RS-09-104, Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation, to Allow Alternate Method of Verifying Drywell Leakage

Request for License Amendment to Revise Technical Specification 3.4.5, RCS Leakage Detection Instrumentation, to Allow Alternate Method of Verifying Drywell Leakage

ML092400548
Person / Time
Site:	Dresden, Quad Cities
Issue date:	08/28/2009
From:	Hansen J Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-09-104
Download: ML092400548 (31)

Text

Exelon.)

Exelon Nuclear www.exeloncorp.co m Nuclear 4300 Winfield Road Warrenville, IL 60555 10 C FR 50.90 RS-09-104 August 28, 2009 U . S . Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D.C . 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Request for License Amendment to Revise Technical Specification 3.4.5, "RCS Leakage Detection Instrumentation," to Allow Alternate Method of Verifying D ell Leakage References : 1) Letter from P. R. Simpson (Exelon Generation Company, LLC) to U . S.

NRC, "Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System," dated August 18, 2008

2) Letter from C . Gratton (U. S . NRC) to C. G . Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Unit 3 - Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467)," dated August 22, 2008 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS) of Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3 (DNPS), and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS).

The proposed amendment revises Technical Specification (TS) 3.4 .5, "RCS Leakage Detection Instrumentation," to support implementation of an alternate method of verifying that leakage in the drywell is within limits .

August 28, 2009 U . S. Nuclear Regulatory Commission Page 2 In Reference 1, EGC requested a temporary emergency license amendment for DNPS Unit 3 to allow the reconfiguration of the drywell floor drain sump (DWFDS) monitoring system such that the drywell equipment drain sump (DWEDS) could be used as an alternate method to verify that Reactor Coolant System (RCS) leakage in the drywell is within TS limits . The emergency license amendment request was reviewed and approved by the NRC in Reference 2. The changes proposed in this request seek to clarify and make permanent the alternate method in the DNPS TS for both Unit 2 and Unit 3, and incorporate the alternate method in the QCNPS TS for Unit 1 and Unit 2 .

The attached amendment request is subdivided as follows.

" Attachment 1 provides an evaluation supporting the proposed change.

" Attachment 2a provides the marked-up DNPS TS pages, with the proposed changes indicated .

" Attachment 2b provides the marked-up QCNPS TS pages, with the proposed changes indicated .

Attachment 3a provides the marked-up DNPS TS bases pages, with the proposed changes indicated. This attachment is provided for information only .

Attachment 3b provides the marked-up QCNPS TS bases pages, with the proposed changes indicated . This attachment is provided for information only .

Attachment 4 provides a list of regulatory commitments.

The proposed change has been reviewed and approved by the DNPS and QCNPS Plant Operations Review Committees and Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

There are three regulatory commitments contained within this letter (i .e., as described in ). EGC requests approval of the proposed change by August 29, 2010, with the amendment being implemented within 60 days of issuance .

In accordance with 10 CFR 50 .91, "Notice for public comment; State consultation," EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official .

Should you have any questions concerning this letter, please contact Mr. John L. Schrage at (630) 657-2821 .

August 28, 2009 U . S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28 day of August 2009.

Jeffrey-L. Hansen Manager - Licensing : Evaluation of Proposed Change a : Proposed Markup of DNPS Technical Specification 3.4.5 b : Proposed Markup of QCNPS Technical Specification 3.4 .5 a: Proposed Markup of DNPS Technical Specification Bases B3 .4.5 b: Proposed Markup of QCNPS Technical Specification Bases B3 .4.5 : List of Regulatory Commitments

ATTACHMENT 1 Evaluation of Proposed Change 1 .0 DESCRIPTION

3.0 BACKGROUND

4 .0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements and Criteria

6.0 ENVIRONMENTAL CONSIDERATION

7.0 IMPACT ON PREVIOUS SUBMITTALS

8.0 REFERENCES

Page 1 of 10

ATTACHMENT 1 Evaluation of Proposed Change 1 .0 DESCRIPTION In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS) of Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3 (DNPS), and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS).

The proposed amendment revises Technical Specification (TS) 3 .4 .5, "RCS Leakage Detection Instrumentation," to support implementation of an alternate method to quantify Reactor Coolant System (RCS) leakage in the primary containment (i.e., the drywell) . The proposed alternate method uses the installed drywell equipment drain sump (DWEDS) monitoring system, with the drywell floor drain sump (DWFDS) overflowing to the DWEDS, to verify that RCS leakage in the drywell is within TS 3.4.4, "RCS Operational Leakage," limits . This configuration would only be used when the DWFDS monitoring system is unavailable.

The purpose of the proposed license amendment is to increase operating flexibility and avoid unnecessary plant transients due to extended inoperability of the DWFDS monitoring system (e.g., inoperability caused by a component failure) . The proposed change will enable each station to reconfigure the DWFDS system such that it is overflowing into the DWEDS . The reconfigured drywell sump monitoring system can then be used to verify that drywell leakage is within the limits specified in TS 3.4.4 . This operating configuration is conservative to the normal configuration in that the TS 3 .4.4.b unidentified leakage limit of less than or equal to 5 gallons per minute (gpm) will be applied to total leakage, as opposed to the TS 3.4 .4.c limit of less than or equal to 25 gpm.

2.0 PROPOSED CHANGE

The proposed amendment revises DNPS and QCNPS TS Limiting Condition for Operation (LCO) 3.4.5.a to state that a drywell sump monitoring system is required to be OPERABLE.

Correspondingly, the proposed amendment revises DNPS and QCNPS TS 3.4.5, Condition A and Required Action A.1 to remove the specific references to the DWFDS monitoring system and replaces these with a reference to the drywell sump monitoring system . The drywell sump monitoring system is defined in the proposed DNPS and QCNPS TS Bases as either the DWFDS monitoring system or the DWEDS monitoring system with the DWFDS overflowing to the DWEDS .

Finally, the proposed amendment revises DNPS Surveillance Requirement (SR) 3.4 .5 .2 and SR 3.4 .5 .3 to remove the specific references to the DWFDS monitoring system instrumentation, and replaces these with a reference to the drywell sump monitoring system.

Page 2 of 10

ATTACHMENT 1 Evaluation of Proposed Change

3.0 BACKGROUND

On August 16, 2008, at approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, EGC operations personnel at DNPS attempted to pump the DNPS Unit 3 DWFDS utilizing Dresden Operating Procedure (DOP) 2000-24, "Drywell Sump Operation." Successful completion of DOP 2000-24 is used, in part, to satisfy SR 3 .4 .4.1, "Verify RCS unidentified and total LEAKAGE and unidentified LEAKAGE increase are within limits ." The pumps started as expected; however, the integrator indicated no flow . During a second attempt to operate the pumps, EGC operations personnel observed the position indicators for the two containment isolation valves, which indicated that the valves were in their proper position. EGC maintenance personnel also inspected the pump breakers and measured pump motor current, with no abnormalities identified . The drywell floor drain sump pumps had been successfully pumped previously at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, and every four hours prior.

EGC conducted troubleshooting actions to identify possible malfunctions . These troubleshooting actions indicated that the containment isolation valve (i .e., one of two drywell floor drain sump pump discharge valves) may have failed closed . Since the drywell floor drain sump could not be pumped, EGC was not able to satisfy the acceptance criteria of SR 3.4 .4 .1 for DNPS Unit 3. Therefore, TS LCO 3.4 .4 for unidentified leakage could not be verified to be within limits . The applicable TS action requires that the unit be placed in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

In that the containment isolation valve is part of primary containment, the valve could not be repaired during unit operation . As such, EGC requested, and the NRC granted, a Notice of Enforcement Discretion (NOED) for TS 3.4 .4, Condition C and TS 3 .4 .5, Condition C (i.e.,

References 1 and 2, respectively) . Specifically, the NOED provided a seven-day extension to the TS Completion Times to place the unit in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The extension provided sufficient time to reconfigure the DWFDS monitoring system such that the DWEDS monitoring system could be physically utilized to quantify unidentified drywell leakage. In addition, the seven-day extension provided sufficient time for EGC to request, and the NRC to review and approve, an emergency license amendment to revise TS 3 .4 .5, on a temporary basis, to approve the use of the DWEDS monitoring system as an alternate method to quantify unidentified leakage (i.e., References 3 and 4, respectively) .

The changes proposed in this request seek to make permanent the alternate method in the DNPS TS for both Unit 2 and Unit 3, and incorporate the alternate method in the QCNPS TS for Unit 1 and Unit 2 . The proposed alternate method has been incorporated into the TSs for the Monticello Nuclear Generating Plant (i .e., References 5 and 6) and the Peach Bottom Atomic Power Station (PBAPS), Unit 2 and Unit 3 (i.e ., References 7 and 8).

4.0 TECHNICAL ANALYSIS

The RCS includes systems and components that contain or transport the reactor coolant to or from the reactor core . The pressure-containing components of the RCS and the portions of connecting systems out to and including the isolation valves define the reactor coolant pressure boundary (RCPB) . The joints of the RCPB components are welded or bolted .

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ATTACHMENT 1 Evaluation of Proposed Change During plant life, the joint and valve interfaces can produce varying amounts of reactor coolant leakage, through either normal operational wear or mechanical deterioration. Limits on RCS operational leakage are required to ensure appropriate action is taken before the integrity of the RCPB is impaired.

TS 3.4.4, "RCS Operational LEAKAGE," specifies the leakage limits for the RCS. The leakage limits require, in part, unidentified leakage to be less than or equal to five gallons per minute (gpm), total leakage averaged over the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to be less than or equal to 25 gpm, and the increase in unidentified leakage within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to be less than or equal to two gpm.

Section 5.2.5 of the DNPS and QCNPS Updated Final Safety Analysis Report (UFSAR) describes the independent methods by which RCS leakage to the drywell can be detected .

These independent methods monitor drywell sump levels (i .e ., DWFDS and DWEDS), drywell pressure and temperature changes, and drywell atmosphere radioactivity levels . These sensitive and diverse systems meet the acceptance criteria of Regulatory Guide (RG) 1 .45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0 .

Although there are multiple, independent methods to detect RCS leakage in the drywell, the sole method of quantifying RCS leakage is the drywell sump monitoring system. DNPS and QCNPS UFSAR Subsection 5 .2.5 .1 describes the use of the drywell sumps to monitor both identified leakage and unidentified leakage from the RCS into primary containment. The leakage collected in the DWEDS is identified leakage, and the leakage collected in the DWFDS is unidentified leakage.

The DWFDS monitoring system monitors the leakage collected in the floor drain sump. This unidentified leakage consists of leakage from control rod drives, valve flanges or packings, floor drains, the Reactor Building Closed Cooling Water System, drywell air cooling unit condensate drains, and any leakage not collected in the drywell equipment drain sump. The DWFDS monitoring system consists of two pumps that take suction from the drywell floor drain sump and discharge through a containment penetration to the liquid radioactive waste system . Flow indication from the DWFDS pumps is provided in the control room. Sump input, which is used to determine a leakage rate, is based on the readings from a flow integrator located in the control room.

The DWEDS monitoring system is similar to the DWFDS monitoring system . Leakage into the DWEDS is considered identified leakage. Identified leakage is composed of the normal seal and valve-packing leakage and does not represent a safety consideration as long as the leakage is small compared to the available reactor coolant makeup capacity . The DWEDS monitoring system can be used in combination with the DWFDS monitoring system and other leak detection equipment to determine the source of leakage in the drywell . When a high level is reached in either the DWFDS or DWEDS, a level switch actuates to start the pumps when the pump discharge valves are open.

TS 3.4.5 currently requires use of the DWFDS monitoring system to verify that RCS unidentified leakage is within limits . The proposed change revises TS 3.4.5 to support implementation of an alternate method when the DWFDS monitoring system is unavailable, using the installed DWEDS monitoring system, to verify RCS unidentified leakage in the drywell is within TS limits .

Page 4 of 10

ATTACHMENT 1 Evaluation of Proposed Change As described below, EGC has confirmed that use of the alternate method provides an acceptable level of leakage monitoring capability .

The DNPS and QCNPS DWEDS is physically located next to the DWFDS, with the top of both sumps at the same elevation, approximately three feet apart. There are no obstructions between the two sumps to prevent or divert DWFDS overflow from reaching the DWEDS. This was verified at DNPS Unit 3 in August 2008 . EGC has also verified that the QCNPS Unit 1 and Unit 2, and DNPS Unit 2 sump configurations are equivalent to the DNPS Unit 3 configuration.

Prior to initial use of the alternate method at DNPS Unit 2 and QCNPS Unit 1 and Unit 2, EGC will verify that the DWFDS overflows into the DWEDS .

[Regulatory Commitments CM-1, CM-2, and CM-3]

Based on recent surveillance tests at DNPS and QCNPS, the input to the DWEDS (i.e.,

identified leakage) has ranged from approximately 1 .2 gpm to 1 .8 gpm, and the input to the DWFDS (i .e., unidentified leakage) has ranged from approximately 0 .1 gpm to 0.3 gpm .

Historical trends indicate that these normal input rates have remained steady, thus ensuring that small increases in total leakage, relative to the TS 3.4.4 limits, are identified and appropriate actions are implemented .

By allowing the DWFDS to overflow into the DWEDS, operations personnel will not be able to differentiate between the identified and unidentified leakage inputs . As such, all leakage in the combined drywell sumps will be conservatively treated as unidentified leakage. As stated above, the TS 3.4 .4 limits for unidentified leakage is less than or equal to five gpm, and less than or equal to a 25 gpm for total leakage. Therefore, the existing limit specified in TS 3.4 .4 for total leakage averaged over the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (i .e ., less than or equal to 25 gpm) will be significantly reduced to the unidentified leakage value of five gpm . Based on these two conservative factors, implementation of the alternate method to quantify unidentified RCS leakage and total RCS leakage in the drywell is conservative with respect to the current TS 3.4.4 limits .

Historical RCS leakage data at DNPS Unit 3 (i .e ., from June 2008 to November 2008) indicates that the DWEDS monitoring system, with the DWFDS overflowing to the DWEDS, provides an acceptable method to verify that drywell leakage is within TS 3 .4.4 limits .

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria Dresden Nuclear Power Station (DNPS) Units 2 and 3 and Quad Cities Nuclear Power Station (QCNPS) Units 1 and 2 were originally designed and constructed prior to the issuance of the General Design Criteria (GDC). Proposed GDC were issued in July 1967, during the construction of the plant. These proposed criteria were not adopted as regulatory requirements at the time that DNPS and QCNPS were built. The proposed GDC were used by the Atomic Energy Commission to evaluate the original design of all four units at DNPS and QCNPS. This evaluation indicated that based on the applicant's understanding of the intent of the proposed GDC, DNPS and QCNPS fully satisfied the intent of the criteria. DNPS and QCNPS Updated Final Safety Analysis Report (UFSAR)

Page 5 of 10

ATTACHMENT 1 Evaluation of Proposed Change Section 3 .1, "Conformance with NRC General Design Criteria," addresses conformance of DNPS and QCNPS to the proposed GDC.

DNPS and QCNPS UFSAR Section 3.1 .3 .6 discusses Criterion 16, "Monitoring Reactor Coolant Pressure Boundary," which requires a means to monitor the reactor coolant pressure boundary to detect leakage . The evaluation for compliance with Criterion 16 states that the necessary plant controls, instrumentation, and alarms for safe and orderly operation are located in the control room. These include such controls as the control rod position indication, the reactor core heat removal system, and the reactor coolant system leakage detection system.

Section 5.2 .5 of the DNPS and QCNPS Updated Final Safety Analysis Report (UFSAR) describes the independent methods by which RCS leakage to the primary containment (i.e., the drywell) can be detected . These independent methods monitor drywell sump levels, drywell pressure and temperature changes, and drywell atmosphere radioactivity levels . These sensitive and diverse systems meet the acceptance criteria of Regulatory Guide 1 .45, "Reactor Coolant Pressure Boundary Leakage Detection Systems,"

Revision 0 .

DNPS and QCNPS TS 3 .4.4, "RCS Operational LEAKAGE," specifies the leakage limits for the RCS. The leakage limits require, in part, unidentified leakage to be less than or equal to five gallons per minute (gpm), total leakage averaged over the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to be less than or equal to 25 gpm, and the increase in unidentified leakage within the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to be less than or equal to two gpm.

Although there are multiple, independent methods to detect RCS leakage in the drywell, the sole method of quantifying RCS leakage is the drywell sump monitoring system . The leakage collected in the drywell equipment drain sump (DWEDS) is identified leakage, and the leakage collected in the drywell floor drain sump (DWFDS) is unidentified leakage . DNPS and QCNPS UFSAR Subsection 5 .2.5.1 describes the use of the containment sumps to monitor both identified and unidentified RCS leakage to the primary containment.

The proposed change does not involve physical changes to the RCS leakage detection systems . Rather, the proposed change allows use of the DWEDS monitoring system to perform the function of the DWFDS monitoring system, when the DWFDS is unavailable, in quantifying unidentified leakage within the DNPS and QCNPS drywells . The design function of the RCS leakage detection systems is not affected by the proposed change .

In addition, the alternate method conservatively assumes that all leakage in the drywell is unidentified leakage. Therefore, there is no impact to EGC's ability to meet the applicable regulatory requirements discussed above.

5.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Appendix A, Technical Specifications (TS) of Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3 (DNPS), and Renewed Page 6 of 10

ATTACHMENT 1 Evaluation of Proposed Change Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS). The proposed amendment revises Technical Specification (TS) 3.4.5, "RCS Leakage Detection Instrumentation," to support implementation of an alternate method to quantify Reactor Coolant System (RCS) leakage in the primary containment (i .e., the drywell) . The proposed alternate method uses the installed drywell equipment drain sump (DWEDS) monitoring system, with the drywell floor drain sump (DWFDS) overflowing to the DWEDS, to verify that RCS leakage in the drywell is within TS 3 .4 .4, "RCS Operational Leakage," limits . This configuration would only be used when the DWFDS monitoring system is unavailable.

According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability or consequences of any accident previously evaluated ; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or Involve a significant reduction in a margin of safety .

EGC has evaluated the proposed change, using the criteria in 10 CFR 50 .92, and has determined that the proposed change does not involve a significant hazards consideration . The following information is provided to support a finding of no significant hazards consideration.

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

Response : No The proposed change does not involve physical changes to any plant structure, system, or component. As a result, no new failure modes of the RCS leakage detection systems are being introduced . Additionally, the change being proposed will have no impact on the RCS leakage detection system that would impact initiating event frequency.

The consequences of a previously analyzed accident are dependent on the initial conditions assumed for the analysis, the behavior of the fuel during the analyzed accident, the availability and successful functioning of the equipment assumed to operate in response to the analyzed event, and the setpoints at which these actions are initiated. The RCS leakage detection systems do not perform an accident mitigating function . Emergency Core Cooling System, Reactor Protection System, and primary and secondary containment isolation actuations are not affected by the proposed change. The proposed change has no impact on any setpoints or functions related to these actuations . There are no changes in the types or significant increase in the amounts of any effluents released offsite.

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ATTACHMENT 1 Evaluation of Proposed Change Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response : No The proposed change allows use of the drywell equipment drain system as an alternate method to verify that RCS leakage in the drywell is within TS limits . The drywell equipment drain system will continue to be used for leakage collection and quantification. There is no alteration to the parameters within which the plant is normally operated or in the setpoints that initiate protective or mitigative actions.

As a result, no new failure modes are being introduced .

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated .

Does the proposed change involve a significant reduction in a margin of safety?

Response : No The current TSs require a periodic measurement of RCS leakage. The proposed change maintains the existing level of safety by allowing use of the DWEDS monitoring system to verify that RCS leakage in the drywell is within TS limits. No changes are being made to any of the RCS leakage limits specified in TS 3 .4.4.

The impact of the change is that the amount of unidentified and identified RCS leakage within the drywell will be quantified and evaluated as a single unidentified leakage value. This alternate method is more conservative than the current method .

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

Based on the above evaluation, EGC has determined that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified .

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

Page 8 of 10

ATTACHMENT 1 Evaluation of Proposed Change

6.0 ENVIRONMENTAL CONSIDERATION

EGC has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation ." However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Paragraph (c)(9) .

Therefore, pursuant to 10 CFR 51 .22, Paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment .

7.0 IMPACT ON PREVIOUS SUBMITTALS In Reference 9, EGC submitted a license amendment request (LAR) to delete the DNPS TS 3.4.5 changes that were implemented as a temporary license amendment by Reference 4. The marked-up DNPS TS pages in Attachment 2a also reflect deletion of the changes from Reference 4. This LAR does not seek to execute changes on any other TSs that currently have pending amendments .

8.0 REFERENCES

1) Letter from D . B. Wozniak (Exelon Generation Company, LLC) to U . S. NRC, "Request for Enforcement Discretion for Technical Specifications (TS) 3.4 .4,

'RCS Operational Leakage' and TS 3 .4 .5, 'RCS Leakage Detection Instrumentation,'" dated August 19, 2008

2) Letter from C. Pederson (U . S. NRC) to C. G . Pardee (Exelon Generation Company, LLC), "Notice of Enforcement Discretion for Exelon Generation Company LLC Regarding Dresden Nuclear Power Station, Unit 3 (NOED 08 002)," dated August 21, 2008

3) Letter from P . R. Simpson (Exelon Generation Company, LLC) to U . S . NRC, "Request for Emergency License Amendment Regarding Drywell Floor Drain Sump Monitoring System," dated August 18, 2008

4) Letter from C. Gratton (U. S . NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Unit 3 - Issuance of Emergency Amendment Regarding Drywell Floor Drain Sump Monitoring System (TAC No. MD9467)," dated August 22, 2008 Page 9 of 10

ATTACHMENT 1 Evaluation of Proposed Change

5) Letter from L . M . Padovan (U . S. NRC) to D. L. Wilson (Nuclear Management Company, LLC), "Monticello Nuclear Generating Plant - Issuance of Amendment Re: Drywell Leakage and Sump Monitoring Detection System (TAC No.

MB7945)," dated August 21, 2003

6) Letter from T. A. Beltz (U . S. NRC) to J . T. Conway (Nuclear Management Company, LLC), "Monticello Nuclear Generating Plant (MGNP) - Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond-Scope Issues (TAC Nos . MC7505, MC7597, through MC7611, and MC8887)," dated June 5, 2006

7) Letter from G. Gears (U. S . NRC) to E . G . Bauer (Philadelphia Electric Company), "Technical Specification Amendments Pertaining to the Monitoring of Coolant Leakage and the Providing of Limitations on Iodine Concentrations in the Reactor Coolant," dated February 27, 1985

8) Letter from J. W Shea (U . S. NRC) to G . A. Hunger, Jr., (PECO Energy Company, "Issuance of Improved Technical Specifications, Peach Bottom Power Station, Unit Nos. 2 and 3, (TAC Nos . M90746 and M90747)," dated August 30, 1995

9) Letter from J . L. Hansen (Exelon Generation Company, LLC) to U . S. NRC, "Request for License Amendment to Technical Specification (TS) 3 .4.5, 'RCS Leakage Detection Instrumentation,' TS 5.6.5, 'Core Operating Limits Report' and Renewed Facility Operating License," dated April 7, 2009 Page 10 of 10

ATTACHMENT 2a Proposed Markup of DNPS Technical Specification 3 .4.5 RCS Leakage Detection Instrumentation

RCS Leakage Detection Instrumentation 3 .4 .5 3 .4 REACTOR COOLANT SYSTEM (RCS) 3 .4 .5 RCS Leakage Detection Instrumentation LCO 3 .4 .5 The following RCS leakage detection instrumentation shall be OPERABLE :

a. Drywel l fl eep di-ri-flr sump monitoring system-' ; and

b. Primary containment atmospheric particulate sampling system .

APPLICABILITY : MODES l, 2, and 3 .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywel l fleet- ---di-ai-ft A .1 Restore drywel l fl eep 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sump monitoring H sump monitoring systems` inoperable . systems to OPERABLE status .

B. Primary containment B .1 Restore primary 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmospheric containment particulate sampling atmospheric system inoperable, particulate sampling system to OPERABLE status .

C. Required Action and C .1 Be in MODE 3 . 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met . AND C .2 Be in MODE 4 . 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Dresden 2 and 3 3 .4 .5-1 Amendment No . 185/221

RCS Leakage Detection Instrumentation 3 .4 .5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3 .4 .5 .1 Perform primary containment atmospheric 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> particulate sampling .

SR 3 .4 .5 .2 Perform a CHANNEL FUNCTIONAL TEST of 31 days drywell fl-eep - dpaiR sump monitoring system-L' instrumentation .

SR 3 .4 .5 .3 Perform a CHANNEL CALIBRATION of drywell 12 months sump monitoring systems' instrumentation .

Dresden 2 and 3 3 .4 .5-2 Amendment No . '85,'-m

ATTACHMENT 2b Proposed Markup of QCNPS Technical Specification 3.4.5 RCS Leakage Detection Instrumentation

RCS Leakage Detection Instrumentation 3 .4 .5 3 .4 REACTOR COOLANT SYSTEM (RCS) 3 .4 .5 RCS Leakage Detection Instrumentation LCO 3 .4 .5 The following RCS leakage detection instrumentation shall be OPERABLE :

a. Drywell - a4-R sump monitoring system ; and

b. Primary containment atmospheric particulate monitoring system .

APPLICABILITY : MODES 1, 2, and 3 .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell flees -f Restore drywell fl-eep 30 days sump monitoring system d-Fain sump monitoring inoperable . system to OPERABLE status .

(continued)

Quad Cities 1 and 2 3 .4 .5-1 Amendment No . 22 fro

ATTACHMENT 3a Proposed Markup of DNPS Technical Specification Bases B3 .4.5 RCS Leakage Detection Instrumentation

RCS Leakage Detection Instrumentation B 3 .4 .5 B 3 .4 REACTOR COOLANT SYSTEM (RCS)

B 3 .4 .5 RCS Leakage Detection Instrumentation BASES BACKGROUND UFSAR, Section 3 .1 .2 .4 .1 (Ref . 1), requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE . Regulatory Guide 1 .45 (Ref . 2) describes acceptable methods for selecting leakage detection systems .

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref . 2) .

Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates . The Bases for LCO 3 .4 .4, "RCS Operational LEAKAGE," discuss the limits on RCS LEAKAGE rates .

the LEAKAGE e-Yan identified seupee are necessary to provide prompt antitative information to the operators to permit them o' take immediate corrective action .

LEAKAGE from the RCPB inside the drywell is detected by at least one of the two monitored variables, such as measuring flow and primary nment atmospheric particulate radioactivity level .

from the drywell sumps with the required RCS LEAKAGE detection instrumentation (i .e .,

the drywell floor drain sump monitoring The drywell floor "rain sump monitoring system monitors the system or the drywell LEAKAGE collect in the floor drain sump . This equipment drain sump unident ified ..L AKAGE consists of LEAKAGE from control rod monitoring system, drives, va e flanges or packings, floor drains, the Reactor with the drywell floor Buildin Closed Cooling Water System, and drywell air drain sump overflowing cool i g unit condensate drains, and any LEAKAGE not to the drywell equipment drain sump), co ected in the drywell equipment drain sump . Leakage into e drywell floor drain sump is pumped through a piping header that penetrates the containment wall to the ses d F a i--ee l l e et-e,-- tank .

Although alternate methods of detecting RCS LEAKAGE are available, the sole means of quantifying RCS leakage is (continued) with the required drywell sump monitoring system .

Liquid Radioactive Waste Management Systems Dresden 2 and 3 B 3 .4 .5-1 Revision 4-1

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES BACKGROUND An alternate to the Hn-i-t ; drywell floor drain sump (continued) monitoring sy is the Un4t 3 drywell equipment drain sump monitori-aT'system, men-1-y if the drywell floor drain sump for quantifying overflowing T-~e drywell equipment drain sump colle unidentified LEAKAGE all leaka nto the drywell equipment drain sump and overf>~ from the drywell floor drain sump . There re, if drywell floor drain sump is overflowing to e drywell to the drywell equipment drain sump, the drywell equipment ain sump equipment drain monitoring system can be used to quantify AKAGE . In this sump . In this condition, all LEAKAGE measured by the drywell equipment configuration, the drain sump monitoring system is assumed to be unidentified LEAKAGE,.r T -alte~wRa-t- 4 y~e-fethad ma ,, he , s WHr4 3 The LEAKAGE determination process, including the transition to and use of the alternate method Two drywell floor drain sump pumps take sHetien fi-eFR the is described in station flee p ..

procedures . The Radioactive Waste Management stems alternate method would only be used when the drywell floor drain sump monitoring system M is unavailable . discharge valyt-'s are op- sumps decreases

. i 0i'cation in the control room . In addition, eak rate re'9dirder is provided capable of identifying a gpm change,/tver an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period . The pumps can also be and two drywell equipment drain sump The p mary containment atmospheric particulate sampling pumps take suction sy em provides a means to monitor the primary containment from their mosphere for airborne particulate radioactivity . An respective sumps increase of radioactivity may be attributed to RCPB steam or reactor water LEAKAGE . The primary containment atmospheric particulate sampling system is not capable of quantifying The two pumps for each system LEAKAGE rates . The primary containment atmospheric particulate sampling system consists of a manifold rack that allows drywell atmospheric grab samples to be obtained for analysis and a continuous air monitor that contains particulate and charcoal filters for monitoring of the drywell atmosphere .

(continued)

Dresden 2 and 3 B 3 .4 .5-2 Revision 4~

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES (continued)

APPLICABLE A threat of significant compromise to the RCPB exists if the SAFETY ANALYSES barrier contains a crack that is large enough to propagate rapidly . LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB (Refs . 3 and 4) . The drywell p--dpair+ sump monitoring system is designed with the capability of detecting LEAKAGE less than the established LEAKAGE rate limits and providing appropriate alarm of excess LEAKAGE in the control room .

The primary containment atmospheric particulate sampling system provides a means to detect changes in LEAKAGE rates (Ref . 5) .

A control room alarm provided by the drywell flsew-d-wa-i-ff sump monitoring system allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary, shut down the reactor for further investigation and RCS leakage detection corrective action . The allowed LEAKAGE rates are well below instrumentation the rates predicted for critical crack sizes (Ref . 6) .

satisfies Therefore, these actions provide adequate response before a significant break in the RCPB can occur .

Criterion 1 of 10 CFR 50 .36(c)(2)(ii) . The primary containment atmospheric particulate sampling system is maintained to be consistent with NUREG-1433 .

LCO system to be considered OPERABLE, the flow toring portion of the system must be OPERABLE .

The required M~

r a~a.~~+r s~asr.~sas' ~r instrumentation to quantify unidentified "

LEAKAGE from the RCS Tom- n consists of either aii i  ,i, , iq+  the d .,. ,,l R t a"),

the drywell floor sHfflp drain sump monitoring ~Bircif system or the drywell ar~wsrrs :.sasr~

equipment drain sump monitoring system,  :~..~....,. "i'TT""

7 i . .

this T

with the drywell floor drain sump overflowing to the drywell equipment LEAKAGE ey w e , l f l e,ei, drain sumpd. Thus, e H'1'y, iii-the for either t°cp thart (continued)

Dresden 2 and 3 B 3 .4 .5-3 Revision 44

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES LCO The primary containment atmospheric particulate sampling (continued) system is available to the operators so closer examination can be made to determine the extent of any corrective action that may be required . Only one sampling method (either the manifold rack or the continuous air monitor) is required to meet the OPERABILITY requirements . With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded .

APPLICABILITY In MODES l, 2, and 3, the leakage detection systems are required to be OPERABLE to support LCO 3 .4 .4 . This Applicability is consistent with that for LCO 3 .4 .4 .

ACTIONS A .1 With t required RCS LEAKAGE

---inoperable, no other form of sampling can provide the detection equivalent information to quantify leakage . However, other instrumentation onitoring systems are normally available that will provide cation of changes in leakage .

With the ei--able, but with RCS unidentified and total LEAKAGE being determined every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (SR 3 .4 .4 .1), operation may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> . The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time of Required Action A .l is acceptable, based on operating experience, considering the alternative form of leakage detection that is normally available and the fact that the LEAKAGE is still being determined every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> .

With the primary containment atmospheric particulate sampling system inoperable, operation may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> . The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time of Required Action B .1 is acceptable, based on operating experience, considering the alternative form of leakage detection that is normally available and the fact that the LEAKAGE is still being determined every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (SR 3 .4 .4 .1) .

(continued)

Dresden 2 and 3 B 3 .4 .5-4 Revision -

0-I-

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES ACTIONS C .1 and C .2 (continued)

If the Required Action and associated Completion Time of Condition A or B cannot be met, the plant must be brought to a MODE in which the LCO does not apply . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> . The allowed Completion Times are reasonable, based on operating experience, to perform the actions in an orderly manner and without challenging plant systems .

SURVEILLANCE SR 3 .4 .5 .1 REQUIREMENTS This SR requires performance of a primary containment atmospheric particulate sample every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> . This is performed by either removing and analyzing the particulate and charcoal filters from the continuous air monitor or by analyzing a grab sample .

SR 3 .4 .5,2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the The test ensures that the--,o; can perform its function in the dp~sd'm ner na . The test also verifies the rel ccuracy of the instrument string . A required RCS LEAKAGE suc~es~urt-irest of the required contact(s) of a channel detection relay may be performed by the verification of the change of instrumentation state of a single contact of the relay . This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay . This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions . The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation .

(continued)

Dresden 2 and 3 B 3 .4 .5-5 Revision 44

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES SURVEILLANCE SR 3 .4 .5 .3 REQUIREMENTS (continued) This SR is for the performance of a CHANNEL CALIBRATION of the (i .e ., drywell floor drain sump pump discharge flow integrator-}; and the required RCS LEAKAGE detection instrumentation drywell equipment drain sump pump discharge flow channels integrator) . The calibration verifies the accuracy of the instrument string . The Frequency of SR 3 .4 .5 .3 is based on the assumption of a 12 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis .

REFERENCES 1 . UFSAR, Section 3 .1 .2 .4 .1 .

2. Regulatory Guide 1 .45, May 1973 .

3. LEAP-5620, "Failure Behavior in ASTM A106B Pipes Containing Axial Through-Wall Flaws," April 1968 .

4. NUREG-75/067, "Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants," October 1975 .

5. UFSAR, Section 5 .2 .5 .2 .

6. UFSAR, Section 5 .2 .5 .6 .4 .

Dresden 2 and 3 B 3 .4 .5-6 Revision

ATTACHMENT 3b Proposed Markup of QCNPS Technical Specification Bases B3.4.5 RCS Leakage Detection Instrumentation

RCS Leakage Detection Instrumentation B 3 .4 .5 B 3 .4 REACTOR COOLANT SYSTEM (RCS)

B 3 .4 .5 RCS Leakage Detection Instrumentation BASES BACKGROUND UFSAR, Sections 3 .1 .3 .6 and 3 .1 .6 .4 (Ref . 1), require means for detecting RCS LEAKAGE . Regulatory Guide 1 .45 (Ref . 2) describes acceptable methods for selecting leakage detection systems .

Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RCPB is impaired (Ref . 2) .

Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative quantifying measurement of leakage rates . The Bases for LCO 3 .4 .4, "RCS Operational LEAKAGE," discuss the limits on RCS LEAKAGE es .

from the drywell sumps with the required RCS Systems forl-s~~ the LEAKAGE LEAKAGE detection are necessary to provide prompt instrumentation (i .e .,

the drywell floor and quantitative information to the operators to permit them drain sump monitoring o take immediate corrective action .

system or the drywell equipment drain sump LEAKAG om the RCPB inside the drywell is detected by at monitoring system, least one o wo independently monitored variables, such as with the drywell floor changes in flow and drain sump overflowing drywell particulate radioactivity levels . The deywe4l-,

to the drywell equipment drain sump),

he drywell floor drain sump monitoring system monitors the LEAKAGE collected in the floor drain sump . This unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the Closed Cooling Water System, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump . Leakage into the drywell floor drain sump is pumped through a piping header that penetrates the containment wall to the Liquid Radioactive Waste System .

Although alternate methods of detecting RCS LEAKAGE are (continued) available, the sole means of quantifying RCS leakage is with the required RCS LEAKAGE detection instrumentation .

Quad Cities 1 and 2 B 3 .4 .5-1 Revision $

RCS Leakage Detection Instrumentation B 3 .4 .5 Insert QC B3 .4 .5-1 sumps BASES BACKGROUND Two drywell flo r drain sump pumps (continued) and discharge to the Liquid Radioactive Wa to System . When a high level is reached in the a level switch actuates to start a f l eep --d-pa~* sump pump when the pump discharge valves are open . A flow monitor i n the discharge line of the d+y-we4 f 1 eel . d-fi-n sump pumps provides a flow input to a flow and two drywell integrator in the control room . The flow integrator is used equipment drain sump to quantify the amount of sump input . The pumps can also be pumps take suction started from the control room .

from their respective sumps The primary containment atmospheric particulate monitoring system continuously monitors the primary containment atmosphere for airborne particulate radioactivity . A sudden increase of radioactivity, which may be attributed to RCPB steam or reactor water LEAKAGE, is annunciated in the control room . The primary containment atmospheric particulate monitoring system is not capable of quantifying LEAKAGE rates, but satisfies the Regulatory Guide 1 .45 (Ref . 2) recommended sensitivity of 1 .0E-9 pCi/cc radioactivity for airborne particulates .

APPLICABLE A threat of significant compromise to the RCPB exists if the SAFETY ANALYSES barrier contains a crack that is large enough to propagate rapidly . LEAKAGE rate limits are set low enough to detect the LEAKAGE emitted from a single crack in the RCPB (Refs. 4 and 5) . The drywell fleep -dF-a4-rr sump monitoring system i s designed with the capability of detecting LEAKAGE less than the established LEAKAGE rate limits . The primary containment atmospheric particulate monitoring system provides indication of changes in leakage rates .

A control room alarm, provided by the primary containment atmospheric particulate monitoring system, allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary, shut down the reactor for further investigation and corrective action . The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Ref . 6) . Therefore, these actions provide adequate response before a significant break in the RCPB can occur .

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50 .36(c)(2)(ii) .

(continued)

Quad Cities 1 and 2 B 3 .4 .5-2 Revision 4

RCS Leakage Detection Instrumentation B 3 .4 .5 BASES (continued)

LCO The required fep the system to be considered OPERABLE, the flow instrumentation to quantify unidentified monitoring portion of the system must be OPERABLE . The LEAKAGE from the RCS other monitoring system (particulate) provides early alarms consists of either the to the operators so closer examination of other detection drywell floor drain sump systems will be made to determine the extent of any monitoring system or the corrective action that may be required . With the leakage drywell equipment drain detection systems inoperable, monitoring for LEAKAGE in the sump monitoring system, RCPB is degraded .

with the drywell floor drain sump overflowing to the drywell equipment drain sump . Thus, for In MODES 1, 2, and 3, leakage detection systems are required either to be OPERABLE to support LCO 3 .4 .4 . This Applicability is consistent with that for LCO 3 .4 .4 .

ACTIONS With the inopje~le, no other form of sampling can provide the ivalent information to quantify leakage . However, the required RCS LEAKAGE primary containment atmospheric particulate monitoring detection system will provide indication of changes in leakage .

instrumentation With i-+re-pew, but with RCS unidentified and total LEAKAGE being determined every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (SR 3 .4 .4 .1), operation may continue for 30 days . The 30 day Completion Time of Required Action A .1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available .

B .l and B . 2 With the primary containment atmospheric particulate monitoring system inoperable, grab samples of the primary containment atmosphere must be taken and analyzed to provide periodic leakage information . Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the plant may be operated for up to 30 days to allow restoration of the required monitor .

(continued)

Quad Cities 1 and 2 B 3 .4 .5-3 Revision 24

Insert QC 3 .4 .5-1 An alternate to the drywell floor drain sump monitoring system for quantifying unidentified LEAKAGE is the drywell equipment drain sump monitoring system, if the drywell floor drain sump is overflowing to the drywell equipment drain sump . In this configuration, the drywell equipment drain sump collects all leakage into the drywell equipment drain sump and the overflow from the drywell floor drain sump .

Therefore, if the drywell floor drain sump is overflowing to the drywell equipment drain sump, the drywell equipment drain sump monitoring system can be used to quantify unidentified LEAKAGE . In this condition, all LEAKAGE measured by the drywell equipment drain sump monitoring system is assumed to be unidentified LEAKAGE . The LEAKAGE determination process, including the transition to and use of the alternate method is described in station procedures . This configuration would only be used when the drywell floor drain sump monitoring system is unavailable .

ATTACHMENT 4 List of Regulatory Commitments The following table identifies those actions committed to by EGC for Dresden Nuclear Power Station and Quad Cities Nuclear Power Station as part of the License Amendment Request .

Any other statements in this submittal are provided for information purposes and are not regulatory commitments.

Commitment Commitment Commitment Event Number Date One-Time Programmatic Action (Yes/No)

(Yes/No)

CM-1 EGC will verify that the drywell Prior to initial use Yes No floor drain sump overflows into of the alternate the drywell equipment drain sump monitoring sump at DNPS Unit 2 . method for DNPS Unit 2.

CM-2 EGC will verify that the drywell Prior to initial use Yes No floor drain sump overflows into of the alternate the drywell equipment drain sump monitoring sump at QCNPS Unit 1 . method for QCNPS Unit 1 .

CM-3 EGC will verify that the drywell Prior to initial use Yes No floor drain sump overflows into of the alternate the drywell equipment drain sump monitoring sump at QCNPS Unit 2. method for QCNPS Unit 2.