Text

Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel
	ML21231A144
Person / Time
Site:	Dresden, Clinton, Quad Cities, LaSalle
Issue date:	08/19/2021
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-21-078
	Download: ML21231A144 (64)
	v • d • e

4300 Winfield Road Warrenville , IL 60555 Exelon Generation 630 657 2000 Office RS-21-078 10 CFR 50.90 August19,2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station , Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 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:

Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements," and TSTF-583-T, "TSTF-582 Diesel Generator Variation" References : 1. Letter from P.R. Simpson (Exelon) to U.S. NRC, "Application to Revise Technical Specification to Adopt TSTF-582, 'Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements,"' dated November 18, 2020 (ML20323A248)

2. Email from S. Wall (U.S. Nuclear Regulatory Commission) to R. Steinman (Exelon Generation Company, LLC),

Subject:

"Final RAI - Exelon Fleet LAR to Adopt TSTF-582 and TSTF-583-T (EPID Nos. L-2020-LLA-0253, and L-2020-LLA-0254)," dated July 8, 2021 (ML21190A019)

In the Reference 1 letter, Exelon Generation Company, LLC, (EGC) requested an amendment to Facility Operating License (FOL) No. NPF-62 for Clinton Power Station , Unit 1, Renewed FOL Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3, Renewed FOL Nos. NPF-11 and NPF-18 for LaSalle County Station, Units 1 and 2, and Renewed FOL

August 19, 2021 U.S. Nuclear Regulatory Commission Page2 Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2. The proposed amendment is consistent with previously NRC-approved Industry/Technical Specification Task Force Traveler 582 (TSTF-582), Revision 0, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements," (Reference 1), and also incorporates the variation described in TSTF-583-T, Revision 0, "TSTF-582 Diesel Generator Variation."

In Reference 2, the NRC requested additional information that is needed to complete the review of the proposed amendment. In response to this request, EGC is providing the additional information requested in Attachments 1 through 4. contains the response to the request for additional information (RAI) in Reference 2. Attachment 2 contains corrected Technical Specification markup for Dresden. contains corrected Technical Specification markup for LaSalle. Attachment 4 contains corrected Technical Specification markup for Quad Cities. Attachments 2, 3 and 4 will replace in its entirety Attachments 2.2, 2.3, and 2.4, respectively, of the original submittal (Reference 1).

EGC has reviewed the information supporting the finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition , the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained within this letter.

Should you have any questions concerning this letter, please contact Ms. Linda Palutsis at (630) 657-2821.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of August 2021.

Respectfully, P~R Patrick Si~

Sr Manager Licensing Exelon Generation Company, LLC

August19 , 2021 U.S. Nuclear Regulatory Commission Page 3 Attachments:

1. Response to Request for Additional Information

2. Markup of Proposed Technical Specification Pages for Dresden Nuclear Power Station

3. Markup of Proposed Technical Specification Pages for LaSalle County Station

4. Markup of Proposed Technical Specification Pages for Quad Cities Nuclear Power Station cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Response to Request for Additional Information

Background

Paragraph 50.36(c)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires that TSs include surveillance requirements (SRs), which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation (LCOs) will be met.

The LCO and associated SRs for alternating-current (AC) electrical power sources that are applicable when a unit is in modes 1, 2, and 3 are specified in TS 3.8.1, "AC Sources -

Operating." The LCOs and associated SRs for AC electrical power sources and electrical distributions systems that are applicable when a unit is in modes 4 and 5 or during movement of recently irradiated fuel assemblies in the secondary containment are specified in TS 3.8.2, "AC Sources - Shutdown," and TS 3.8.8, "Distribution Systems - Shutdown," respectively.

Request Additional Information {RAI) 1 {Dresden)

Section 8.3.1.5.2 , "System Arrangement," of the Dresden Updated Final Safety Analysis Report (UFSAR) states, in part, that diesel generator (DG) 2 provides power to the Division II emergency core cooling system (ECCS) equipment for Unit 2, and DG 3 provides power to Division II ECCS equipment for Unit 3. DG 2/3 provides power to the Division I ECCS equipment for either Unit 2 or Unit 3.

Dresden LCO 3.8.1.d requires that the following AC electrical power source be operable when the unit is operating : "The opposite unit's DG capable of supporting the equipment required to be OPERABLE by LCO 3.6.4.3, LCO 3.7.4 (Unit 3 only), and LCO 3.7.5 (Unit 3 only)." SR 3.8.1.21 is applicable to the opposite unit's AC electrical power sources and it specifies, in part, the SRs necessary to meet LCO 3.8.1.d.

Dresden LCO 3.8.2.b requires that the following AC electrical power source be operable when the unit is shutdown: "One diesel generator (DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8." When a unit is shutdown, Dresden LCO 3.8.8 requires: "The necessary portions of the AC , DC [direct current],

and the opposite unit's Division 2 electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE." Dresden SR 3.8.2.1 specifies the SRs in TS 3.8.1 that are necessary to meet LCO 3.8.2.

The licensee proposed to revise Dresden SR 3.8.2.1 as shown in the table below. The proposed changes would make several SRs for AC sources required by TS 3.8.2 no longer applicable . The licensee also proposed to revise TS 3.3.8.1, "Loss of Power (LOP)

Instrumentation," such that LCO 3.3.8.1 would no longer be applicable "[w]hen the associated diesel generator is requ ired to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown."' The LAR states that these changes are based on TSTF-582 and TSTF-583-T. However, these travelers and the NRC safety evaluation for TSTF-582 do not address shared AC sources at multi-unit sites. In addition , the LAR does not address the shared AC sources at Dresden . The LAR also proposes, without justification, to delete SRs currently required by SR 3.8.2.1 (e.g.,

Dresden SR 3.8.1. 7) which are not included in the TSTF-582 or TSTF-583-T changes . The proposed changes would also make SR 3.8.2.1 inconsistent with SR 3.8.1.21 .

Page 1

ATTACHMENT 1 Response to Request for Additional Information Current SR 3.8.2.1 Proposed SR 3.8.2.1

N 0 TE-------------------- -------------------N 0 TE--------------------

The following SRs are not required to be The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 performed : SR 3.8.1.3, SR 3.8.1 .10, through SR 3.8.1.12 , and SR 3.8.1.14 SR 3.8.1 .11 , SR 3.8.1.15, and SR 3.8.1.17.

through -------------------------------------------

SR 3.8.1 .18. The following SRs are applicable for AC

sources required to be OPERABLE:

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR3.8.1.1 SR 3.8.1.6 SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.19, SR 3.8.1.2 SR 3.8.1.10 SR 3.8.1 .20, and SR 3.8.1.21 are applicable. SR 3.8.1 .3 SR 3.8.1.11 SR 3.8.1.4 SR 3.8.1.15 SR 3.8.1 .5 SR 3.8.1.17 Provide the following information for Dresden:

A. For SR 3.8.2.1, identify the currently applicable SRs of TS 3.8.1 that are necessary to meet LCO 3.6.4.3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should discuss the following plant conditions : Unit 2 operating and Unit 3 shutdown , Unit 2 shutdown and Unit 3 operating , and both Units 2 and 3 shutdown.

B. For each SR of TS 3.8 .1 that would no longer be applicable to TS 3.8.2 under the proposed amendment, explain why the SR is not needed to support the opposite unit or to meet the requirements of LCO 3.8.2. The response should address the requirements in LCO 3.6.4.3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should also identify and address any differences between the events considered in the NRC staffs safety evaluation for TSTF-582 and the Dresden design and licensing basis.

C. Identify the changes to SR 3.8.1.21 that are needed to make it consistent with the proposed SR 3.8.2.1. Provide justification to support these changes.

D. In conjunction with the information requested under A, B, and C above, justify the deletion of the following wording from the Applicability of LCO 3.3.8.1: "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown."'

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ATTACHMENT 1 Response to Request for Additional Information Response to RAI 1 (Dresden):

Part A Dresden Surveillance Requirement (SR) 3.8.2.1 lists the subset of SRs from Technical Specification (TS) 3.8.1, "AC Sources - Operating," that are required to be met for alternating current (AC) electrical power sources that are required to be operable by limiting condition for operation (LCO) 3.8.2, "AC Sources - Shutdown." LCO 3.8.2 is applicable to a unit that is in modes 4 or 5, or during movement of recently irradiated fuel assemblies in the secondary containment. LCO 3.8.2 requires one offsite circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown," and one diesel generator (DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8.

According to LCO 3.0.9 and SR 3.0.5, LCOs and SRs, respectively, are applied individually to each unit at a dual-unit site, such that the operating mode of one unit does not affect the application of the TS to the opposite unit. Therefore, the TS 3.8.1 SRs that are currently required to be met by SR 3.8.2.1 when a unit is in the mode of applicability of SR 3.8.2 are independent of the opposite unit's mode. The applicability of these SRs under the current Dresden SR 3.8.2.1 wording (prior to adoption of TSTF-582) is summarized in Table 1A-1 .

Table 1A-1 Dresden TS 3.8.1 SRs Required by Current SR 3.8.2.1 SR Unit Two (Shutdown) Unit Three (Shutdown}

3.8.1 .1 Applicable (offsite circuit) Applicable (offsite circuit) 3.8.1 .2 Applicable* Applicable**

3.8.1 .3 Applicable* Applicable**

3.8.1.4 Applicable* Applicable**

3.8.1 .5 Applicable* Applicable**

3.8.1 .6 Applicable* Applicable**

3.8.1 .7 Applicable* Applicable**

3.8.1 .8 Applicable* Applicable**

3.8.1 .9 Not Applicable Not Applicable 3.8.1.10 Applicable* Applicable**

3.8.1.11 Applicable* Applicable**

3.8.1.12 Applicable* Applicable **

3.8.1.13 Not Applicable Not Applicable 3.8.1.14 Applicable* Applicable**

3.8.1.15 Applicable* Applicable**

3.8.1.16 Applicable* Applicable**

3.8.1.17 Applicable* Applicable**

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ATTACHMENT 1 Response to Request for Additional Information SR Unit Two (Shutdown) Unit Three (Shutdown) 3.8.1.18 Applicable* Applicable**

3.8.1.19 Not Applicable Not Applicable 3.8.1.20 Not Applicable Not Applicable 3.8.1.21 Not Applicable Not Applicable

For Unit 2, the required DG will be either the Unit 2 DG or the Unit 2/3 (shared) DG.

- For Unit 3, the required DG will be either the Unit 3 DG or the Unit 2/3 (shared) DG.

LCOs 3.6.4 .3, 3.7.4, and 3.7.5 are not applicable to a unit that is in mode 4 or 5 unless recently irradiated fuel is being moved in the shared secondary containment. These LCO's, when applicable, require equipment to be operable that is powered by both the same unit and the opposite unit's AC distribution subsystem(s). For equipment powered by the same unit (e.g., for Unit 2, 2/38 Standby Gas Treatment (SBGT), Control Room Emergency Ventilation (CREV),

and Control Room Emergency Ventilation Air Conditioning (CREV-AC)), the AC Sources required by LCO 3.8.2 support the associated equipment, with applicable SRs specified in the table above. For equipment powered by the opposite unit (e.g., for Unit 2, 2/3A SBGT), the required opposite unit distribution subsystems are required to be operable by LCO 3.8.8; however, no corresponding opposite unit requirement exists under LCO 3.8.2 for AC Sources.

This is supported by the current bases of LCO 3.8.2 state that:

"In general, when the unit is shutdown the Technical Specification requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in modes 1, 2, and 3 have no specific analyses in modes 4 and 5. Worst case bounding events are deemed not credible in modes 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from OBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems."

Therefore, under current Dresden's TS the applicable SR's of LCO 3.8.1 that are specified to be met under SR 3.8.2 .1 for the AC sources required to be operable by LCO 3.8.2 are those listed in the table above, even if movement of recently irradiated fuel in secondary containment is causing the shutdown unit to be in the mode of applicability of LCOs 3.6.4.3, 3.7.4, and 3.7.5. Adequate power to support the operability of required opposite unit equipment is assured by LCO 3.8.8.

For any operating unit, even if the opposite unit is shutdown , all SR's of LCO 3.8.1 apply to the AC sources required to be operable, which will include one qualified circuit between the offsite transmission network and the opposite unit's onsite Class 1E AC Electrical Power Distribution System and the opposite unit DG capable of supporting LCOs 3.6.4.3, 3.7.4, and 3.7.5.

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ATTACHMENT 1 Response to Request for Additional Information Part B Since no changes have been proposed for SR 3.8.1.21, any opposite unit AC sources required by a unit operating in mode 1, 2, or 3 will continue to be subject to the existing set of SRs to establish operability. For multi-unit sites with shared AC distribution systems and sources, the same AC Source (e.g., a unit or shared DG) may be required for each Unit by different LCOs (e.g., LCO 3.8.1 or LCO 3.8.2); however, the basis for the equipment being required to be operable is different for an operating unit versus a shutdown unit. Since the operating unit must still have the capability to mitigate the effects of Design Basis Accidents (OBA) analyzed for operating conditions (e.g., OBA Loss of Coolant Accident), all of the requirements associated with DG automatic start in response to Emergency Core Cooling Systems (ECCS) or Loss of Offsite Power (LOOP) signals, time to achieve rated voltage and frequency, and load sequencing continue to be required. Thus, no changes to SR 3.8.1.21 are appropriate or proposed.

As described in the Safety Evaluation for TSTF-582 (Reference 1) and supported by the Loss of Power (LOP) Variation model Safety Evaluation (Reference 2), the DGs supporting a shutdown unit (operating in mode 4, 5, or during movement of recently irradiated fuel in secondary containment) may be manually started and loaded in response to a Reactor Pressure Vessel (RPV) draining event. Furthermore, the essential consideration for the events assessed in Reference 1, namely that the Fuel Handling Accident (FHA) does not assume a LOOP and that the minimum Drain Time permitted for any duration by LCO 3.5.2 is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , are consistent with the Dresden licensing basis. The ability of each required DG to support the required loads via manual start and loading continues to be demonstrated by the SRs that are retained under the proposed revision to SR 3.8.2.1. Additionally, for the FHA, no credit in the analysis is taken for the operation of SBGT, GREV, or GREV-AC (Reference 3). Equipment required by LCOs 3.6.4.3, 3.7.4, and 3.7.5 will continue to be supported by operable distribution subsystems specified by LCO 3.8.8. The Dresden licensing basis does not include any additional events requiring automatic start of DGs for a shutdown unit that have not already been considered in the safety evaluation for TSTF-582 (i.e. , Fuel Handling Accident, draining event in mode 4 or 5).

The proposed LAR does not affect which AC sources will be required via LCO 3.8.2 to support the distribution systems required operable via LCO 3.8.8, but only revises the applicable SRs that are required to consider a DG operable for LCO 3.8.2 (though additional SRs may apply to the same DG and its associated start logic if required by an operating unit via SR 3.8.1.21 ).

Based on the above considerations, justification for deletion of each proposed SR of LCO 3.8.1 from the list of SRs required by the DG(s) required to be operable by LCO 3.8 .2 is provided :

SR 3.8.1 .8 This surveillance verifies the DG ability to achieve required voltage and frequency within 13 seconds. The 13 second timeframe is not required to support manual start of the DG in response to the postulated events in mode 4 or 5, and the ability of the DG to be manually started and loaded continues to be demonstrated by SR 3.8.1.2. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21 . This SR is equivalent to SR 3.8.1.7 from NUREG-1433 Revision 4, with the exception that the Dresden SR includes a note allowing the performance of this test for the common DG to satisfy this SR for both Units. This SR is assessed for deletion from the NUREG-1433 Standard Technical Specification (STS) SR 3.8.2.1 in Reference 2.

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ATTACHMENT 1 Response to Request for Additional Information SR 3.8.1 .12 This surveillance verifies, in part, the automatic start and loading of a DG on a LOOP signal. As previously discussed, response to the postulated events in mode 4 and 5 does not require automatic start and loading of a DG. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21 . This SR is equivalent to SR 3.8.1 .11 from NUREG-1433 Revision 4, with the exception that Dresden does not include the verification of auto-connected loads through a load sequencer (since the Dresden design does not have this feature). This SR is approved for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 1.

SR 3.8.1 .14 This surveillance verifies that the required DG's noncritical automatic trips are bypassed on an actual or simulated loss of voltage signal on the emergency bus concurrent with an actual or simulated ECCS initiation signal. Since the requirement for operable ECCS initiation signals is proposed for removal from LCO 3.3.5.2, removal of this surveillance from the list of those surveillances required for a DG supporting LCO 3.8.2 establishes consistency. Consistent with the assessment provided in Section 3.6 of Reference 1, LCO 3.8.2 and LCO 3.5.2 will, upon an actual LOOP, continue to require the restoration of an RPV injection source capable of operating without offsite power within a timeframe adequate for responding to a vessel draining event. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21. This SR is equivalent to SR 3.8.1.13 from NUREG-1433 Revision 4. This SR is approved for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 1.

SR 3.8.1 .16 This surveillance demonstrates that the DG can restart from a hot condition, such as subsequent to shutdown from normal surveillances, and achieve the required voltage and frequency within 13 seconds. The 13 second timeframe is not required to support manual start of the DG in response to the postulated events in mode 4 or 5, and the ability of the DG to be manually started and loaded continues to be demonstrated by SR 3.8.1.2 . If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1 .21. This SR is equivalent to SR 3.8.1 .15 from NUREG-1433 Revision 4, with the exception that the Dresden SR includes a note allowing the performance of this test for the common DG to satisfy this SR for both Units. This SR is assessed for deletion from the NUREG-1433 STS SR 3.8.2 .1 in Reference 2.

SR 3.8.1.18 This surveillance verifies the interval between each sequenced load block is ~90% of the design interval for each load sequence time delay relay. This logic is associated with automatic start and loading of an EOG in response to an ECCS initiation signal concurrent with a LOOP. Since the requirement for operable ECCS initiation signals is proposed for removal from LCO 3.3.5.2, removal of this surveillance from the list of those surveillances required a DG supporting LCO 3.8.2 establishes consistency. Manual loading of the DG will continue to be able to be performed by licensed operators in response to the postulated events in mode 4 and 5 or during Page 6

ATTACHMENT 1 Response to Request for Additional Information movement of recently irradiated fuel in secondary containment. This SR is equivalent to SR 3.8.1 .18 from NUREG-1433 Revision 4. This SR is assessed for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 2.

SR 3.8.1 .7 SR 3.8.1 .7 was inadvertently removed from the list of SRs required to be performed under SR 3.8.2.1 even though it is required as shown in Table 1A-1. Attachment 2 provides the corrected markup of SR 3.8.2.1. Attachment 2 will replace in its entirety Attachment 2.2 of the original submittal. However, the only change to the markup is the correction to SR 3.8.2.1 on Page 3.8.2-3.

Part C As discussed in the responses to Parts A and B, no changes are required for SR 3.8.1.21, as this SR continues to specify the appropriate criteria for operability of an opposite unit AC source that is required by a unit operating in modes 1, 2, or 3.

Part D As described in Part B, the DGs supporting a shutdown unit (operating in mode 4, 5, or during movement of recently irradiated fuel in secondary containment) may be manually started and loaded in response to a Reactor Pressure Vessel (RPV) draining event.

TSTF-582 did not include all the TS changes needed to reflect that TS 3.8.2 does not require automatic start and loading of a DG within 13 seconds on an ECCS initiation signal or LOOP signal. TSTF-583-T addressed these additional changes, which included the revision of the Applicability of LCO 3.3.8.1 to remove the currently specified condition "When the associated diesel generator as required to be OPERABLE by LCO 3.8.2 , 'AC Sources - Shutdown ."'

TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is currently applicable in modes 1, 2, and 3, and when the associated DG is required to be operable by TS 3.8.2. Implementation of TSTF-582 revises TS 3.8.2 to no longer require automatic start and loading of a DG on a LOOP signal. Consequently, the instrumentation that generates the LOOP signal should not be required to be operable when the DG is required to be operable by TS 3.8.2. As a result, the deletion of the condition related to TS 3.8.2 in the applicability of LCO 3.3.8.1 is appropriate.

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ATTACHMENT 1 Response to Request for Additional Information RAI 2 (LaSalle)

Section 8.3.1.1.2, "Unit Class 1E A-C Power System ," of the LaSalle UFSAR states, in part, that the main components of the unit Class 1E AC power system for Unit 1 (or Unit 2) are three DGs, one of which is common to Unit 1 and Unit 2.

LaSalle LCO 3.8.1 .c requires that the following AC electrical power source be operable when the unit is operating : "The opposite unit's Division 2 DG capable of supporting the associated equ ipment requi red to be OPERABLE by LCO 3.6.4.3, 'Standby Gas Treatment (SGT) System ,'

LCO 3.7.4 , 'Control Room Area Filtration (CRAF) System,' and LCO 3.7.5, 'Control Room Area Ventilation Air Conditioning (AC) System."' SR 3.8.1 .21 is applicable to the opposite unit's AC electrical power sources and it specifies, in part, the SRs necessary to meet LCO 3.8.1 .c.

LaSalle LCO 3.8.2 requ ires , in part, that the following AC electrical power sources be operable when the unit is shutdown:

b. One diesel generator (DG) capable of supplying one division of the Division 1 or 2 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8;

d. One qualified circuit, which may be the same circuit in LCO 3.8.2.a. between the offsite transmission network and the opposite unit Division 2 onsite Class 1E AC electrical power distribution subsystem , or the opposite unit DG capable of supplying the opposite unit Division 2 onsite Class 1E AC electrical power distribution subsystem , when the opposite unit Division 2 onsite Class 1E AC electrical power distribution subsystem is requ ired by LCO 3.8.8.

When a unit is shutdown , LaSalle LCO 3.8.8 requires: "The necessary portions of the Division 1, Division 2, and Division 3 AC and DC, and the opposite unit Division 2 AC and DC electrical power distribution subsystems shall be OPERABLE to support equ ipment required to be OPERABLE." LaSalle SR 3.8.2 .1 specifies the SRs in TS 3.8.1 that are necessary to meet LCO 3.8 .2.

The licensee proposed to revise LaSalle SR 3.8.2 .1 as shown in the table below. The proposed changes would make several SRs for AC sources required by TS 3.8.2 no longer applicable.

The licensee also proposed to revise LaSalle TS 3.3.8.1, "Loss of Power (LOP)

Instrumentation," such that LCO 3.3.8.1 would no longer be applicable "[w]hen the associated diesel generator (DG) is required to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown. "'

The LAR states that these changes are based on TSTF-582 and TSTF-583-T. However, these travelers and the NRC safety evaluation for TSTF-582 do not address shared AC sources at multi-unit sites. In addition , the LAR does not address the shared AC sources at LaSalle. The LAR also proposes, without justification , to delete SRs currently required by SR 3.8.2.1 (e.g. ,

LaSalle SR 3.8.1 .21) which are not included in the TSTF-582 or TSTF-583-T changes. The proposed changes would also make SR 3.8.2.1 inconsistent with SR 3.8.1.21 .

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ATTACHMENT 1 Response to Request for Additional Information Current SR 3.8.2.1 Proposed SR 3.8.2.1

N 0 TES-------------------- -------------------N 0 TE--------------------

1. The following SRs are not requ ired to be The following SRs are not requ ired to be performed: SR 3.8.1 .3, SR 3.8.1.9 performed : SR 3.8.1.3, SR 3.8.1.9, through SR 3.8.1.11 , and SR 3.8.1.13 SR 3.8.1 .10, SR 3.8.1.14, and SR 3.8.1.16.

through SR 3.8.1.16, SR 3.8.1 .18, and ---------------------------------------------

SR 3.8.1.19. The following SRs are appl icable for AC sources required to be OPERABLE:

2. SR 3.8.1.12 and SR 3.8.1.19 are not required to be met. SR3.8.1.1 SR 3.8.1 .6

SR 3.8.1.2 SR 3.8.1 .9 For AC sources required to be OPERABLE , SR 3.8.1 .3 SR 3.8.1.10 the SRs of Specification 3.8.1, except SR 3.8.1.4 SR 3.8.1 .14 SR 3.8.1 .8, SR 3.8.1.17, and SR 3.8.1.20, SR 3.8.1 .5 SR 3.8.1.16 are applicable.

Provide the following information for LaSalle:

A. For SR 3.8.2.1, identify the currently applicable SRs of TS 3.8.1 that are necessary to meet LCO 3.6.4 .3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should discuss the following plant conditions : Unit 1 operating and Unit 2 shutdown , Unit 1 shutdown and Unit 2 operating , and both Units 1 and 2 shutdown.

B. For each SR of TS 3.8.1 that would no longer be applicable to TS 3.8.2 under the proposed amendment, explain why the SR is not needed to support the opposite unit or to meet the requirements of LCO 3.8.2. The response should address the requirements in LCO 3.6.4.3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should also identify and address any differences between the events considered in the NRC staff's safety evaluation for TSTF-582 and the LaSalle design and licensing basis.

C. Identify the changes to SR 3.8.1.21 that are needed to make it consistent with the proposed SR 3.8.2.1. Provide justification to support these changes.

D. In conjunction with the information requested under A, B, and C above, justify the deletion of the following wording from the Applicability of LCO 3.3.8.1 : "When the associated diesel generator (DG) is required to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown. "'

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ATTACHMENT 1 Response to Request for Additional Information Response to RAI 2 (LaSalle):

PART A:

LaSalle SR 3.8.2.1 lists the subset of SRs from TS 3.8.1, "AC Sources - Operating," that are required to be met for alternating current (AC) electrical power sources that are required to be operable by LCO 3.8.2, "AC Source - Shutdown." LCO 3.8.2 is applicable to a unit that is in modes 4 or 5, or during movement of irradiated fuel assemblies in the secondary containment.

LCO 3.8.2 requires one offsite circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown," and one diesel generator (DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8 and LCO 3.8 .2.d.

According to LCO 3.0.9 and SR 3.0.5, LCOs and SRs, respectively, are applied individually to each unit at a dual-unit site, the operating mode of one unit does not affect the application of the TS to the opposite unit. Therefore, the TS 3.8.1 SRs that are required to be met by SR 3.8.2.1 when a unit is in the mode of applicability of SR 3.8.2 are independent of the opposite unit's mode. The applicability of these SRs under the current LaSalle SR 3.8.2 .1 wording (prior to adoption of TSTF-582) is summarized in Table 2A-1.

Table 2A-1 LaSalle TS 3.8.1 SRs Required by Current SR 3.8.2.1 SR Unit One {Shutdown) Unit Two (Shutdown) 3.8.1.1 Applicable Applicable 3.8.1.2 Applicable Applicable 3.8.1.3 Applicable Applicable 3.8.1.4 Applicable Applicable 3.8.1.5 Applicable Applicable 3.8.1.6 Applicable Applicable 3.8.1.7 Applicable Applicable 3.8.1.8 Not Applicable Not Applicable 3.8.1.9 Applicable Applicable 3.8.1.10 Applicable Applicable 3.8.1.11 Applicable Applicable 3.8.1.12 Applicable Applicable 3.8.1.13 Applicable Applicable 3.8.1.14 Applicable Applicable 3.8.1.15 Applicable Applicable 3.8.1.16 Applicable Applicable 3.8.1.17 Not Applicable Not Applicable 3.8.1.18 Required Applicable 3.8.1.19 Required Applicable Page 10

ATTACHMENT 1 Response to Request for Additional Information SR Unit One {Shutdown) Unit Two {Shutdown) 3.8.1.20 Not Applicable Not Applicable 3.8.1.21 Not Applicable Not Applicable LCOs 3.6.4.3, 3.7.4, and 3.7.5 are not applicable to a unit that is in mode 4 or 5 unless irradiated fuel is being moved in the shared secondary containment or when core alterations are in progress. These LCO's, when applicable, require equipment to be operable that is powered by both the same unit and the opposite unit's Division 2 AC distribution subsystem(s). For equipment powered by the same unit (e.g. , for Unit 1, Unit 1 Standby Gas Treatment (SBGT), A Control Room Area Filtration (GRAF) System, and A Control Room Area Ventilation Air Conditioning (AC) System), the AC Sources required by LCO 3.8.2 support the associated equipment, with applicable SRs specified in the table above. For equipment powered by the opposite unit (e.g., for Unit 1, Unit 2 SBGT, B Control Room Area Filtration (CRAF) System, and B Control Room Area Ventilation Air Conditioning (AC) System), the required opposite unit distribution subsystems are required to be operable by LCO 3.8.8; however, no corresponding opposite unit requirement exists under LCO 3.8.2 for AC Sources. This is supported by the current bases of LCO 3.8.2 state that:

"In general, when the unit is shutdown the Technical Specification requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents.

However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required . The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in modes 1, 2, and 3 have no specific analyses in modes 4 and 5. Worst case bounding events are deemed not credible in modes 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences. These deviations from OBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems."

Therefore, under current LaSalle TS the applicable SR's of LCO 3.8.1 that are specified to be met under SR 3.8.2.1 for the AC sources required to be operable by LCO 3.8.2 are those listed in the table above, even if movement of irradiated fuel in secondary containment or during core alterations are causing the shutdown unit to be in the mode of applicability of LCOs 3.6.4 .3, 3.7.4, and 3.7.5. Adequate power to support the operability of required opposite unit equipment is assured by LCO 3.8.8.

For any operating unit, even if the opposite unit is shutdown , all SR's of LCO 3.8.1 apply to the AC sources required to be operable, which will include two qualified circu its between the offsite transmission network and onsite Class 1E AC Electrical Power Distribution System, three DGs (Division 1, 2 &3), and the opposite unit's onsite Class 1E AC Electrical Power Distribution System and the opposite unit DG capable of supporting LCOs 3.6.4.3, 3.7.4, and 3.7.5.

Page 11

ATTACHMENT 1 Response to Request for Additional Information PART B:

Since no changes have been proposed for SR 3.8.1.21, any opposite unit AC sources required by a unit operating in mode 1, 2, or 3 will continue to be subject to the existing set of SRs to establish operability. For multi-unit sites with shared AC distribution systems and sources, the same AC Source (e.g. , a unit or shared DG) may be required for each Unit by different LCOs (e.g. , LCO 3.8.1 or LCO 3.8.2); however, the basis for the equipment being required to be operable is different for an operating unit versus a shutdown unit. Since the operating unit must still have the capability to mitigate the effects of Design Basis Accidents (OBA) analyzed for operating conditions (e.g. OBA Loss of Coolant Accident), all of the requirements associated with DG automatic start in response to ECCS or LOOP signals, time to achieve rated voltage and frequency, and load sequencing continue to be required. Thus, no changes to SR 3.8.1.21 are appropriate or proposed.

As described in the Safety Evaluation for TSTF-582 (Reference 1) and supported by the LOP Variation model Safety Evaluation (Reference 2), the DGs supporting a shutdown unit (operating in mode 4, 5, or during movement of irradiated fuel in secondary containment) may be manually started and loaded in response to a Reactor Pressure Vessel (RPV) draining event.

Furthermore, the essential consideration for the events assessed in Reference 1, namely that the FHA does not assume a LOOP and that the minimum Drain Time permitted for any duration by LCO 3.5.2 is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , are consistent with the LaSalle licensing basis. The ability of each required DG to support the required loads via manual start and loading continues to be demonstrated by the SRs that are retained under the proposed revision to SR 3.8.2.1.

Additionally, the FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

Equipment required by LCOs 3.6.4.3, 3.7.4, and 3.7.5 will continue to be supported by operable distribution subsystems specified by LCO 3.8.8. The LaSalle licensing basis does not include any additional events requiring automatic start of DGs for a shutdown unit that have not already been considered in the safety evaluation for TSTF-582 (i.e., Fuel Handling Accident, draining event in mode 4 or 5). The proposed LAR does not affect which AC sources will be required via LCO 3.8.2 to support the distribution systems required operable via LCO 3.8.8, but only revises the applicable SRs that are required to consider a DG operable for LCO 3.8.2 (though additional SRs may apply to the same DG and its associated start logic if required by an operating unit via SR 3.8.1 .21 ).

Based on the above considerations, justification for deletion of each proposed SR of LCO 3.8.1 from the list of SRs required by the DG(s) required to be operable by LCO 3.8.2 is provided:

SR 3.8.1.7 This SR requires that the DG starts from standby conditions and achieves required voltage and frequency within 13 seconds. The 13 second start requirement supports the assumptions in the design basis Loss of Coolant Accident (LOCA) analysis.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal. Therefore, the 13 second start requirement per SR 3.8.1. 7 is not applicable.

Page 12

ATTACHMENT 1 Response to Request for Additional Information LCO 3.6.4.3, LCO 3.7.4, and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 SR 3.8.1 .11 This SR demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads (Divisions 1 and 2 only) and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time .

The DG auto-start and energization of permanently connected loads time of 13 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal. Therefore, the automatic Loss of Power diesel start per SR 3.8.1.11 is not applicable.

LCO 3.6.4 .3, LCO 3.7.4, and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 SR 3.8.1.12 This SR demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (13 seconds) from the design basis actuation signal (LOCA signal).

Page 13

ATTACHMENT 1 Response to Request for Additional Information LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal. Therefore, the automatic LOCA Signal diesel start per SR 3.8.1 .12 is not applicable.

LCO 3.6.4 .3, LCO 3.7.4 , and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 SR 3.8.1 .13 This SR demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage signal concurrent with an ECCS initiation test signal and critical protective functions (engine overspeed and generator differential current) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition . This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the OBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on a loss of voltage signal concurrent with an ECCS initiation signal. Therefore, SR 3.8.1.13 is not applicable.

LCO 3.6.4 .3, LCO 3.7.4, and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 Page 14

ATTACHMENT 1 Response to Request for Additional Information SR 3.8.1.15 This SR demonstrates that the DG can restart from a hot condition , such as subsequent to shutdown from normal surveillances, and achieve the required voltage and frequency within 13 seconds. The 13 second time is derived from the requirements of the accident analysis for responding to a design basis large break LOCA.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start or restart following a shutdown within 13 seconds. Therefore, the diesel restart demonstration per SR 3.8.1.15 is not applicable.

LCO 3.6.4 .3, LCO 3.7.4 , and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1,2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition .

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 SR 3.8.1.18 This SR verifies the interval between each sequenced load block is ~90% of the design interval for each load sequence time delay relay. This logic is associated with automatic start and loading of an EOG in response to an ECCS initiation signal concurrent with a LOOP. Since the requirement for operable ECCS initiation signals is proposed for removal from LCO 3.3.5.2, removal of this surveillance from the list of those surveillances required a DG supporting LCO 3.8.2 establishes consistency.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on a loss of power signal concurrent with an ECCS initiation signal. Therefore , demonstrating the interval for each load sequence time delay relay per SR 3.8.1.18 is not applicable.

LCO 3.6.4.3, LCO 3.7.4 , and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

Page 15

ATTACHMENT 1 Response to Request for Additional Information LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2.

SR 3.8.1 .19 This Surveillance demonstrates the DG operation during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal.

LCO 3.5.2 This LCO does not assume that the onsite electrical power source will start automatically on a loss of voltage signal concurrent with an ECCS initiation signal. Therefore, SR 3.8.1.19 is not applicable.

LCO 3.6.4.3, LCO 3.7.4, and LCO 3.7.5 These LCOs are only required in modes 1, 2, 3, during movement of irradiated fuel assemblies in the secondary containment, and during core alterations. TS 3.8.2 does not apply in modes 1, 2 or 3. The FHA analysis does not assume a Loss of Off-Site Power as an initial condition.

LCO 3.8.8 The distribution systems required to be operable per LCO 3.8.8 are not changed by the proposed LAR. The proposed changes only revise the applicable SRs that are required to consider a DG operable per LCO 3.8.2 Part C As discussed in the responses to items A and B, no changes are required for SR 3.8.1.21, as this SR continues to specify the appropriate criteria for operability of an opposite unit AC Source that is required by a Unit operating in modes 1, 2, or 3.

Part D TSTF-582, "RPV WIC Enhancements," states that LCO 3.5.2, "RPV WIC," does not assume that the onsite electrical power source will start automatically on an ECCS or loss of power signal. Additionally, the FHA analysis does not assume a Loss of Off-Site Power as an initial condition. In an oversight in TSTF-582, not all TS 3.8.1 SRs listed in SR 3.8.2.1 that test automatic start and loading of a diesel generator on an ECCS or loss of offsite power signal were excluded , and the Applicability of TS 3.3.8.1 was not revised to reflect that the LOP instrumentation should not be required to be operable when the associated EOG is not required to automatically start in response to a LOOP.

Page 16

ATTACHMENT 1 Response to Request for Additional Information RAI 3 (Quad Cities)

Section 8.3.1.6, "Standby Emergency Diesel Generator System, " of the Quad Cities UFSAR states, in part, that the DG system provides emergency source of AC power in the event all normal offsite power becomes unavailable. The system consists of three DGs: 1, 2, and 1/2 (shared DG).

Quad Cities LCO 3.8.1.d requires that the following AC electrical power source be operable when the unit is operating: "The opposite unit's DG capable of supporting the equipment required to be OPERABLE by LCO 3.6.4.3 , LCO 3.7.4 (Unit 2 only) , and LCO 3.7.5 (Unit 2 only)." SR 3.8.1.21 is applicable to the opposite unit's AC electrical power sources and it specifies, in part, the SRs necessary to meet LCO 3.8.1.d.

Quad Cities LCO 3.8.2.b requires that the following AC electrical power source be operable when the unit is shutdown: "One diesel generator (DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8." When a unit is shutdown , Quad Cities LCO 3.8.8 requires: "T he necessary portions of the AC , DC, and the opposite unit's electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE." Quad Cities SR 3.8.2.1 specifies the SRs in TS 3.8.1 that are necessary to meet LCO 3.8.2.

The licensee proposed to revise Quad Cities SR 3.8.2 .1 as shown in the table below. The proposed changes would make several SRs for AC sources required by TS 3.8.2 no longer applicable . The licensee also proposed to revise Quad Cities TS 3.3.8.1, "Loss of Power (LOP)

Instrumentation," such that LCO 3.3.8.1 would no longer be applicable "[w]hen the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown .'" The LAR states that these changes are based on TSTF-582 and TSTF-583-T. However, these travelers and the NRC safety evaluation for TSTF-582 do not address shared AC sources at multi-unit sites. In addition , the LAR does not address the shared AC sources at Quad Cities.

The LAR also proposes , without justification , to delete SRs currently required by SR 3.8.2 .1 (e.g ., Quad Cities SR 3.8.1.7) which are not included in the TSTF-582 or TSTF-583-T changes .

The proposed changes would also make SR 3.8.2.1 inconsistent with SR 3.8.1 .21.

Current SR 3.8.2.1 Proposed SR 3.8.2.1

N 0 TE-------------------- -------------------N 0 TE--------------------

The following SRs are not required to be Th e following SRs are not requi red to be performed : SR 3.8.1.3, SR 3.8.1 .10 through performed : SR 3.8.1.3, SR 3.8.1 .10, SR 3.8.1 .12, and SR 3.8.1.14 through SR 3.8.1 .11 , SR 3.8.1.15, and SR 3.8.1.17.

SR 3.8.1 .19.

The following SRs are applicable for AC For AC sources required to be OPERABLE sources required to be OPERABLE:

the SRs of Specification 3.8.1 , except SR 3.8.1 .9, SR 3.8.1.13, SR 3.8.1.19 , SR 3.8.1 .1 SR 3.8.1.6 SR 3.8.1 .20, and SR 3.8.1.21 , are applicable. SR 3.8.1 .2 SR 3.8.1.10 SR 3.8.1 .3 SR 3.8.1.11 SR 3.8.1.4 SR 3.8.1.15 SR 3.8.1 .5 SR 3.8.1.17 Provide the following information for Quad Cities:

Page 17

ATTACHMENT 1 Response to Request for Additional Information A. For SR 3.8.2.1, identify the currently applicable SRs of TS 3.8.1 that are necessary to meet LCO 3.6.4.3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should discuss the following plant conditions: Unit 1 operating and Unit 2 shutdown, Unit 1 shutdown and Unit 2 operating, and both Units 1 and 2 shutdown.

B. For each SR of TS 3.8.1 that would no longer be applicable to TS 3.8.2 under the proposed amendment, explain why the SR is not needed to support the opposite unit or to meet the requirements of LCO 3.8.2. The response should address the requirements in LCO 3.6.4.3, LCO 3.7.4, LCO 3.7.5, and LCO 3.8.8. The response should also identify and address any differences between the events considered in the NRC staffs safety evaluation for TSTF-582 and the Quad Cities design and licensing basis.

C. Identify the changes to SR 3.8.1.21 that are needed to make it consistent with the proposed SR 3.8.2.1. Provide justification to support these changes.

D. In conjunction with the information requested under A, B, and C above, justify the deletion of the following wording from the Applicability of LCO 3.3.8.1: "When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, 'AC Sources Shutdown."'

Page 18

ATTACHMENT 1 Response to Request for Additional Information Response to RAI 3 (Quad Cities):

Part A Quad Cities Surveillance Requirement (SR) 3.8.2.1 lists the subset of SRs from Technical Specification (TS) 3.8.1, "AC Source - Operating," that are required to be met for alternating current (AC) electrical power sources that are required to be operable by LCO 3.8.2, "AC Sources - Shutdown." LCO 3.8.2 is applicable to a unit that is in modes 4 or 5, or during movement of recently irradiated fuel assemblies in the secondary containment. LCO 3.8.2 requires one offsite circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems -

Shutdown," and one diesel generator (DG) capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8.

According to LCO 3.0.9 and SR 3.0.5, LCOs and SRs, respectively, are applied individually to each unit at a dual-unit site, such that the operating mode of one unit does not affect the application of the TS to the opposite unit. Therefore, the TS 3.8.1 SRs that are currently required to be met by SR 3.8.2.1 when a unit is in the mode of applicability of SR 3.8.2 are independent of the opposite unit's mode. The applicability of these SRs under the current Quad Cities SR 3.8.2.1 wording (prior to adoption of TSTF-582) is summarized in Table 3A-1.

Table 3A-1 Quad Cities TS 3.8.1 SRs Required by Current SR 3.8.2.1 SR Unit One (Shutdown) Unit Two (Shutdown) 3.8 .1.1 Applicable (offsite circuit) Applicable (offsite circuit) 3.8.1.2 Applicable* Applicable**

3.8.1.3 Applicable* Applicable**

3.8.1.4 Applicable* Applicable**

3.8 .1.5 Applicable* Applicable**

3.8.1.6 Applicable* Applicable**

3.8 .1.7 Applicable* Applicable**

3.8.1.8 Applicable* Applicable**

3.8 .1.9 Not Applicable Not Applicable 3.8.1 .10 Applicable* Applicable**

3.8.1 .11 Applicable* Applicable**

3.8.1 .12 Applicable* Applicable**

3.8.1 .13 Not Applicable Not Applicable 3.8.1 .14 Applicable* Applicable**

3.8.1 .15 Applicable* Applicable**

3.8.1 .16 Applicable* Applicable**

3.8.1.17 Applicable* Applicable**

3.8.1 .18 Applicable* Applicable**

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ATTACHMENT 1 Response to Request for Additional Information SR Unit One (Shutdown) Unit Two (Shutdown) 3.8.1 .19 Not Applicable Not Applicable 3.8.1 .20 Not Applicable Not Applicable 3.8.1.21 Not Applicable Not Applicable

For Unit One, the required DG will be either the Unit 1 DG or the Unit 1/2 (shared) DG.

- For Unit Two, the required DG will be either the Unit 2 DG or the Unit 1/2 (shared) DG.

LCOs 3.6.4.3, 3.7.4, and 3.7.5 are not applicable to a unit that is in mode 4 or 5 unless recently irradiated fuel is being moved in the shared secondary containment. These LCO's, when applicable, require equipment to be operable that is powered by both the same unit and the opposite unit's AC distribution subsystem(s). For equipment powered by the same unit (e.g., for Unit 1, 1/2B Standby Gas Treatment (SBGT), Control Room Emergency Ventilation (CREV),

and Control Room Emergency Ventilation Air Conditioning (CREV-AC)), the AC Sources required by LCO 3.8.2 support the associated equipment, with applicable SRs specified in the table above. For equipment powered by the opposite unit (e.g ., for Unit 1, 1/2A SBGT), the required opposite unit distribution subsystems are required to be operable by LCO 3.8.8; however, no corresponding opposite unit requirement exists under LCO 3.8.2 for AC Sources.

This is supported by the current bases of LCO 3.8.2 state that:

"In general, when the unit is shutdown the Technical Specification requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or loss of all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in modes 1, 2, and 3 have no specific analyses in modes 4 and 5. Worst case bounding events are deemed not credible in modes 4 and 5 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and corresponding stresses result in the probabilities of occurrences significantly reduced or eliminated, and minimal consequences . These deviations from OBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems."

Therefore, under current Quad Cities TS the applicable SR's of LCO 3.8.1 that are specified to be met under SR 3.8.2 .1 for the AC sources required to be operable by LCO 3.8.2 are those listed in the table above, even if movement of recently irradiated fuel in secondary containment is causing the shutdown unit to be in the mode of applicability of LCOs 3.6.4.3, 3.7.4, and 3.7.5. Adequate power to support the operability of required opposite unit equipment is assured by LCO 3.8.8.

For any operating unit, even if the opposite unit is shutdown, all SR's of LCO 3.8.1 apply to the AC sources required to be operable, which will include one qualified circuit between the offsite transmission network and the opposite unit's onsite Class 1E AC Electrical Power Distribution System and the opposite unit DG capable of supporting LCOs 3.6.4 .3, 3.7.4, and 3.7.5.

Page 20

ATTACHMENT 1 Response to Request for Additional Information Part B Since no changes have been proposed for SR 3.8.1.21, any opposite unit AC sources required by a unit operating in mode 1, 2, or 3 will continue to be subject to the existing set of SRs to establish operability. For multi-unit sites with shared AC distribution systems and sources, the same AC Source (e.g. , a unit or shared DG) may be required for each Unit by different LCOs (e.g. , LCO 3.8.1 or LCO 3.8.2); however, the basis for the equipment being required to be operable is different for an operating unit versus a shutdown unit. Since the operating unit must still have the capability to mitigate the effects of Design Basis Accidents (OBA) analyzed for operating conditions (e.g. OBA Loss of Coolant Accident), all of the requirements associated with DG automatic start in response to ECCS or LOOP signals, time to achieve rated voltage and frequency, and load sequencing continue to be required. Thus, no changes to SR 3.8.1 .21 are appropriate or proposed .

As described in the Safety Evaluation for TSTF-582 (Reference 1) and supported by the LOP Variation model Safety Evaluation (Reference 2), the DGs supporting a shutdown unit (operating in mode 4, 5, or during movement of recently irradiated fuel in secondary containment) may be manually started and loaded in response to a Reactor Pressure Vessel (RPV) draining event. Furthermore, the essential consideration for the events assessed in Reference 1, namely that the FHA does not assume a LOOP and that the minimum Drain Time permitted for any duration by LCO 3.5.2 is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , are consistent with the Quad Cities licensing basis. The ability of each required DG to support the required loads via manual start and loading continues to be demonstrated by the SRs that are retained under the proposed revision to SR 3.8.2.1. Additionally, for the Fuel Handling Accident, no credit in the analysis is taken for the operation of SBGT, GREV, or GREV-AC (Reference 4 ). Equipment required by LCOs 3.6.4.3, 3.7.4, and 3.7.5 will continue to be supported by operable distribution subsystems specified by LCO 3.8.8. The Quad Cities licensing basis does not include any additional events requiring automatic start of DGs for a shutdown unit that have not already been considered in the safety evaluation for TSTF-582 (i.e. , Fuel Handling Accident, draining event in mode 4 or 5).

The proposed LAR does not affect which AC sources will be required via LCO 3.8.2 to support the distribution systems required operable via LCO 3.8.8, but only revises the applicable SRs that are required to consider a DG operable for LCO 3.8.2 (though additional SRs may apply to the same DG and its associated start logic if required by an operating unit via SR 3.8.1.21 ).

Based on the above considerations, justification for deletion of each proposed SR of LCO 3.8.1 from the list of SRs required by the DG(s) required to be operable by LCO 3.8.2 is provided:

SR 3.8.1.8 This surveillance verifies the DG ability to achieve required voltage and frequency within 13 seconds. The 13 second timeframe is not required to support manual start of the DG in response to the postulated events in mode 4 or 5, and the ability of the DG to be manually started and loaded continues to be demonstrated by SR 3.8.1.2. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21 . This SR is equivalent to SR 3.8.1.7 from NUREG-1433 Revision 4, with the exception that the Quad Cities SR includes a note allowing the performance of this test for the common DG to satisfy this SR for both Units. This SR is assessed for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 2.

SR 3.8.1 .12 Page 21

ATTACHMENT 1 Response to Request for Additional Information This surveillance verifies, in part, the automatic start and loading of a DG on a LOOP signal. As previously discussed, response to the postulated events in mode 4 and 5 does not require automatic start and loading of a DG. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21 . This SR is equivalent to SR 3.8.1 .11 from NUREG-1433 Revision 4, with the exception that Quad Cities does not include the verification of auto-connected loads through a load sequencer (as the Quad Cities design does not have this feature). This SR is approved for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 1.

SR 3.8.1 .14 This surveillance verifies that the required DG's noncritical automatic trips are bypassed on an actual or simulated loss of voltage signal on the emergency bus concurrent with an actual or simulated ECCS initiation signal. Since the requirement for operable ECCS initiation signals is proposed for removal from LCO 3.3.5.2, removal of this surveillance from the list of those surveillances required for a DG supporting LCO 3.8.2 establishes consistency. Consistent with the assessment provided in Section 3.6 of Reference 1, LCO 3.8.2 and LCO 3.5.2 will, upon an actual LOOP, continue to require the restoration of an RPV injection source capable of operating without offsite power within a timeframe adequate for responding to a vessel draining event. If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1.21. This SR is equivalent to SR 3.8.1.13 from NUREG-1433 Revision 4. This SR is approved for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 1.

SR 3.8.1.16 This surveillance demonstrates that the DG can restart from a hot condition, such as subsequent to shutdown from normal surveillances, and achieve the required voltage and frequency within 13 seconds. The 13 second timeframe is not required to support manual start of the DG in response to the postulated events in mode 4 or 5, and the ability of the DG to be manually started and loaded continues to be demonstrated by SR 3.8.1.2 . If an operating unit requires the same DG to be operable, this surveillance will continue to be applicable for the operating unit via SR 3.8.1 .21. This SR is equivalent to SR 3.8.1 .15 from NUREG-1433 Revision 4, with the exception that the Quad Cities SR includes a note allowing the performance of this test for the common DG to satisfy this SR for both Units. This SR is assessed for deletion from the NUREG-1433 STS SR 3.8.2.1 in Reference 2.

SR 3.8.1 .18 This surveillance verifies the interval between each sequenced load block is <::90% of the design interval for each load sequence time delay relay. This logic is associated with automatic start and loading of an EOG in response to an ECCS initiation signal concurrent with a LOOP. Since the requirement for operable ECCS initiation signals is proposed for removal from LCO 3.3.5.2, removal of this surveillance from the list of those surveillances required a DG supporting LCO 3.8.2 establishes consistency. Manual loading of the DG will continue to be able to be performed by licensed operators in response to the postulated events in mode 4 and 5 or during movement of recently irradiated fuel in secondary containment. This SR is equivalent to SR 3.8.1 .18 from NUREG-1433 Revision 4. This SR is assessed for deletion from the Page 22

ATTACHMENT 1 Response to Request for Additional Information NUREG-1433 STS SR 3.8.2.1 in Reference 2.

SR 3.8.1 .7 This SR was inadvertently removed from the list of SRs required to be performed under SR 3.8.2.1 and will be retained . Attachment 4 provides the corrected markup of SR 3.8.2.1. will replace in its entirety Attachment 2.4 of the original submittal. However, the only change to the markup is the correction to SR 3.8.2.1 on Page 3.8.2-5.

Part C As discussed in the responses to Parts A and B, no changes are required for SR 3.8.1.21, as this SR continues to specify the appropriate criteria for operability of an opposite unit AC Source that is required by a unit operating in modes 1, 2, or 3.

Part D As described in Part B, the DGs supporting a shutdown unit (operating in mode 4, 5, or during movement of recently irradiated fuel in secondary containment) may be manually started and loaded in response to a Reactor Pressure Vessel (RPV) draining event.

TSTF-582 did not include all the TS changes needed to reflect that TS 3.8.2 does not require automatic start and loading of a DG within 13 seconds on an ECCS initiation signal or LOOP signal. TSTF-583-T addressed these additional changes, which included the revision of the Applicability of LCO 3.3.8.1 to remove the currently specified condition "When the associated diesel generator as required to be OPERABLE by LCO 3.8.2, 'AC Sources - Shutdown."'

TS 3.3.8.1, "Loss of Power (LOP) Instrumentation," is currently applicable in modes 1, 2, and 3, and when the associated DG is required to be operable by TS 3.8.2. Implementation of TSTF-582 revises TS 3.8.2 to no longer require automatic start and loading of a DG on a LOOP signal. Consequently, the instrumentation that generates the LOOP signal should not be required to be operable when the DG is required to be operable by TS 3.8.2. As a result, the deletion of the condition related to TS 3.8.2 in the applicability of LCO 3.3.8.1 is appropriate .

Page 23

ATTACHMENT 1 Response to Request for Additional Information RAI 4 (LaSalle)

LaSalle SR 3.5.2.6 currently requires the licensee to: "Operate the required ECCS injection/spray subsystem through the recirculation line for~ 10 minutes." Adoption of TSTF-582 should revise SR 3.5.2.6 by adding two notes and deleting "through the recirculation line."

However, the markup of SR 3.5.2.6 in the LAR only adds the two notes.

Confirm that "through the recirculation line" is to be deleted from LaSalle SR 3.5.2.6 or provide justification for not making this change.

LaSalle SR 3.5.2.6 currently requires the licensee to : "Operate the required ECCS injection/spray subsystem through the recirculation line for~ 10 minutes." Adoption of TSTF-582 should revise SR 3.5.2 .6 by adding two notes and deleting "through the recirculation line."

However, the markup of SR 3.5.2.6 in the LAR only adds the two notes.

Confirm that "through the recirculation line" is to be deleted from LaSalle SR 3.5.2.6 or provide justification for not making this change.

Page 24

ATTACHMENT 1 Response to Request for Additional Information Response to RAI 4 (LaSalle):

The originally submitted mark-up for LaSalle SR 3.5.2.6 incorrectly omitted the markup for the deletion of the phrase "through the recirculation line" as shown in TSTF-582. A corrected mark-up of TS page 3.5.2-5 is included in Attachment 3 to this letter. Attachment 3 supersedes .3 of the original submittal.

Page 25

ATTACHMENT 1 Response to Request for Additional Information REFERENCES

1. Letter from Victor G. Cusumano (U.S . NRC) to Technical Specification Task Force, "Final Safety Evaluation of Technical Specification Task Force Traveler TSTF-582, Revision 0, 'RPV WIC Enhancements' Using the Consolidated Line Item Improvement Process (EPID L-2019-PMP-0199)," dated August 13, 2020 (ML20219A317)

2. Letter from Victor G. Cusumano (U.S . NRC) to Technical Specification Task Force, "model Safety Evaluation of Technical Specification Task Force Traveler TSTF-582, Revision 0, 'RPV WIC Enhancements' and TSTF-583-T, Revision 0, 'TSTF-582 Diesel Generator Variation ,' Using the Consolidated Line Item Improvement Process," dated October 9, 2020

3. Dresden UFSAR Section 15.7.

4. Quad Cities UFSAR Section 15.7.

Page 26

ATTACHMENT 2 Markup of Proposed Technical Specifications Pages Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-4 3.3.5.2-1 3.3.5.2-2 3.3.5.2-3 3.3.8.1-1 3.6.1.3-5 3.8.2-3

Definitions

1. 1 1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e . § ., seismic eveAt ,

l oss of Aorrna l po *.1er , siA§le hbtrnaA error) ,

for all penetration flow paths below the TAF except:

Penetration flow paths connected to an closed and intact closed system, or isolated by administratively controlled manual or automatic valves that are l ocke9 , sea l e9 , or other **i se seCb1re8 in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration fl ow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

(continued)

Dresden 2 and 3 1.1-4 Amendment No. 266/259

RPV Water I nventory Contro l I nstrumentation

3. 3. 5. 2 3.3 I NS TRUMENTATION 3.3 . 5.2 Reactor Pressure Vesse l (RPV) Water I nventory Control I nstrumentation LCO 3.3.5.2 The RPV Water Inventory Contro l instrumentation for each Funct i on in Table 3.3.5.2-1 sha l l be OP ERABLE.

AP PLI CAB ILIT Y: According to Tab l e 3.3.5.2-1.

ACTIONS

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

Separate Cond i tion entry is al lowed for each channe l .

CON DIT ION REQU I RED AC TI ON COM PLE TI ON TI ME A.- GAe OF Arn Fe GAflAAe~ s A--.+/-- E:A teF tl:le 6oA9itioA I11m1e9i ete~ J' iAOFJeFaB~e . Fef:eFeAGe9 i A

+a t:i~e J . J . a . ~ 1 f:OF tRe GAaAAe~ .

A.1 I

\¥

.g.._ As BJ' .g....,..+ I nitiate act i on to Immediately

\

Fe~tJiFe9 Re~tJi Fe9 AGtiOA A. 1 place channe l in a Ag Fef:eFeAGe9 i A trip .

+at:i ~e J . J . a . ~ 1.

OR IA.2.1 I it Dec l are associated Immediately A.On e or more channels ~

in ope rable. penetration fl ow path(s) incapable of automatic iso l ation.

A~

B.2 . 2 I nitiate action to Immediately ca l cu l ate DRAIN TIM E.

6 . As Fe~tJi Fe9 gJ1 b----.----+/-- i:n aGe GAaAAe~ i A tFiFJ . 1 AOLiF Re~tJiFe9 AGtioA A. 1 fJA9 Fef:eFeAGe9 i A

+at:i~e J . J . a . 2 1.

(cont i nued)

Dresden 2 and 3 3.3 . 5. 2-1 Amendment No . 2§g/2§1

RPV Water I nventory Contro l I nstrumentation

3. 3. 5. 2 ACTIONS COND IT ION REQUIRED ACTION COMP LETI ON TI ME Q. As FeEjtii reEI B:J' .IJ-.--+/-. Restere GRannel te 24 R8blFS ReEjti ire El AGtien A. 1 OPrnAgLE stattis .

a nEI ref:erenGeEI in

+:a8le ~ . ~ . 9 . 2 1.

E. ReEjti ire El AGtien a nEI -h IJeGlare asseGiateEI l ei,1 +/-mmeEli atel:J' asseGiateEI 6emf)letien flFesstire E66£

+:ime ef: 6enElitien 6 8F i naeGti en,LSfJFa:J' Q net met. SblBS:J' Stem inef)eFa8le .

SURV EILL ANCE REQUIR EMENTS

~These SRs apply to each Function in I

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

Ref:er te Tab l e 3.3.5.2-1 te Eletermine 11RiGR £Rs af)fllY f:er eaGR E66£ ~tinGtien .

SURVEI LLANC E FR EQUENCY SR 3 . 3.5 . 2. 1 Perform CHANNE L CHECK . In accordance with the Survei l lance Frequency Contro l Program SR 3 . 3 . 5.2.2 Perform CHANNE L FUNC TI ONAL TE ST. I n accordance wi t h the Survei l lance Frequency Contro l Program Dresden 2 and 3 3.3 . 5. 2-2 Amendment No . 268/261

RPV Water I nventory Contro l I nstrumentation

3. 3. 5. 2 Table 3 . 3 . 5 . 2-1 (Page 1 of lJ RPV Water Inventory Control Instrumentation APPLICABLE bGNl:llTIGMS MODES R>*rnrnGrn OR OTHER REQUIRED ~

SPECIFIED CHANNELS PER R>Q " IRrn SllR" U bb ' MG> ALLOWABLE FUNCTIO N CONDITIONS FUNCTION ' bTIG~I 0

.1 R>Ql lIR>MDIH VALUE

~ ReaGter Steam Geme ~ L~ . 9 . 2 . 2 ,,; ;J41.7 ~sig Press~re be11 (Permissi,,e)

B-. Gere S~ray P61m~ ~ ~ :i . :i . 8 . 2 . 2 G i s>:~arge

l e" be11 ~ 1 1m~ (al rn) ~a66 l

,..___ be11 Prsss *1rs Geel a Rt IRjeGtieR (bPG I ) Systsm

~ ReaGter Steam Geme ~ ;J.:J.9.2.2 ,,; ;J41.7 ~sig Prsss~re be11 (Psrmissi,,e) be1 I Press 11re Geel a Rt

{)... 4-,----4 ~ ~ ;i . ;i . 9. 2. 2 llG? g~m IRjeGtieR P11m~ lee~ ( 3)

GiSGRarge

1e1 I be11

~

rny~ass)

~ Shutdown Cooling System (SOC) Isolation a . Reactor Vessel Water

~ ( {} ) per trip ~ ;i . ;i . 9. 2. i ~ 2 . 65 inches Level-Low system ~ ;i . ;i . 9. 2. 2

~ 4-. Reactor Water Cleanup System Isolation

a. Reactor Vessel Water

~ ( {} ) per trip ~ ;i . ;i . 9. 2. 1 ~ 2 . 65 inches Level-Low system ~ ;i . ;i . 9. 2. 2 0

sseGiate9 " itR aR .:u:s s~9system re~~ireEJ te 9e GP>R ' H> 9y u:G :l . 9 . 2 , " RP " 'later IR"eRtery (;eRtrel ."

When automatic i solation of the associated pene t ration flow path(sJ is credited in calculat i ng DRAIN TIME .

Dre sden 2 and 3 3 .3 . 5 . 2-3 Amendment No . 256 / 249

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1 -1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3,

'1Jf1 e A

~

Hie assoc i ate El Eli es e l § e A et at o I" i s I" e q 1:.d I" e El to 13 e OPERABLE B)' LCO 3. 8 . 2, " AC Sotll"ces SFiutElo 'vJA ."

ACTIONS

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

Separate Condition entry is all owed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. trip.

B. Required Action and B.1 Declare associated Immediately associated Completion diesel generator (DG)

Time not met. inoperable.

Dresden 2 and 3 3.3.8.1-1 Amendment No. 185/180

PC I Vs 3 . 6 .1. 3 AC TIONS CON DIT ION REQUIR ED AC TIO N COM PLETI ON TI ME

c. (con t inued) C. 2 - - - - - - - -NO TE S- - - - - - - -

1. I so l ation devices in hi gh rad i ation areas may be veri f ied by use of adm i ni strative means.

2. I so l ation devices t hat a re a l ocked, sea l ed, or otherwise secured may be verified by use of ad mi nistrative means .

Ver i fy the affected Once per 31 days penetrat i on fl ow path is i so l ated.

D. MS I V lea kage ra t e D. 1 Restore leakage ra t e 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months not wit hin l im it. to wit hin l i mit .

E. Requ i red Ac ti on and E. 1 Be i n MOD E 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months assoc i ated Comp l et i on Ti me of Cond iti on A, AND B' C, or D no t met ..:i-A-MQg~

+/-' 2 ' 8F d . E. 2 Be i n MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Dresden 2 and 3 3 . 6.1.3-5 Amendment No . 256 / 249

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.1 Suspend CORE Immediatel y inoperable. ALTERATIONS.

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

B.3 Initiate action to Immediatel y restore required DG to OPERABLE status.

SR 3.8.1.3, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.15, and SR 3.8.1 .17.

SURVEILLANCE REQUIREMENTS FREQUENCY

-+

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

The followi g SRs are not required to performed: r~~r.--...+-.--T.---2M+--'7-.e-.--:r--.--:+/-:-1::1----t-tt-H::H:ttl-ft t

~R 2 . g . 1 . 12 , ane ~R 2 . g . 1 . 14 thro~gh

~R 2 . g . i. rn .

The following SRs i------+ ~ AC sources required to be OPERABLE In accordance are applicable for ~Rs of ~pecification 2 . g . 1 , except with applicable

~R 2 . g . 1 . 9 , ~R 2 . g . 1 . 12 , ~R 2 . g . 1 . 19 , SRs

~R 2 . g . 1 . 20 , ane ~R 2 . g . 1 . 21 are applica8 l e .

SR 3.8.1.1 SR 3.8.1.7 SR 3.8.1.2 SR 3.8.1.10 SR 3.8.1.3 SR 3.8.1.11 SR 3.8.1.4 SR 3.8.1.15 SR 3.8.1.5 SR 3.8.1.17 SR 3.8.1.6 Dre sden 2 and 3 3 .8.2-3 Amendment No. 26g/26 1

ATTACHMENT 3 Markup of Proposed Technical Specifications Pages LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-4 3.3.5.2-1 3.3.5.2-2 3.3.5.2-3 3.3.5.2-4 3.3.6.1-4 3.3.8.1-1 3.5.1-1 3.5.1-2 3.5.2-2 3.5.2-3 3.5.2-5 3.8.2-4

Definitions

1. 1 1.1 Definitions DOSE EQUIVALENT I-131 30, Supplement to Part 1, pages 192-212, Table (continued) titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the l imiting drain rate;

b. The lim i ting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the dra i n rates through multiple penetration flow paths susceptible to a common mode failu re (e . g ., seismic event , loss of normal

~0 .1er , single ~u1man error) , for all 1

penet rat ion flow paths below the TAF except:

1. Penetration flow paths connected to an closed and administratively intact closed system, or isolated by manual or automatic valves that are controlled l ocked , sea l ed , or 0H1ernise seCblred in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or (continued)

LaSalle 1 and 2 1.1-4 Amendment No. 242/228

RPV Water Inventory Control Instrumentation -+-

3. 3. 5. 2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

A.1 Initiate action to place

- channel in trip.

ACTIONS OR

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

Separate Condition entry is a lowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME I

-A-o- 0Ae or more cAaAAels EAter tAe CoAElitioA Imme Eli a tel :Y iAoperable . referCAced i A Taele 3. 3. 5. 2 1 for A. One or more tAe cAaAAel . \!Immediately I

-channels

- -r+----i IV inoperable. '+'

-&-;- As reEJt:li reEl by Declare associated Immediately ReEjuireEl ActioA A. 1 penetration flow aAEl refereAceEl iA path(s) incapable of Taele 3. 3 . 5. 2 1. automatic isolation.

( ~A N~

IQ-/ ,. r Initiate action to calculate Calculate DRAIN TIME.

IA.2.2:t---.~B-: Immediately C. As reEJui red by Place cAaAAel iA trip . 1 ROUP ReEjui r eEl ActioA A. 1 aAEl refereAceEl iA Table 3 . 3 . S. 2 1.

(continued)

LaSalle 1 and 2 3.3.5.2-1 Amendment No. 230/216

RPV Water In ventory Control In strumentation ~

3.3 .5 .2 AC TION S (continued)

CONDITION REQUIRED AC TIO N COMPLETION TIME B. ,ais FeEf td Fee B:Y B-:-+ Res=!:sFe eFiaAAel =!:s 24 AS~FS ReEf~i Fee ,o,e=t:i SA A . 1 OPERABLE s=!:a=!:~s .

a AEl Fefe FeAeeEl i A

=Fasl e 3 . 3 . 5 . 2 1.

E. ReEJ~i Fee P.c=!:i SA a AS f-:-1. Beel a Fe asssci a=!:ee Ifflffleei a=!:el y asssei a=!:ee EGGS i Aj ee=!:i SA 1ls13 Fa :y Gsfflp le=!: i SA =Fiffle sf s~ssys=!:effl iAspeFasle .

GsAElHi SA G SF B AS=!:

m-e+-:-

These SRs apply to each Function in SUR VEILL ANCE REQUIREMENTS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NO TE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

RefeF =!:s Table 3.3.5.2-1 =!:s Ele=!:eFffliAe WAiCA SRs apply fsF eacFI EGGS F~Ac=!:isA .

SURVEI LLANC E FREQUENCY SR 3.3.5.2. 1 Perform CHANN EL CHE CK. I n accordance wi th the Surve i 11 ance Frequency Control Program SR 3.3.5.2.2 Perform CHANNE L FUNCTIONAL TEST. In accordance with the Surveil l ance Frequency Control Program LaSal l e 1 and 2 3.3.5.2-2 Amendmen t No. 230/216

RPV Water I nventor y Control I ns trumentation + -

+

3 . 3 . 5. 2 Table 3. 3. 5. 2- 1 (page 1 of 2)

RPV Water Inve nt ory Control Instrume nt atio n

= = = = = =

APP LI CABLE G8Pl8 IT I8N S MOD ES OR REQU IR ED REFERDIGEB OTHER CHANNE LS -F-R8!4 SPECIFIED PER RE81:1 I RE8 Sl:IRVEI LLMIGE AL LOWABLE FUNCTION CO NDIT IONS FUNCTION AGTI8PI A. l RE81:1 I REMUITS VAL UE h Le .. PFessriFe Gee l aAt IAjeetieA A (LPG!)

aA8 Le .. PFessriFe GeFe S19Fa) ( LPGSJ Sri13s; stems

..r.- ReaeteF Steam .£tf 3. 3. 5. 2. 2 ~ ~

Beme PFessriFe Le ..

(!Ajeeti BA PeFmissi oe)

-&-:- LPGS Prim19 ~ ~ .£tf 3 .3. 5. 2. 2 ~ §I'm a AS Bi sei'1aF§Je ~..+ < 1835 §J l3m Fle .. Le .. (B;13ass)

--:- LPGI Prim13 A ~ ~ .£tf 3 .3. 5. 2. 2 ~ §Jl3m a AS Bi sei'1aF§Je ~..+ < 2111 §I'm Fl s .. Ls .. (B) 13a ss l 4-:- LPGS aA8 LPGI ,', ~ ~ .£tf 3 .3. 5. 2. 2 ~~

lAjeetieA LiAe ~..+

PFessriFe Ls ..

(lAjeetieA PeFmissioe)

~ LPGI B aA8 LPGI G Sri8s) stems

..r.- ReaeteF Steam .£tf 3. 3. 5. 2. 2 ~ ~

Bsme PFessriFe Ls ..

(lAjeetieA PeFmissi.el

-&-:- LPG! Prim13 B .£tf 3.3. 5.2.2 ~ §Jl3m aAS aA8 LPGI Prim13 G < 2111 §I'm Bisei'1aF§Je Fle .. Le .. (B)13ass)

--:- LPG! B aA8 LPG! G .£tf 3.3. 5.2.2 ~ ~

lAjeetisA LiAe PFessriFe Le ..

(lAjeetieA PeFmissi.el (contin ued)

+a-+ Asseeiates .. itR aA EGGS sril3s;stem FeEfriiFe8 te 13e 8PERABLE 13; LG8 3 . 5 . 2 , " RPV ', /ateF !AoeAtef)

GeAtFel . "

LaSal l e 1 and 2 3 . 3 .5.2-3 Amendmen t No. 230/216

RPV Water In ventory Control In strumentation ~

3.3 .5 .2 Table 3 . 3.5.2-1 (page 2 of 2)

RPV Water Inventory Control Instrumentation APPLICABLE co~rn IT ID~Js MODES OR REQUIRED REFERDJCEB OTHER CHANNELS -F-OOM SPECIFIED PER REGl:IIREB Sl:IRVEI LLMICE ALLOWAB LE FUNCTION CONDITIONS FUNCTION ACTION A. 1 RE81:1IREMEMTS VALUE

- Iii §A PFesstJFe Cs Fe S13Fa) ( llPCSl S)steFA 13-7 l l PGS PtlFA/3 ~ 3. 3. 5. 2. 2 > 113 . 2 13si§ Bi seAaF§e PFeSStJFe Iii §A rnnass)

-&-:- l l PCS S) steFA Fl e" ~ 3. 3 . 5. 2. 2 ~~

Rate Le .. (8)13ass) -a-A4

< 219~ §/3FA

[]

~ 4-:- RHR Shutdown Coo li ng Syste m Isolation

a. Reactor Vessel ( !> )

2 in one ~ 3. 3. 5. 2. 1 ;:: 11. 0 Water Leve l - Low, trip ~ 3. 3. 5. 2. 2 inches Level 3 system

~,,.,. Reoctoc Wotec Cleooop (RWC UJ System I solation

a. Reactor Vessel

~ ( !> )

2 in one ~ 3.3. 5.2.2 ;:: - 58. 0 Water Leve l - Low trip inches Low, Level 2 system

+a-+ AssseiateEI .. itfl aA EGGS StlBS)SteFA FetjtJiFeE1 ts 13e OPE 11ABL E B) LCO 3 . 5 . 2 , " IWV '.later lAoeAtSF)

CsAtFe l ."

~) When automatic isolation of the associated penetration f l ow path(s) i s credited in calculat in g DRAIN TIME.

LaSal le 1 and 2 3.3.5.2-4 Amendmen t No. 230 / 2 16

Prima ry Containment I sol ation In strumentation 3 . 3 .6.1 ACT IO NS CON DIT ION REQUIRED ACT IO N CO MPL ET IO N TI ME J. As requ i red by Re qui re d J .l Init i ate action to Immed i at el y Act i on C.l and referenced restore cha nne l to i n Ta bl e 3. 3. 6.1-1. OP ERAB LE st at us .

I Ait i ate aetieA ts IF!HtteEl i a te l )

i se l ate Hie Resi E1 1:1a l li e at Remeva l (R llR ) Sl91:1 tE1e .. A Cee li A§ (S BC) S)ste m.

SURVEI LLANCE REQU I RE ME NTS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOT ES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1. Refer to Tab l e 3 . 3.6 . 1- 1 to deter mi ne whi ch SRs ap pl y for eac h Pr imary Contai nme nt Isolat i on Fu nction.

2. Whe n a chan nel is pl aced in an i noperable sta t us so l ely for pe r for mance of requi red Survei l lances , entry in to assoc i ate d Con diti ons and Re qui re d Ac ti ons may be de l ayed f or up to 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s provi ded t he assoc i at ed Fun ct i on mainta i ns isolation capa bi l i ty .

SURVEI LLANCE FR EQ UEN CY SR 3. 3.6 . 1. 1 Perfor m CHANNEL CHE CK . I n accorda nce wit h t he Sur veil l ance Freq uency Co ntrol Progra m

+

SR 3. 3.6 . 1.2 Perfor m CHANNEL FUN CTIO NAL TES T. In accordance wit h th e Survei l lance Fre que ncy Con t ro l Program (cont i nued)

LaSalle 1 and 2 3 . 3 .6.1-4 Amendment No. 200 / 187

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1 -1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3..., ~

'1Jf1eA Hie associatee eiese l §eAerator (DC) is re~uiree to be OP CRABLE by LCO 3. 8 . 2, "AG Sources Sl'l uteo *,m ."

ACTIONS

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

Separate Condition entry is all owed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channe l in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. trip.

B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.

Time not met.

LaSalle 1 and 2 3.3.8.1-1 Amendment No. H 7/133

ECCS-Operating

3. 5. 1 3.5 EMERGENCY CORE COOLING SYSTEMS CECCS), REACTOR PRESSURE VESSEL CRPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING CRCIC)

SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure ~ 150 psig.

High Pressure Core Spray (HPCS)

ACTIONS

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

LCO 3.0.4.b is not applicable to H-P-G-& .

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A. 1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE status.

(continued)

LaSalle 1 and 2 3.5.1-1 Amendment No. 230 / 216

ECCS-Operating

3. 5. 1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. l ligfi PresstH' e Core B.1 Verify by Immediately S~ray ( HPCS+ System administrative means inoperable. RCIC System is OPERABLE when RCIC is required to be OPERABLE.

B.2 Restore HPCS System 14 days to OPERABLE status.

C. Two low pressure ECCS C.1 Restore one low 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months injection/spray pressure ECCS subsystems inoperable. injection/spray subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, or C not met.

E. One required ADS valve E.1 Restore required ADS 14 days inoperable. valve to OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition E not met.

(continued)

LaSalle 1 and 2 3.5.1-2 Amendment No. 196/183

RPV Water Inventory Control .+----

3. 5. 2 ACTIONS (continued)

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

- I CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

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

-i(SGT)I C.3 Verify one sta y 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment /

subsystem is capable of being placed in operation in less than the DRAIN TIME.

(continued)

LaSalle 1 and 2 3.5.2-2 Amendment No. 230 / 216

RPV Water In ventory Control ..+--

3 .5 .2 AC TION S (continued)

COND ITION REQUIRED AC TION COMP LETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 - - - - - - -NOTE- - - - - - - -

Required ECCS injection/spray subsystem or additional method of water injection sh a 11 be capab le of operating without off site electrical power.

Initiate action to Immediately establish an additional method of water inj ect i on wit h water sources capab l e of maintaining RPV water l eve l > TAF for

'.'. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initi ate action to Immediately establish secondary conta inment boundary.

AND D. 3 Initiate action to Immediately isolate each

!automatically or }-----____ secondary containment

penetration flow path r---__ , or verify it can be I ~ manually isolated from the control room.

D.4 Initi ate a~

verify one staA~~Y Immediately

§as treatmCAt subsystem is capable of being placed in operat i on.

(cont in ued)

LaSal le 1 and 2 3.5.2 -3 Amendmen t No. 230/216

NOTES

1. Operation may be through the test return line.

2. Credit may be taken for normal system RPV Water In ventory Control operation to satisfy this SR. 3 .5 .2 SURV EILL ANC E 0 EQUIREMENTS (cont inu ed)

SURVE ILLANC E FREQUEN CY

-&ff 3. 5. 2. 5 -

'"ITC

~

-I---

p~ 8t PeEjtd PeEI t8 ee lflet f e P S:'J'Stelfl ~'eAt f 1 8111' i:iaHis ei:ieAeEI l::!ASeP aEllfli Ai s=l:Pa=ti 'i'e eeA=l:Pei .

\I e Pi f:,' , feP He PeEjl::!i PeEI EGGS i Aj ee=ti 8A1'SFJPa:'7' Sl::!B5:'7'5telfl , eaeA lfla Al::!a 1 ,

i:ie 1~e P ei:iePa=teEI , a AEI al::!telfla=tie 1 ~a 1 1 ~e i A He 1

f 1 8~1 13aH , Hat i 5 Aet ieel<eEI , seai eEI , 8P

+/-A aeeePdaAee 11~i t A He Sl::!P~'ei 11 aAee

~PeEfl::!eAE:'7'

+-

eHe P~vi se seel::!PeEI i A 13esitieA , i 5 i A He Ge At Pei PPe§Palfl eePPeet i:iesitieA .

t

~

SR 3.5.2. Operate the required ECCS i njection/spray In accordance subsys tem tAP8l::!§A He Peei Pel::!i a=ti eA HAe for with the

~

~ 10 minutes. Survei 11 ance Frequ ency Control Program SR 3 .5. 2 . Verify each valve credited for automatically In accordance isolating a penetration fl ow path actuates with the

~ to the isolation position on an actual or s imulat ed i so l at i on s ig nal.

Survei 11 ance Frequ ency Control Program SR 3.5.2 . .g - - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -

Vessel injection/spray may be excluded.

~ -------------------------------------------

Verify the required ECCS injection/spray In accordance s ubsystem can be manually operated. with the Survei 11 ance Frequency Control Program LaSal le 1 and 2 3.5.2 -5 Amendmen t No. 230/216

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required offsite D.1 Declare associated Immediately circuit or DG of LCO standby gas treatment Item d. inoperable. subsystem, control room area filtration subsystem, and control room area ventilation air conditioning subsystem inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 - - - - - - - - - - - - - - - - - - -NOTE-& - - - - - - - - - - - - - - - - - - -

+.:- The following SRs are not required to , SR 3.8.1.10, be performed: SR 3.8.1.3, SR 3.8.1.9 SR 3.8.1.14, and tAFS~§A SR 3 . 8 . 1 . 11 , SR 3 . 8 . 1 . 13 tAFS~§A SR 3.8.1.16, SR 3 . 8 . 1 . 18 , UftE!.

SR 3 . 8 . 1. 19 .

~ SR 3 . 8 . 1 . 12 aA8 SR 3 . 8 . 1 . 19 are As t Fe ~~i Fe G te Be ffi et .

The following SRs f.&r AC sources required to be OPERABLE, In accordance are applicable for SRs ef S13ee if ieatieA 3 . 8 . l , eJ(eqit with applicable SR 3 . 8 . 1 . 8 , SR 3 . 8 . 1 . 17 , aA8 SR 3 . 8 . 1 . 20 , SRs a Fe a1313l i casl e .

SR 3.8.1.1 SR 3.8.1 .6 SR 3.8.1.2 SR 3.8.1 .9 SR 3.8.1.3 SR 3.8.1 .10 SR 3.8.1.4 SR 3.8.1 .14 SR 3.8.1.5 SR 3.8.1 .16 LaSalle 1 and 2 3.8.2-4 Amendment No. 230 / 216

ATTACHMENT 4 Markup of Proposed Technical Specifications Pages Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-4 3.3.5.2-1 3.3.5.2-2 3.3.5.2-3 3.3.8.1-1 3.5.2-2 3.5.2-4 3.5.2-5 3.5.2-6 3.6.1.3-1 3.6.1.3-4 3.8.2-5

Definitions

1. 1 1.1 Definitions (continued)

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a. The water inventory above the TAF is divided by the limiting drain rate;

b. The limiting drain rate i s the larger of the drain rate through a s ingle penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e . g ., seismic eveRt ,

l oss of Rormeil poi,ier , siRgle hblmeiR error) ,

for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or i so lated by closed and administratively controlled manual or automat ic va l ves that are l ockeEi , seei l eEi , or otheni'i se secblreEi in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capab le of being isolated by valves that wi ll close automatically with out offsite power prior to the RPV water le vel being equal to the TAF when actuated by RPV water le ve l isolation instrumentation; or

3. Penetration flow paths with is olation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous commun ication with the control room, i s stat ioned at the controls, and is capable of closing the penetration flow path i solat ion device without offsite power.

(continued)

Quad Cities 1 and 2 1. 1-4 Amendment No. 279/274

RPV Water I nventory Control I nstrumentation 3.3 . 5.2 3.3 I NS TRUMENTATI ON 3 . 3 . 5.2 Reactor Pressure Vesse l (RPV) Water I nventory Contro l I nstrumentat i on LCO 3.3.5.2 The RPV Water Inventory Contro l instrumentat i on for each Funct i on in Table 3.3.5.2 - 1 shal l be OPERAB LE.

AP PLI CAB ILIT Y: According to Tab l e 3.3.5.2- 1 .

ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -NO TE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Separate Cond i tion entry is al lowed for each channel.

A.1 Initiate action to place channel in trip CON DIT ION OR COMP LETI ON TI ME

/Jr.. 0Ae 8P lfl8Pe cl9aAAel s A-:- EA:f:et" =E 19 e CeAE1it:ieA IlfllfleE1i at: el y i Ae13 n a 131 e . PefereAceE1 i A A. One or more Tas le 3 . 3 . 5. 2 1 fep rllmmediately I r channels inoperable.

.J He el9aAAel .

JV '4 B-:- As PeEjui PeE1 B:Y £-:-+ Dec l are assoc i ated Immediate l y ReEjui PeE1 ,01c=EieA A . 1 penetration fl ow a As Pe:fePeAces i A I A~.11 path(s) incapable of c

Ta sle 3 . 3 . 5. 2 1. automatic isolation.

~ f Initiate action to calculate IA.2.2 H ~ -B-ti- Cal cul a=Ee DRA I N TI ME. Immed i ate l y

c. As PeEjUi PCS B)' -:-+ Place CAaAAel i A fPij3 . 1 A8UP ReEjUiPeS Ac=EieA A. 1 a AE1 PefePeAeeE1 i A

i:a 81 e 3 . 3 . 5 . 2 1.

D. As PeEjUi PeE1 B)' ~ Resf:epe el9aAAel f; 0 2q A8UPS ReEjuiPe8 Act:ieA A. 1 OPERABLE st:a t:us .

a AE1 PefePeAeeE1 i A Tasle 3 . 3 . 5 . 2 1.

(continued) I Quad Ci t i es 1 and 2 3.3.5.2-1 Amendment No. 273/268

RPV Water I nventory Control I nstrumentation 3.3 . 5.2 ACTIONS COND IT ION REQUI RED ACTION COM PLE TI ON TIM E E. ReEjtl i FEEi Aet i sA a AEl f-:4. Deel a Fe assseiateEI l S\i' l A'IA'leEl i a tel y J assseiateEI GSA'if3 l et i SA f3FESSl:lFe EGGS /

f i ffie Sf GsAElitisA G SF i Ajeeti SA 11 s13 Fa:,*

D ASt ffiet . StlBS:)'Steffi i As13eFa l=Jl e .

rJThese SRs apply to each Function in I

SURV EILL ANC E REQ UIR EMENTS

-)

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

~ ef:eF ts Tab l e 3.3.5.2-1 ts EleteFA'liAe ld ~i e~ SRs a1313 l y f:sF eae~ EGGS FtlAetisA .

SURV EI LLANC E FREQU ENCY I

SR 3.3.5 . 2 . 1 Perform CHANNE L CHECK . In accordance with the Surve i 11ance

-)

Frequency Control Program ..

SR 3.3.5.2 . 2 Perform CHANNEL FUNCTIONAL TE ST. In accordance with the Survei 11ance Frequency Control Program Quad Ci t i es 1 and 2 3.3.5.2-2 Amendment No. 273/268

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3 . 3.5 . 2-1 (Page 1 of 1)

RPV Wat e r Inventory Control Instrumentatio n APPLICABLE G8~18 I TI 8N S MODES REFERUIGEB OR OTHER REQU I RED fiWM SPECIFIED CHANNELS PER RE88IRE9 S8R"EI LL ' NGE ALLOWABLE FUNCTIO N CONDITIONS FUNCTIO N AGT I 8N P . l RE88IREMENTS VAL UE h Ge Fe S13Fa; S; stelll tt7 Reaete1- Stealll Bellle 5-lt 3. 3 . 5. 2. 2 P1 esst:H'e Le (Pe:lllissi.el tr. GeFe S13Fa) P~lllf3 5-lt 3. 3 . 5. 2. 2 Bi SEAaF§e Fl e Ls (8)13assl b Le .. P1 ess~1 e Geel a19t IAjeetieA (LPG!) S;stelll tt7 ReaeteF Stealll Bellle 5-lt 3. 3 . 5. 2. 2 PFess~Fe Le ..

(PeFl!lissi el tr. Le Press~Fe GeelaAt +--!7tt 5-lt 3. 3 . 5. 2. 2 IAjeeti SA P~lllf3 le e13 (al Bi SEAaF§e Fl e Le (B;13assl RHR Shutdown Cooling System (SOC) Isolation

a. Reactor Vessel Water per trip 5-lt 3. 3 . 5. 2. 1 ~ 3. 8 inches Level-Low system 5-lt 3. 3 . 5. 2. 2

~ 4..,. Reactor Water Cleanup (RWCUJ System Isolatio n i

a. Reactor Vessel Water per trip 5-lt 3. 3 . 5. 2. l ~ 3. 8 inches Level-Low system 5-lt 3. 3 . 5. 2. 2

' sseeiateEI itA aA EGGS s~BS)Stelll Fe~~i FEEi te se 8PER ' BLE B) LG8 3 . 5 . 2 , " RP " llateF IA eAtSF) GeAtFel . "

When automatic isolation of the associated pene t ration flow path(s) is credited in calculating DRAIN TIME .

Quad Cities 1 and 2 3.3.5.2-3 Amendment No. 273 / 268

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1 -1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, WAeA tAe associated diesel geAerator is reqHired to be OPERABLE by LCO 3 . 8 . 2 , " AC SoHrces SAHtdmm ."

ACTIONS

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

Separate Condition entry is all owed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Place channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. trip.

B. Required Action and B.1 Declare associated Immediately associated Completion diesel generator (DG)

Time not met. inoperable.

Quad Cities 1 and 2 3.3.8.1-1 Amendment No. 199/195

RPV Water Inventory Control ~

3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME. ~(SGT) I C.3 Verify one sta / 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

(continued)

Quad Cities 1 and 2 3.5.2-2 Amendment No. 273 / 268

RPV Water Inventory Control t 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.3 Initiate action to Immediately isolate each secondary containment penetration flow path or verify it can be

!automatically or f-------~-' manually isolated from the control room.

D.4 Initiate action to Immediately verify one st aA~~ Y ga s treatmeAt ~.L."::..---r1:SGT I subsystem is capable of being placed in operation.

E. Required Action and E.l Initiate action to Immediately associated Completion restore DRAIN TIME to Time of Condition C or ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

D not met.

DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Survei 11 ance Frequency Control Program (continued)

Quad Cities 1 and 2 3.5.2-4 Amendment No. 273 / 268

RPV Water Inventory Control +-

3. 5. 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for the required ECCS injection/ In accordance spray subsystem, the: with the Survei 11 ance

a. Suppression pool water level is Frequency

~ 8.5 ft; or Control Program

b. Contaminated condensate storage tank(s) water volume is~ 140,000 available gallons.

SR 3.5.2.3 Verify, for the required ECCS In accordance 'I' injection/spray subsystem, locations with the susceptible to gas accumulation are Survei 11 ance sufficiently filled with water. Frequency Control Program

-R 3 . 5 . 2 . ~

Net l"etji:1i l"e E1 te s e FA et fel" sys t eFA 'o'eAt fl 8'oJ

~a t ~ s e ~ e A e E1 ~ A E1 el" aE1FAi Ai stPat i ve ceAtl"e l .

VeP ify , fe l" t~ e l"e ~~i l"e E1 EGGS IA acc e PE1aA ce

+

iAj ec tieA /s ~ P a y s ~s sys t e fFI , eac~ FF1a A ~al , *,;i tA Hi e

~e 'oJCI" e~el"ate E1 , aAE1 a~teFAat i c 'wa l ve iA Hie S~l"vei ll aAce fl 8\1' ~atA , tAat is Aet l ecke E1 , sea l eE1 , el" Fl"e~~eAcy et~el"wise sec~PeE1 i A ~ esitieA , is iA t~e GeAtl"e l Pl"e §l"aFA cel"l"ect ~ esitieA .

(continued)

Quad Cities 1 and 2 3.5.2-5 Amendment No. 273 / 268

NOTES

1. Operation may be through the test return line.

r In ventory Control 3 .5. 2

-r ISR 3.5.2.4 I 2. Credit may be taken for normal system I operation to satisfy this SR.

REQU I/REI I SURVEI LLANCE FREQUENCY

'Y

-&R- 3 . 5. 2. 5 Operate the required ECCS injection/spray In accordance subsystem t A P S~§A tA e Pec iP c ~latieA liA e with the for ~ 10 minutes. Survei 11 ance Frequency

~- Control Program SR 3.5.2.~----------------------+-------

-&R- 3 . 5. 2. 6 Verify each valve credited for In accordance _____

automatically isolating a penetration flow with the path actuates to the isolation position on Surveil lan ce an actual or simulated isolation signa l . Frequency Control Program ISR 3.5.2.6 I 3 . 5. 2. 7 - - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance subsystem can be manually operated. with the Survei 11 ance Frequency Control Program

========================================================== +-'

Quad Cities 1 and 2 3.5.2-6 Amendmen t No. 273 / 268

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

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, W~eR associate~ iRstr~meRtatioR is re~~ire~ to ~e OPERAgLE f)er LCD 2 . 2 . 8 . 1 , " Primary CoRtaiRmeRt IsolatioR I RstrnmeRtati OR ."

ACTIONS

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

1. Penetration flow paths may be unisolated intermittently under administrative controls.

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

3. Enter app l icable Conditions and Required Actions for systems made inoperable by PCIVs.

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

CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE-------- A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except Only app l icable to penetration flow path for main steam penetration flow paths by use of at least l in e with two or more one closed and PC I Vs. de-activated automatic valve, closed manual valve, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main One or more blind flange, or steam line penetration flow paths check valve with flow with one PCI V through the valve inoperab l e for reasons secured.

other than Condition D. AND (continued)

Quad Cities 1 and 2 3.6.1.3-1 Amendment No. 199/195

PC I Vs 3 . 6 . 1.3 AC TI ONS CON DIT ION REQU IRED AC TI ON COM PLE TI ON TI ME

c. (con t inued) C. 2 - - - - - - - - NOT ES- - - - - - - -

1. I so l at i on dev i ces in high rad i ation areas may be verif i ed by use of adm i ni s t rat i ve means .

2. I so l at i on devices that are locked, sea l ed, or oth erw i se secured may be verified by use of administrat i ve mea ns .

Verify th e affec t ed Once per 31 days penetra t ion fl ow path i s i solated .

D. MS I V leakage rate D. 1 Restore leakage ra t e 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months no t with i n li mit. to withi n l i mit .

E. Required Action and E. 1 Be in MODE 3 . 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Comp l et ion Time of Cond iti on A, AND B' C, or D no t met-+A-MQQi; +/-, 2 , er 3 . E.2 Be i n MOD E 4 . 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Quad Ci t i es 1 and 2 3 . 6.1.3-4 Amendment No . 273/ 268

AC Sources-Shutdown 3.8.2 SR 3.8.1.3, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.15, and SR 3.8.1.17.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 t

~

The following SRs f.ef'- AC sources required to be OPERABLE t-J:T.e. In accordance are applicable for SRs ef SfJcci fi ca ti eA 3 . 8 . 1 , CJ\CCfJt with applicable SR 3 . 8 . 1 . 9 , SR 3 . 8 . 1 . 13 , SR 3 . 8 . 1 . 19 , SRs -t-SR 3 . 8 . 1 . 20 , aA8 SR 3 . 8 . 1 . 21 , ape afJfJl i casl e .

SR 3.8.1.1 SR 3.8.1.7 SR 3.8.1.2 SR 3.8.1.10 SR 3.8.1.3 SR 3.8.1.11 SR 3.8.1.4 SR 3.8.1.15 SR 3.8.1.5 SR 3.8.1.17 SR 3.8.1.6 Quad Cities 1 and 2 3.8.2-5 Amendment No. 273/268

v t e Letter Sequence Response to RAI
EPID:L-2020-LLA-0253, TSTF-582 (Approved, Closed)
Initiation Request Acceptance Administration Questions 8 July 2021 Answers 19 August 2021 Results Approval Other:
MONTHYEAR2021-12-07 [Table View]

RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel

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RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel

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