes of operation and guidance for proper handling, transfer, storage, and packaging of radioactive waste materials resulting from plant operations.

13.5.2.2.6 Maintenance Procedures 13.5.2.2.6.1 Mechanical Maintenance Procedures Mechanical maintenance Procedures govern maintenance of safety-related components, detail steps for complex mechanical maintenance activities, and detail steps for mechanical maintenance activities that are not performed at a fixed frequency.

Maintenance Procedures provide guidance for both electrical and mechanical repair personnel.

Maintenance Procedures differ from Repair Manuals in that the repair manuals contain rigging suggestions, tool lists and supplementary information to vendor manuals. Repair manuals do not contain detailed step-by-step sequences. Consequently, repair manuals are not procedures, do not require review by the Plant Operations Review Committee, and are administratively controlled within the Maintenance Department.

13.5.2.2.6.2 Electrical Maintenance Procedures Electrical Maintenance Procedures govern electrical maintenance of safety-related components and detail steps for electrical maintenance activities not performed on a fixed frequency.

13.5.2.2.6.3 Emergency Plan Maintenance Procedures Emergency Plan Maintenance Procedures detail the steps necessary for station personnel to perform surveillance and maintenance activities on station Emergency Response Facilities to assure they are available to implement the Generating Station Emergency Plan.

13.5.2.2.7 Warehouse Procedures Warehouse Procedures control packaging, receiving, handling, and storage of items in the storeroom.

They also control storage of safety-related and ASME-related materials, provide for preventive maintenance for items in storage, and provide for proper documentation.

13.5-6

DRESDEN - UFSAR Rev. 9 June 2011 13.5.2.2.8 Security Procedures Security Procedures (DSPs) detail the steps necessary to implement the Security Plan.

13.5.2.2.9 Fuel Handling Procedures Fuel Handling Procedures implement the nuclear procedures. They detail steps necessary to perform core alterations; to inspect, receive, and handle new fuel; to handle and ship spent fuel; to load, move and store fuel in casks for Dry Cask Storage; and to perform activities within the spent fuel pool, within the new fuel storage vault, and on the refueling floor.

13.5.2.2.10 Fire Protection Procedures Fire Protection Procedures detail operation of the fire protection systems.

13.5.2.2.11 Safe Shutdown Procedures Safe Shutdown Procedures are classified by specific procedure paths based upon location and extent of damage. They provide guidelines for bringing the reactor to a cold shutdown condition using a minimum number of components during severe fire conditions.

13.5.2.2.12 High Radiation Sample Building Procedures High Radiation Sample Building Procedures detail steps for obtaining normal and post-accident chemistry samples from the high radiation sample system.

13.5.2.2.13 Technical Staff Procedures Technical Staff Procedures establish programs dealing with technical concerns, detail the collection of data for required reports, and control the calibration of technical staff instrumentation.

13.5.2.2.14 Contingency Procedures Contingency Procedures detail the steps necessary to implement the safeguards contingency plan.

13.5-7

DRESDEN - UFSAR Rev. 9 June 2011 13.5.2.2.15 Special Procedures Special Procedures are temporary in nature. They serve one or more of the following purposes:

A. To detail operation during specific and/or unique circumstances; B. To detail steps required to accomplish a task not immediately covered by permanently approved procedures; C. To verify steps or conditions such that a permanent procedure can be developed; D. To detail steps necessary to accomplish a specific and/or unique task; E. To detail steps necessary to accomplish an infrequently performed task or a task that is not expected to be repeated; F. To detail steps for troubleshooting a specific problem; and G. To detail steps necessary to accomplish preoperational testing and/or initial calibration of systems and/or equipment when not covered by a modification procedure, work package instruction, or a permanently approved procedure.

H. To detail steps necessary to perform a test, experiment, modification test, or operability test.

Special Procedures that affect Nuclear Safety receive review by the Plant Operations Review Committee and Nuclear Safety Review Board. Although the procedure or steps of the procedure may be repeated as necessary to accomplish the task or purpose of the procedure, the Special Procedure may not be reused once the intent of the procedure has been achieved without subsequent review and approval under a new Special Procedure number. Except for outage-related procedures, a Special Procedure is not used for a time period in excess of 6 months. The level of detail should be consistent with the complexity, skill level, and acceptance criteria of the task to be performed.

13.5.2.2.16 Metrology Procedures Metrology Procedures detail specific methods/steps for the calibration of Measurement and Test Equipment (M&TE) traceable to nationally recognized standards.

13.5-7a

DRESDEN - UFSAR Rev. 9 June 2011 13.5.3 Surveillance Procedures Surveillance procedures provide station surveillance and periodic task scheduling required for each department.

13.5.3.1 Chemistry Surveillances Chemistry Surveillances provide for scheduling of periodic checks, inspections, tests, analyses, periodic calibrations, preventive maintenance tasks that are expected to prevent malfunctioning of equipment, and tasks that satisfy commitments to documents (e.g., the Technical Specifications).

13.5-8

DRESDEN - UFSAR Rev. 9 June 2011 13.5.3.2 Electrical Surveillances Electrical Surveillances provide for verification of operability or performance characteristics of systems/equipment; performance of periodic checks, inspections, tests, and analyses; performance of periodic calibrations; performance of maintenance tasks that are expected to prevent malfunctioning of equipment; and compliance with commitments to documents (e.g., the Technical Specifications).

13.5.3.3 Fire Protection Surveillances Fire Protection Surveillances provide for verification of operability or performance characteristics of systems/equipment; performance of periodic checks, inspections, tests, and analyses; performance of periodic calibrations; and performance of maintenance tasks that are expected to prevent malfunctioning of equipment.

13.5.3.4 Instrument Surveillance Procedures Instrument Surveillance Procedures detail steps for regularly scheduled instrument surveillances and calibrations.

13.5.3.5 Mechanical Surveillances Mechanical Surveillances provide for verification of operability or performance characteristics of systems/equipment; performance of periodic checks, inspections, tests, and analyses; performance of periodic calibrations; performance of maintenance tasks that are expected to prevent malfunctioning of equipment; and compliance with commitments to documents (e.g., the Technical Specifications).

13.5.3.6 System Operating Surveillance Procedures System Operating Surveillance Procedures ensure the operability of systems required by Technical Specifications, detail steps for verifying operability of systems required for plant operation, and detail steps for checks that are required to be performed on a regularly scheduled frequency.

13.5.3.7 Radiation Protection Surveillances Radiation Protection Surveillances provide for scheduling of periodic checks, inspections, tests, and analyses; periodic calibrations; and maintenance tasks that are expected to prevent malfunctioning of equipment such as effluent and discharge monitors. These surveillances also schedule tasks that satisfy commitments to documents (e.g., Technical Specifications).

13.5-9

DRESDEN - UFSAR Rev. 9 June 2011 13.5.3.8 Technical Staff Surveillance Procedures Technical Staff Surveillance Procedures describe regularly scheduled surveillances that require engineering expertise to accomplish or that should be performed under the cognizance of an engineer.

13.5.3.9 Non-Station Work Group Procedures Non-station work group procedures are procedures which govern work performed at Dresden and which are either prepared by onsite contractors, by EGC departments located offsite, or are prepared by station personnel to address activities which are not controlled by station procedures (e.g., fire pre-plans). The station may use non-station work group procedures once they are reviewed in accordance with the applicable administrative procedure.

13.5.4 Corporate Procedures Corporate Procedures may be used in lieu of station Administrative procedures once they are reviewed and approved in accordance with the applicable administrative procedure.

13.5-10

DRESDEN - UFSAR Rev. 9 June 2011 Table 13.5-1 STATION PROCEDURE DESIGNATIONS AND CATEGORIES Deleted

DRESDEN - UFSAR Rev. 4 13.6 SECURITY EGC implements and maintains in effect all provisions of the NRC-approved physical security, guard training and qualification, and safeguards contingency plans for Dresden Station in accordance with the operating licenses. The plans are specified in the following documents, as revised and filed with the NRC:

A. "Dresden Nuclear Power Station Security Plan,"

B. "Dresden Nuclear Power Station Security Personnel Training and Qualification Plan,"

and C. "Dresden Nuclear Power Station Safeguards Contingency Plan."

These plans meet the requirements of 10 CFR 73.55 and Part 73, Appendices B and C.

The security plan documents contain safeguards information protected under 10 CFR 73.21 and are, therefore, withheld from public disclosure. Some general information relating to security is presented in the following paragraphs.

The Site Vice President has the ultimate responsibility and authority for security at the Station.

Below the Vice President, the management of the security organization is independent of the site management. Authority for administration of the security organization is delegated from the Security Director to the Station Security Administrator (see Section 13.1). The Station Security Administrator reports directly to the Security Director and maintains an information and coordinator channel to the Site Vice President.

Station access is controlled by station security in accordance with the Dresden security plan and Dresden administrative procedures.

The following area designations are used at the station:

A. Unrestricted area: that area beyond the site property line.

B. Owner Controlled Area: that area between the station security fence and the property boundary line.

C. Unposted area: that area within the station security fence that is not part of a radiologically posted area.

D. Radiologically posted areas: those areas posted as radiation areas, high radiation areas, radioactive materials areas, airborne radioactivity areas, or combinations thereof.

Access to radiologically posted areas for all work is controlled in accordance with station radiation protection procedures.

E. Protected area: that area within the owner-controlled area enclosed by a station security fence in which the main buildings are located. Access to the protected area is controlled.

13.6-1

DRESDEN - UFSAR Rev. 2 F. Vital area: any area within the protected area which contains vital equipment. Vital equipment is any plant equipment, system, or device whose failure or destruction could directly or indirectly endanger public health and safety by a release of radioactivity which could result in a total radiation dose in excess of the limits established by 10 CFR 100.11.

Equipment or systems which would be required to function to protect public health and safety following such failure or destruction are also considered vital equipment. Security equipment is not considered vital equipment. All vital equipment is contained in vital areas.

Normal access to the protected area is through the gatehouse. Personnel entering the gatehouse are screened by security systems, e.g., explosive and firearms detectors. When necessary, personnel are given a pat-down search in accordance with the requirements of the Dresden security plan.

Final entry to the protected area is controlled by a computerized card reader in conjuntion with a hand geometry reader system at the Main Access Facility (MAF). Movement within the protected area is controlled by a computerized card reader system.

Security personnel coordinate with Training and Radiation Protection Department personnel to ensure that applicable entry requirements are met.

13.6-2

DRESDEN - UFSAR Rev. 8 June 2009 13.7 RECORDS Quality assurance records are retained to furnish evidence of activities affecting quality. These records are stored from the time of their creation or receipt until their ultimate disposal in a manner which meets the requirements of applicable standards, codes, and regulatory agencies with regard to maintenance, preservation, and protection of files.

Records may be in various forms such as logs, reports, drawings, or meeting minutes.

Records are kept in a manner convenient for review and retained for the period of time specified in Table 13.7-1. It also describes specific records within each type and specifies the minimum required retention period. Record types are briefly discussed in the following subsections.

Other records are retained in accordance with schedules established by NRC orders, Federal Power Commission regulations, and Illinois Commerce Commission regulations. The retention periods for these records are specified in Dresden's Records Retention Schedule.

13.7.1 Control Room Records Operating Logs are reviewed and maintained in accordance with approved administrative programs.

13.7.2 Plant Operation Records Plant operation records provide pertinent information on the history of unit power production, operational excursions, operational testing, and other quality activities. For example, records of normal plant operation include notation of power levels and periods of operation at each power level.

13.7.3 Procedure Changes Records of changes to procedures required by the Quality Assurance Topical Report NO-AA-10 as well as other procedures which affect nuclear safety, are retained.

13.7-1

DRESDEN - UFSAR Rev. 2 13.7.4 Review Committee Transactions Records of review committee transactions include minutes of meetings and results of reviews performed by the Plant Operations Review Committee and Nuclear Safety Review Board.

13.7.5 Radiological and Chemical Records Included in this category of records are the occupational radiation exposure records for all plant personnel, including contractors and plant visitors, in accordance with 10 CFR 20, as well as radiation surveys, offsite environmental monitoring records, and others as noted in Table 13.7-1.

13.7.6 Maintenance Records This category includes records of maintenance and activities (substitution, inspection, and/or repair) for principal equipment pertaining to nuclear safety and the reasons for the maintenance. It also includes records of periodic checks, inspections, calibrations, and/or corrective actions (if any) performed in accordance with Technical Specification surveillance requirements. These records are maintained by the Maintenance Superintendent.

13.7.7 Records of Facility Description and Evaluation Records of facility description and evaluation include drawings, descriptions of plant changes, evaluations performed in accordance with 10 CFR 50.59, and records of environmental qualification.

13.7.8 Personnel Records Personnel records address the qualification, experience, training, and retraining of individual staff members.

13.7-2

DRESDEN - UFSAR Rev. 6 June 2005 Table 13.7-1 REQUIREMENTS FOR RECORD RETENTION(a)

Minimum Record Type Record Description Retention Period Control room records Shift Engineers' logs 5 years Plant operation Normal plant operation 5 years records Reportable events 5 years Safety limit events 5 years Reactor coolant system Life of plant inservice inspections Transient or operational Life of plant cycling of life-limited components Physics tests and other 5 years tests pertaining to nuclear safety Procedure changes Changes to procedures as 5 years required by Quality Assurance Topical Report NO-AA-10 Review committee Reviews by Plant Life of plant transactions Operations Review Committee Reviews by Nuclear Safety Life of plant Review Board Radiological records Personnel exposure records Life of plant Radioactivity in liquid and Life of plant gaseous wastes released to the environment Plant radiation and Life of plant contamination surveys Offsite environmental Life of plant monitoring surveys (Sheet 1 of 2)

DRESDEN - UFSAR Rev. 6 June 2005 Table 13.7-1 REQUIREMENTS FOR RECORD RETENTION(a)

Minimum Record Type Record Description Retention Period Radioactive material shipments Life of plant Byproduct material inventory 5 years Source leak test results 5 years New and spent fuel inventory Life of plant New and spent fuel assembly Life of plant histories Maintenance records Substitution or replacement of Life of plant principal equipment pertaining to nuclear safety Maintenance of principal 5 years equipment pertaining to nuclear safety Periodic checks and 5 years calibrations to meet Technical Specification surveillance requirements Records of facility Equipment changes or reviews 5 years description and of tests and experiments to evaluation comply with 10 CFR 50.59 Changes to the plant as it is Life of plant described in the SAR Plant drawings (updated, Life of plant corrected, and as-built)

Environmental qualification Life of plant Personnel records Staff member qualifications, Life of plant experience, training, and retraining (a) Changes to this table must be made via the provisions of 10 CFR 50.54(a) until the record retention requirements are listed in the Exelon Nuclear QA Topical Report NO-AA-10.

(Sheet 2 of 2)