View source for RS-17-029, Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

{{Adams
| number = ML17045A006
| issue date = 02/10/2017
| title = Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.
| author name = Simpson P
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000237, 05000249
| license number = DPR-019, DPR-025
| contact person = 
| case reference number = RS-17-029
| document type = Letter type:RS, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 195
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-17-029 10 CFR 50.90 February 10, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

==Subject:==
Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications (TS) for Dresden Nuclear Power Station (DNPS),
Units 2 and 3.
The proposed change replaces existing TS requirements related to operations with a potential for draining the reactor vessel (OPDRVs) with new requirements on reactor pressure vessel water inventory control (RPV WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel (TAF). provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides existing TS Bases pages marked to show the proposed changes for information only.
The proposed change has been reviewed and recommended for approval by the DNPS Plant Operations Review Committee in accordance with the EGC Quality Assurance Program.
Approval of the proposed amendment is requested by August 1, 2017, in order to support the DNPS, Unit 2 refueling outage that is planned for October 2017. Once approved, the amendment shall be implemented within 30 days.
EGC is notifying the State of Illinois of this application for a change to the TS by sending a copy of this letter and its attachments to the designated State Official in accordance with 1O CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

February 10, 2017 U.S. Nuclear Regulatory Commission Page2 There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 10th day of February 2017.
Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments: 1.      Description and Assessment
: 2. Proposed Technical Specifications Changes (Mark-Up)
: 3. Revised Technical Specifications Pages
: 4. Proposed Technical Specifications Bases Changes (Mark-Up) cc:     NRC Regional Administrator, Region Ill NRG Senior Resident Inspector - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

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 ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

==Subject:==
Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ,

==1.0   DESCRIPTION==

2.0   ASSESSMENT 2.1  Applicability of Published Safety Evaluation 2.2  Variations

==3.0   REGULATORY ANALYSIS==

3.1  No Significant Hazards Consideration

==4.0   ENVIRONMENTAL CONSIDERATION==

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

==1.0     DESCRIPTION==

Exelon Generation Company, LLC (EGC) proposes a change to the Dresden Nuclear Power Station (DNPS), Units 2 and 3 Technical Specifications (TS) requirements related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel.
2.0     ASSESSMENT 2.1      Applicability of Published Safety Evaluation EGC has reviewed the safety evaluation provided to the Technical Specifications Task Force on December 20, 2016, as well as the information provided in TSTF-542. EGC has concluded that the justifications presented in TSTF-542 and the safety evaluation prepared by the NRC are applicable to DNPS, Units 2 and 3 and justify this amendment for the incorporation of the changes to the DNPS TS.
The following DNPS, Units 2 and 3 TS reference or are related to OPDRVs and are affected by the proposed change:
1.1, Definitions 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation 3.3.5.2, Isolation Condenser (IC) System Instrumentation 3.3.6.1, Primary Containment Isolation Instrumentation 3.3.6.2, Secondary Containment Isolation Instrumentation 3.3.7.1, Control Room Emergency Ventilation (CREV) System Instrumentation 3.5.1, ECCS - Operating 3.5.2, ECCS - Shutdown 3.5.3, IC System 3.6.1.3, Primary Containment Isolation Valves (PCIVs) 3.6.4.1, Secondary Containment 3.6.4.2, Secondary Containment Isolation Valves (SCIVs) 3.6.4.3, Standby Gas Treatment (SGT) System
: 3. 7.4, Control Room Emergency Ventilation (CREV) System 3.7.5, Control Room Emergency Ventilation Air Conditioning (AC) System 3.8.2, AC Sources - Shutdown 3.8.5, DC Sources - Shutdown 3.8.8, Distribution Systems - Shutdown 2.2      Variations EGC is proposing the following variations from the TS changes described in the TSTF 542 or the applicable parts of the NRC's safety evaluation. These variations do not affect the applicability of TSTF-542 or the NRC's safety evaluation to the proposed license amendment.
Page 1 of 10

ATTACHMENT 1 -DESCRIPTION' AND ASSESSMENT In a few instances, the DNPS TS utilize different numbering and titles than the Standard Technical Specifications (STS) on which TSTF-542 was based. Specifically, the titles for the following DNPS, Units 2 and 3 TS vary from the STS discussed in TSTF-542:
3.3. 7.1, Control Room Emergency Ventilation (CREV) System Instrumentation 3.3.5.2, Isolation Condenser (IC) System Instrumentation 3.5, Emergency Core Cooling Systems (ECCS) and Isolation Condenser (IC) System 3.5.3, IC System 3.7.4, Control Room Emergency Ventilation (CREV) System 3.7.5, Control Room Emergency Ventilation Air Conditioning (AC) System 3.8.8, Distribution Systems - Shutdown Additionally, the DNPS, Units 2 and 3 TS do not include TS for a Reactor Core Isolation Cooling (RCIC) System or Inverters. These differences are administrative and do not affect the applicability of TSTF-542 to the DNPS TS.
The TSTF-542 Traveler and Safety Evaluation discuss the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). DNPS, Units 2 and 3 were not licensed to the 10 CFR 50, Appendix A, GDC. The DNPS, Units 2 and 3 Updated Final Safety Analysis Report (UFSAR), Section 3.1.1 contains an evaluation of the design basis of DNPS with respect to the first draft of the 70 proposed "General Design Criteria for Nuclear Power Plant Construction Permits" issued by the Atomic Energy Commission in July 1967. The design basis of DNPS, Unit 2 was later evaluated against the final "General Design Criteria for Nuclear Power Plants," published as 10 CFR 50, Appendix A in July 1971.
This evaluation is presented in Section 3.1.2 of the DNPS UFSAR. This difference does not alter the conclusion that the proposed change is applicable to DNPS.
The DNPS TS contain a Surveillance Frequency Control Program. Therefore, the Surveillance Requirement Frequencies for Technical Specifications 3.3.5.2 and 3.5.2 are "In accordance with the Surveillance Frequency Control Program."
The DNPS TS contain the following requirements that differ from the Standard Technical Specifications on which TSTF-542 was based, but are encompassed in the TSTF-542 justification:
* There are DNPS specific instrumentation functions that differ from the Standard Technical Specifications (STS). Changes to these instrumentation functions are justified by the discussion in Section 3.4.1 of the TSTF-542 justification. DNPS TS Table 3.3.5.1, Functions 1.e and 2.e describe pump start time delay relays for the core spray (CS) and low pressure coolant injection (LPCI) pumps. The purpose of these time delays is to stagger the automatic start of CS and LPCI pumps that are in each Division 1 and 2, thus limiting the starting transients on the 4.16 kV emergency buses. This staggering is unnecessary for manual operation; therefore, these Functions can be removed from the TS because the required ECCS subsystem is proposed to be started by manual operation.
* The DNPS, Units 2 and 3 design features a shutdown cooling (SOC) system that is dedicated to the removal of core decay heat and maintaining the temperature of the reactor coolant. Residual heat removal is not a mode of another system like LPCI; therefore, the Page 2of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT potential for system misalignments are less likely for the DNPS SOC system. The DNPS, Units 2 and 3 TS contain a specific Function that provides automatic isolation of the SOC system penetration flow paths below the TAF on low RPV water level in Modes 4 and 5, which can be credited in Drain Time calculations. Inclusion of this instrumentation Function is justified by the discussion in Section 3.3 of the TSTF-542 justification. Specifically, the definition of Drain Time allows crediting the closing of penetration flow paths that are capable of being automatically isolated by RPV water level isolation instrumentation prior to the RPV water level being equal to the TAF. The Reactor Vessel Water Level - Low Function is only required to be operable when automatic isolation of the associated SOC penetration flow path is credited in calculating Drain Time.
Reactor Vessel Water Level - Low signals are initiated from four level transmitters (i.e., two per trip system) that sense the difference between the pressure due to a constant column of water (i.e., reference leg) and the pressure due to the actual water level (i.e., variable leg) in the vessel. One channel per trip system is required to be operable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time to meet LCO 3.5.2.
This Function was moved from TS 3.3.6.1, Function 6.b to TS 3.3.5.2, Function 3.a. The following changes are proposed:
o    The Applicability is changed. The TS 3.3.6.1 Applicability for this Function is Modes 3, 4, and 5. The proposed TS 3.3.5.2 Applicability is "when automatic isolation of the associated penetration flow path(s) is credited in calculating Drain Time." In other words, if the Drain Time calculation assumes the SOC System would be automatically isolated, this Function must be operable to perform that function. This is consistent with the definition of Drain Time and the TS 3.5.2 requirements. The TS 3.3.6.1 Applicability in Mode 3 is retained to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel in Mode 3. In Modes 1 and 2, another isolation (i.e., Recirculation Line Water Temperature-High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.
o    The TS 3.3.6.1 Required Action 1.1 and 1.2 for an inoperable channel is to immediately initiate action to restore the channel to operable status or to immediately initiate action to isolate the SOC system. The TS 3.3.5.2 Action B requires declaring the associated penetration flow path(s) incapable of automatic isolation. This Action would require Drain Time to be recalculated without crediting automatic isolation of the affected penetration flow paths. The proposed Actions are consistent with the definition of Drain Time and the requirements of LCO 3.5.2. The TS 3.3.6.1 Required Action 1.2 is retained to account for SOC system flowpath isolation in Mode 3 as discussed above.
o    A Channel Check and Channel Functional Test are required at the existing Frequency.
A calibration of the trip unit, Channel Calibration, Logic System Functional Test, and Isolation System Response Time tests are no longer required in Modes 4 and 5, as discussed in Section 3.3.3 of the TSTF-542 Justification.
Page 3of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT
* DNPS , Units 2 and 3 do not currently have the capability to perform Channel Checks for proposed Table 3.3.5.2-1 Functions 1.a, "Reactor Steam Dome Pressure-Low (Permissive}, 1.b, "Core Spray Pump Discharge Flow-Low (Bypass) ," 2.a, "Reactor Steam Dome Pressure-Low (Permissive) ," and 2.b, "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass) ." The current DNPS, Units 2 and 3 TS do not include Channel Checks for these functions ; therefore, no Channel Check Surveillance Requirement (SR) was added for these functions .
* DNPS, Units 2 and 3 each have two LPCI loops with two pumps in each loop (i.e ., four LPCI pumps per unit). The DNPS TS currently require one operable channel for each LPCI loop for the "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass) ," Function .
EGC proposes to maintain the one channel per loop for Technical Specification 3.3.5.2, Function 2.b in lieu of one channel per pump as described in the STS, since at DNPS, there is only one flow transmitter for each loop that monitors the flow of both pumps in that loop (i.e. , two LPCI loop flow transmitters per unit) .
* The current DNPS, Units 2 and 3 TS do not include a manual initiation logic function for the CS or LPCI subsystems. This is due to the fact that the design of DNPS, Units 2 and 3 does not include this feature. Therefore , since this function does not exist at DNPS, manual initiation functions for LPC I and CS are not being included in Technical Specification 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control ," Table 3.3.5.2-1. Additionally, since the manual initiation functions are not included in Table 3.3.5.2-1 , the associated Logic System Functional Test would likewise not be required for TS 3.3.5.2; therefore, TS 3.3.5.2 as proposed for DNPS, Units 2 and 3 does not include a Logic System Functional Test SR.
As an alternative, EGC proposes that Technical Specification 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control ," include an SR to verify that the DNPS, Units 2 and 3 LPCI and CS subsystem can be manually operated through the manipulation of subsystem components from the Main Control Room (i.e., proposed SR 3.5.2.7 shown in Figure 1 below) .
SR     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 1lance Frequency Control Program Figure 1: Proposed SR 3.5.2.7 The manual operation of the LPCI and CS subsystems for the control of reactor cavity or RPV inventory are relatively simple evolutions and involve the manipulation of a small Page 4of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT number of components. These subsystem alignments can be performed by licensed operators from the Main Control Room as described below. This alternative is justified by the fact that a draining event is a slow evolution when compared to a design basis loss of coolant accident (LOCA) , which is assumed to occur at full power, and thus there is adequate time to take manual actions (i.e., hours versus minutes). Adequate time to take action is assured since the proposed Technical Specification 3.5.2, Condition E, prohibits plant conditions that result in Drain Times that are less than one hour. Therefore, there is sufficient time for the licensed operators to take manual action to stop an unanticipated draining event, and to manually start an ECCS injection/spray subsystem or the additional method of water injection. Consequently , there is no need for manual initiation logic to actuate the required subsystem components.
RPV and Reactor Cavity Inventory Control Using LPCI:
: a.      Start one Containment Cooling Service Water (CCSW) Pump in each loop (if available) AND verify 2(3)-1501-3 A/B , "Unit 2(3) Containment Cooling Heat Exchanger A(B) Tube Side Discharge Motor Operated Valves," open .
: b.      Start desired LPCI pump.
: c.      Close 2(3)-1501-21A(B) , "Unit 2(3) LPCI Loop 1(11) Coolant Injection Outboard Isolation Valve. "
: d.      Open 2(3)-1501-22A(B) , "Unit 2(3) LPCI Loop 1(11) Coolant Injection Inboard Isolation Motor Operated Valve."
: e.      Throttle open 2(3)-1501-21A(B) , "Unit 2(3) LPCI Loop 1(11) Coolant Injection Outboard Isolation Valve ," to achieve the desired level in the reactor pressure vessel or reactor cavity.
: f.      When LPCI is no longer required for inventory level control then :
(1)   Close 2(3)-1501-21 A(B) , "Unit 2(3) LPCI Loop 1(11) Coolant Injection Outboard Isolation Valve."
(2)   Close 2(3)-1501-22A(B), "Unit 2(3) LPCI Loop 1(11) Coolant Injection Inboard Isolation Motor Operated Valve."
(3)   Open 2(3)-1501-21A(B), "Unit 2(3) LPCI Loop 1(11) Coolant Injection Outboard Isolation Valve ."
(4)   Stop LPCI pump.
(5)   Stop CCSW pumps started in Step a.
Page 5of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT RPV and Reactor Cavity Inventory Control Using Core Spray:
: a.        Start Unit 2(3)A(B) Core Spray Pump.
: b.        Throttle open , MO 2(3) 1402 25A(B), "Core Spray Pump Discharge Valve ," to achieve the desired level in the reactor pressure vessel or reactor cavity .
: c.        When Core Spray is no longer requi red for inventory control then :
(1)   Close MO 2(3) 1402 25A(B), "Core Spray Pump Discharge Valve."
(2)   Stop Core Spray Pump.
Since the LPCI and CS subsystems can be placed in service using manual means in a short period of time (i.e ., within the timeframes assumed in the development of TSTF-542) , using controls and indications that are read ily available in the Main Control Room, manual operation of the required subsystem would be an equivalent alternative to system initiation via manual initiation logic.
* The DNPS design provides for isolation of the reactor water cleanup (RWCU) system at Reactor Vessel Water Level-Low versus Reactor Vessel Water Level-Low Low; therefore ,
proposed Table 3.3.5.2-1 reflects this RWCU isolation difference.
* The automatic isolation on Reactor Vessel Water Level-Low functions for the RWCU and SOC systems at DNPS , Units 2 and 3 varies slightly from the system described in the STS.
These functions receive input from four reactor vessel water level channels . Each channel inputs into one of four trip stings, and two trip strings make up a trip system . The trip systems are aligned in a parallel configuration , so both trip systems must trip in order to cause an isolation of the RWCU or SOC system valves. Any channel will trip its associated trip string and trip system . Therefore , both trip systems with one trip string in each trip system is required to provide for automatic RWCU and SOC system isolation . Proposed Table 3.3.5.2-1 has been revised to reflect the DNPS, Units 2 and 3 requirement for one operable channel in each Reactor Vessel Water Level-Low isolation trip system for RWCU and SOC.
* The DNPS TS do not currently contain a Note applicable to LCO 3.5.2 regarding realignment to the Low Pressure Coolant Injection mode. This Note is not applicable to DNPS , Units 2 and 3 because of the separate SOC system that provides for the removal of reactor residua l heat. This has no effect on the adoption of the TSTF-542.
* At DNPS, verification of Suppression Pool and Contaminated Condensate Storage Tank volumes is contained in a single SR (i.e., SR 3.5.2.2) versus in separate SRs in the STS.
This does not affect the applicability of TSTF-542.
* EGC proposes to delete DNPS, Units 2 and 3 TS 3.6.1 .3, Condition F and all of its associated Required Actions as shown in Figure 2 below. The Applicability for TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs) ;" is When associated instrumentation is required to be OPERABLE per LCO 3.3. 6. 1, "Primary Containment Isolation Page 6 of 10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT Instrumentation." This change is justified since OPDRV requirements have been deleted, and Mode 4 and 5 PCIV requirements have been relocated from TS 3.3.6.1 and 3.6.1.3 to the proposed TS 3.3.5.2. Thus, there are no longer any PC IVs required to be operable by TS 3.6.1.3 during Mode 4 or 5. These requirements are addressed by the proposed TS 3.3.5.2 in their entirety. Following the removal of OPDRV and relocation of Mode 4 and 5 requirements as discussed above, this Condition and associated Actions in TS 3.6.1.3 would never be applicable ; therefore, are no longer necessary.
PC I Vs 3.6.1.3 ACTIONS CQl"1PbHIOW Til"1[
i:: _ Re El 1-1 i re El Act i oR a REl .....
F~   - lr------+I++-A.....
i* t....i....
ii .....t.,..9.....ii..,s....,t.....i ..,gA
                                                                                                                       ..........t-g lFRFReEliately assosiates Gol!l~letioA                           sw&~9A9 0~9ratioA&
Til!le of CoAE:litioA A,                         1.*itl:1 a ~oteAtial for B, C, or g Rot lllet for                          E:lraiAiP&sect; tRe reastor PGIV(s) reEJ1-.1ireE:I to be                      'lessel (QPgR'!s).
OPeRABLe Bl-JFiR&sect; MQge 4
           ~                                ~
i:: . 2         lRitiate astioR to                                                      Iffiflleeiately restore valve(s) to OP~RABL~ stat1-.1s.
Figure 2: Proposed Variation That Deletes Technical Specification 3.6.1.3 Condition F
* The DNPS Control Room Emergency Ventilation (CREV) and the Control Room Emergency Ventilation Air Conditioning (AC) systems (i.e., Technical Specifications 3.7.4 and 3.7.5, respectively) provide Control Room habitability functions . Changes to the TS controls on these systems is justified by the discussion in Section 3.4.3 of the TSTF-542 justification .
Specifically, these DNPS specific systems provide similar Control Room habitability functions as those described in the STS, and changes to these Technical Specifications are similarly justified .
Page 7of10

ATTACHMENT 1 - DESCRIPTION AND ASSESSMENT

==3.0      REGULATORY ANALYSIS==

3.1      No Significant Hazards Consideration Analysis Exelon Generation Company, LLC (EGC) requests adoption of Technical Specifications Task Force Traveler (TSTF)-542 "Reactor Pressure Vessel Water Inventory Control ," which is an approved change to the Standard Technical Specifications (STS) , into the Dresden Nuclear Power Station, Units 2 and 3 Technical Specifications (TS) . The proposed amendment replaces the existing requirements in the TS related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1 .3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel.
EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50 .92 ,
"Issuance of amendment," as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change replaces existing TS requirements related to OPDRVs with new requirements on RPV WIC that will protect Safety Limit 2.1.1.3. Draining of RPV water inventory in Mode 4 (i.e ., cold shutdown) and Mode 5 (i.e ., refueling) is not an accident previously evaluated and , therefore , replacing the existing TS controls to prevent or mitigate such an event with a new set of controls has no effect on any accident previously evaluated .
RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated . The existing OPDRV controls or the proposed RPV WIC controls are not mitigating actions assumed in any accident previously evaluated.
The proposed change reduces the probability of an unexpected draining event (which is not a previously evaluated accident) by imposing new requ irements on the limiting time in which an unexpected draining event could result in the reactor vessel water level dropping to the top of the active fuel (TAF) . These controls require cognizance of the plant configuration and control of configurations with unacceptably short drain times. These requirements reduce the probability of an unexpected draining event. The current TS requirements are only mitigating actions and impose no requirements that reduce the probability of an unexpected draining event.
The proposed change reduces the consequences of an unexpected draining event (which is not a previously evaluated accident) by requiring an Emergency Core Cooling System (ECCS) subsystem to be operable at all times in Modes 4 and 5. The current TS requirements do not require any water injection systems, ECCS or otherwise, to be operable in certain conditions in Mode 5. The change in requirement from two ECCS subsystems to one ECCS subsystem in Modes 4 and 5 does not significantly affect the consequences of an unexpected draining event because the proposed Actions ensure equipment is available within the limiting drain time that is as capable of mitigating the event as the current Page 8of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT requirements. The proposed controls provide escalating compensatory measures to be established as calculated drain times decrease, such as verification of a second method of water injection and additional confirmations that secondary containment and/or filtration would be available if needed.
The proposed change reduces or eliminates some requirements that were determined to be unnecessary to manage the consequences of an unexpected draining event, such as automatic initiation of an ECCS subsystem and control room ventilation . These changes do not affect the consequences of any accident previously evaluated since a draining event in Modes 4 and 5 is not a previously evaluated accident and the requirements are not needed to adequately respond to a draining event.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response: No The proposed change replaces existing TS requirements related to OPDRVs with new requirements on RPV WIC that will protect Safety Limit 2.1.1 .3. The proposed change will not alter the design function of the equipment involved. Under the proposed change, some systems that are currently required to be operable during OPDRVs would be required to be available within the limiting drain time or to be in service depending on the limiting drain time . Should those systems be unable to be placed into service, the consequences are no different than if those systems were unable to perform their function under the current TS requirements.
The event of concern under the current requirements and the proposed change is an unexpected draining event. The proposed change does not create new failure mechanisms, malfunctions, or accident initiators that would cause a draining event or a new or different kind of accident not previously evaluated or included in the design and licensing bases.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change replaces existing TS requirements related to OPDRVs with new requirements on RPV WIC . The current requirements do not have a stated safety basis and no margin of safety is established in the licensing basis . The safety basis for the new requirements is to protect Safety Limit 2.1.1.3. New requirements are added to determine the limiting time in which the RPV water inventory could drain to the top of the fuel in the reactor vessel should an unexpected draining event occur. Plant configurations that could result in lowering the RPV water level to the TAF within one hour are now prohibited . New Page 9of10

ATTACHMENT 1 -DESCRIPTION AND ASSESSMENT escalating compensatory measures based on the limiting drain time replace the current controls. The proposed TS establish a safety margin by providing defense-in-depth to ensure that the Safety Limit is protected and to protect the public health and safety. While some less restrictive requirements are proposed for plant configurations with long calculated drain times, the overall effect of the change is to improve plant safety and to add safety margin .
Therefore , the proposed change does not involve a significant reduction in a margin of safety.
Based on the above , EGC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 1O CFR 50.92(c) , and , accordingly, a find ing of "no significant hazards consideration" is justified.

==4.0     ENVIRONMENTAL CONSIDERATION==

The proposed change would change a requ irement with respect to installation or use of a facility component located within the restricted area , as defined in 1O CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite , or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 1O CFR 51 .22(c)(9) .
Therefore, pursuant to 10 CFR 51.22(b) , no environmental impact statement or environmental assessment need be prepared in connection with the proposed change .
Page 10of10

Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 2 - PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)
TOC Page i                       3.3.5.2-1                      3.6.1.3-5 TOC Page ii                       3.3.5.2-2                      3.6.1.3-6 1.1-2                        3.3.5.2-3                      3.6.4.1-1 1.1-3                        3.3.5.3-1                      3.6.4.2- 1 1.1-4                        3.3.5.3-2                      3.6.4.2-3 1.1-5                        3.3.6.1 -8                     3.6 .4.3-1 1.1-6                        3.3.6.2-5                      3.6.4.3-2 1.1-7                        3.3.7.1-1                       3.7.4-1 3.3.5.1-2                       3.5.1 -1                       3.7.4-2 3.3.5.1-3                       3.5.2-1                        3.7.5-1 3.3.5.1-5                       3.5.2-2                        3.8.2-3 3.3.5.1-10                       3.5.2-3                        3.8.2-4 3.3.5.1-11                       3.5.2-4                        3.8.5-2 3.3.5.1-12                       3.5.2-5                        3.8.8-2 3.3.5.1-13                       3.5.2-6 3.3.5.1-14                       3.5.3-1

TABLE OF CONTENTS
: 1. 0         USE AND APPLICATION 1.1              Definitions ..... . .... .. .......... ............... ...... ... 1.1 -1
: 1. 2             Logica l Connectors ....................................... 1.2-1
: 1. 3             Comp l etion Times .. . ....... .. ... ...... .... .... ............ 1. 3-1 1.4              Frequency . .... ................ . ... ....................... 1. 4-1
: 2. 0         SAFETY LIMITS (SLs)
: 2. 1             SLs .................................... . . . ... ... ......... 2 . 0-1 2.2              SL Violations ..... .. ................ . . ... ............ .. .. 2.0-1 3.0          LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .. ...... 3 . 0-1 3.0          SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .... . ............ 3 . 0-4
: 3. 1         REAC TI VITY CONTROL SYSTEMS 3 . 1.1          SHUTDOWN MARGIN (SDM) . .. .... .. .... . .. ...... . . ............ 3 .1.1 -1 3 .1. 2          Reactivity Anomalies ..................................... 3 . 1.2-1 3 . 1. 3         Control Rod OPERABILITY .................................. 3 . 1. 3 - 1 3 . 1. 4         Control Rod Scram Times .. . ......... ...... . ... ............ 3.1 .4 -1 3 . 1. 5         Control Rod Scram Accumulators ...................... .. ... 3 . 1. 5 - 1 3 .1. 6          Rod Pattern Control ..... .. .. . . . . ......................... 3 . 1. 6- 1 3 . 1. 7        Standby Liquid Control (SLC) Sy stem ...... .. ... ........... 3 .1. 7- 1 3 . 1. 8        Scram Discharge Volume (SDV) Vent and Drain Valves ....... 3 .1. 8-1 3.2          POWER DISTRIBUTION LIMITS
: 3. 2 .1         AVERAGE PLANAR LINEAR HEAT GEN ERATION RATE (APLHGR) .. .. .. 3 . 2 .1 -1 3 . 2.2         MINIMUM CRITICAL POWER RATIO (MCPR) ...................... 3 . 2 . 2-1
: 3. 2.3           LINEAR HEAT GENERATION RATE (LHGR) .... .. ............... . 3 . 2.3 - 1 3.3          INSTRUMENTATION 3 . 3.1.l        Reactor Protection System (RPS) In strumentation ....... .. . 3 . 3 . 1.1-1 3 . 3.1.2       Source Range Monitor (SRM) Instrumentation ............... 3 . 3 . 1 . 2-1 3 . 3.1.3       Oscillation Power Range Monitor (OPRM) Instrumentation ... 3 . 3 . 1 . 3-1 3.3.2.1         Control Rod Block Instrumentation .......... ........... ... 3 . 3 . 2.1-1 3.3 . 2 . 2      Feedwater Sy stem and Main Turbine High Water Level Trip Instrumentation . .......... ..... ..... .. ......... ... 3 . 3 . 2 . 2-1 3 . 3 . 3 .1     Post Accident Monitoring (PAM) Instrumentation ......... . . 3 . 3 . 3.1-1
: 3. 3. 4 .1      Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation ........ .... ....... 3 . 3.4.1-1 3 . 3 . 5 .1     Emergency Core Cooling System (ECCS) Instrumentation ..... 3 . 3 . 5.1-1 3 . 3 . 5. 2     I sol ati on Condl'.rnserReactor Pressure Vessel ( ~RPV ) S,ysteR1 I nstrYR1entatio nWater Inventory Control Instrumentation ........... . .. . 3 . 3.5 . 2-1
: 3. 3. 5.3        Isolation Condenser (JC) System Instrumentation .......... 3 . 3 . 5 . 3-1 3.3.6.1         Primary Containment Isolation Instrumentation .... . .. . ... . 3 . 3 . 6.1-1
: 3. 3.6. 2       Secondary Containment Isolation Instrumentation .......... 3 . 3.6 . 2-1 3 . 3.6 . 3     Relief Valve Instrumentation .. . ........................ . . 3 . 3 . 6 . 3-1 3 . 3 . 7. 1    Control Room Emergency Ventilation (CR EV ) System Instrumentation ........... .. ........ .. ................. 3 . 3 . 7 . 1-1 3.3.7. 2        Mechanical Vacuum Pump Trip Instrumentation ........ ..... . 3 . 3 . 7 . 2-1 (continued)
Dresden 2 and 3                                                         Amendment No.

TABLE OF CONTENTS
: 3. 3         INSTRUMENTATION (continued) 3 . 3 .8.1       Loss of Power ( LOP ) Instrumentation ......... .. ........... 3.3 .8.1-1 3 . 3 . 8.2      Reactor Protection System (RPS) Electric Power Monitoring ... .. ........................................ 3.3 . 8 . 2-1 3.4          REACTOR COO LAN T SYSTEM (RCS) 3 . 4.1         Recirculation Loops Operating ............. .. ........... .. 3 .4. 1-1 3 .4. 2         Jet Pumps ................................................ 3 .4. 2-1 3 .4. 3         Safety and Relie f Valves ................................ 3 . 4.3-1 3 . 4.4         RCS Operational LEAKAGE ............ . ..................... 3 . 4 . 4-1 3 .4 .5         RCS Leakage Detection Instrumentation ......... ..... ...... 3.4 . 5- 1 3 . 4.6         RCS Specif i c Activity .. . .. ... . ..... ............ ...... .... 3.4 . 6-1 3 .4. 7         Shutdown Cooling (SOC) System-Hot Shut down ............... 3 .4.7 -1 3 .4.8          Shutdown Cooling (SOC) System-Cold Shutdown .............. 3 . 4 . 8-1 3.4.9           RCS Pressure and Temperature (P/T) Limits ................ 3 . 4 . 9-1 3.4 .10         Reactor Steam Dome Pressure ................... . .......... 3 . 4 .1 0-1 3.5          EMERGENCY CORE COOL IN G SYSTEMS (ECCS) , REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM
: 3. 5 .1         EC CS-0 pe r a t i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 . 5 . 1 - 1
: 3. 5. 2         EGGS Shbltaoi,.rnRPV Water Inventory Control ................ . 3 . 5 . 2- 1 3 . 5.3         IC Sys tern .................................. . ............. 3 . 5 . 3 - 1 3.6          CONTAINMENT SYSTEMS 3 . 6 .1.1      Primary Containment ...................................... 3 .6.1.1-1 3 . 6 .1. 2     Primary Containment Air Lock ............................. 3 . 6.1.2-1 3.6 .1. 3       Primary Containment Isolation Valves (PCIVs) ............. 3 . 6.1. 3-1 3.6 . 1.4       Drywell Pressure .. . ..... . .. .. .... ....... ..... ............ 3 . 6 . 1.4-1 3 . 6 . 1.5     Drywell Air Temperature ........................ . ......... 3 . 6 .1. 5-1 3 . 6 . 1.6     Low Set Relief Valves .... ... ... .......................... 3 . 6 . 1.6-1 3 . 6 . 1.7     Reactor Building-to-Suppression Chamber Vacuum Breakers ..... . ......... ....... . .... ......... ..... .... . . 3 . 6. 1. 7 - 1 3 . 6 .1. 8     Suppression Chamber-to-Drywell Vacuum Breakers ....... .. .. 3 . 6 . 1 .8 -1 3.6. 2. 1       Suppression Pool Average Temperature .................. . .. 3.6.2 . 1-1 3.6.2.2         Suppress i on Pool Water Le vel ....... . . ...... .............. 3 . 6 . 2.2-1 3 . 6 .2. 3     Suppression Pool Cooling ................................. 3.6.2 . 3-1 3 . 6 . 2 .4    Suppression Pool Spray ................................... 3 . 6.2 . 4-1 3 . 6 . 2.5     Drywell-to-Suppression Chamber Differential Pressure ..... 3 . 6.2.5-1 3.6.3. 1        Primary Containment Oxygen Concentra t ion ......... ........ 3 . 6 . 3 .1 -1 3 . 6 .4. 1     Secondary Containment ......... . ........... .... . ........ .. 3 . 6 . 4 .1-1 3 . 6 .4. 2     Secondary Containment Isolation Valves (SCIVs) ........... 3 . 6 .4. 2-1 3.6.4 . 3       Standby Gas Treatment (SGT) System ....................... 3 . 6 . 4 . 3-1 (continued)
Dresden 2 and 3                                              ii                                    Amendment No .

Definitions
: 1. 1 1.1  Definitions    (continued)
CHANNE L FUNCTIONAL TEST      A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY . The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.
CORE ALTERATION               CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components , within the reactor vessel with t he vessel head removed and fuel in the vessel . The fo 11 owing exceptions are not considered to be CORE ALTERATIONS :
: a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);
and b . Control rod movement, provided there are no fuel assemblies in the associated core cell .
Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.
CORE OPERATING LIMITS         The COLR is the unit specific document that REPORT (COLR)                 provides cycle specific parameter limits for the current reload cycle . These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5 . 6.5. Plant operation within these limits is addressed in individual Specifications .
DOSE EQUIVALENT I - 131       DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I-131 , I-132 , I-133, I-134, and I-135 actually present . The dose conversion factors used for this calculation shall be the inhalation committed dose conversion factors in Federal Gui dance Report 11 , "L i mit ing Va l ues of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1989.
(continued)
Dresden 2 and 3                         1.1 -2                  Amendment No .

Definitions 1.1 1.1  Definitions DRAIN TINE       The DRAIN TINE 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 th e 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 . g., seismic event, loss of normal power, single human error),
for all penetration flow paths below the TAF except :
: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured 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
: 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- 3               Amendment No .

Definitions 1.1 1.1   Definitions DRAIN TIME        c)   The penetration flow paths required to be (continued)        evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d)   No additional draining events occur; and e)   Realistic cross-sectional areas and drain rates are used .
A bounding DRAIN TIME may be used in lieu of a calculated value .
LEAKAGE           LEAKAGE sha 11 be :
: a. Identified LEAKAGE
: 1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank ; or 2 . LEAKAGE into the drywel 1 atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAG E;
: b. Unidentified LEAKAG E All LEAKAGE into the drywell that is not identified LEAKAGE;
: c. Tota 1 LEAKAGE Sum of the identified and unidentified LEAKAGE; and
: d. Pr essur e Boun dary LEA KAGE LEAKAGE through a nonisolab l e fau l t i n a Reactor Coolant System CRCS) component body, pipe wall, or vessel wall .
(continued)
Dresden 2 and 3             1.1 -4                  Amendment No .

Definitions
: 1. 1 1.1   Definitions  (continued)
LINEAR HEAT GENERATION       The LHGR shall be the heat generation rate per RATE (LHGR)                  unit length of fuel rod . It is the integral of the heat flux over the heat transfer area associated with the unit length .
LOGIC SYSTEM FUNCTIONAL      A LOGIC SYSTEM FUNCTIONAL TEST shall be a te s t TEST                         of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY . The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system step s so that the entire logic system is tested .
MINIMUM CRITICAL POWER       The MCPR shall be the smallest critical power RATIO CMCPR )                ratio (CPR ) that exists in the core for each cla ss of fuel. The CPR i s that power in the assembly that is calculated by applica t ion of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE                         A MODE s hall correspond to any one inclu s ive combination of mode switch po s ition, average reactor coolant temperature, and reactor ve s sel head closure bolt tensioning specified in Table 1.1 - 1 with fuel in the r eactor ve s sel .
OPERABLE-OPERABILITY         A sy s tem, subsy stem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing it s specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function( s ) are also capable of performing their related support function( s ) .
(continued)
Dresden 2 and 3                         1. 1-5               Amendment No .

Definitions 1.1 1.1    Definitions (continued)
RATED THERMAL POWER          RTP shal l be a total reactor core heat transfer
( RTP)                       rate to the reactor coolant of 2957 MWt .
REACTOR PROTECTION           The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE        from the opening of the sensor contact until the TIME                         opening of the trip actuator . The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
SHUTDOWN MARGIN CSDM)        SDM shall be the amount of reactivity by which the reactor is su bcritical or would be su bcritical throughout the operating cycle assuming that:
: a. The reactor is xenon free; b . The moderator temperature is~ 68&deg;F, corresponding to the most reactive state; and
: c. All control rods are fully inserted except for the sing le control rod of highest reactivity worth, which is assumed to be fully withdrawn.
With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.
THERMAL POWER                THERMAL POWER shall be the total reactor core heat tran sfer rate to the reactor coolant.
TURBINE BYPASS SYSTEM        The TURBINE BYPASS SYSTEM RESPONSE TIME shall be RESPONSE TIME                that time interval from when the turbine bypass control unit generates a turbine bypass valve flow signal until the turbine bypass valves travel to their required positions . The response time may be measured by means of any series of se quential, overlapping, or total steps so that the entire response time is measured.
Dresden 2 and 3                        1. 1- 6            Amendment No .

Definitions 1.1 Table 1. 1-1 (page 1 of 1)
MODES REACTOR MODE           AVERAGE REACTOR MODE             TITLE             SWITCH POSITION        COOLAN T TEMP ERATURE
( o F) 1    Power Operation      Run                                     NA 2    Startup              Refuel ca> or Startup/Hot               NA Standby 3    Hot Shutdown '*>     Shutdown                             >   212 4    Cold Shutdown '*>    Shutdown                             ~   212 5    Refuel i ng Cb>      Shutdown or Refuel                      NA (a)   All reactor vessel head closure bolts fully tensioned .
(b)   One or more reactor vessel head closure bolts less than fully tensioned.
Dresden 2 and 3                         1.1- 7            Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 ACTIONS CONDITION             REQUIRED ACTION                             COMPLETION TIME B. As required by      B. 1     - - - - - - - - NOTE.& - - - - - - - -
Required Action A.1         1. Only applicable and referenced in                   in MODtS 1, 2, Table 3.3.5.1 - 1.                 and 3 .
                                 .i.--Only applicable for Functions 1.a, 1.b, 2.a, 2 . b, 2 . d, and 2 . j .
Declare supported                         1 hour from feature(s) inoperable                     discovery of when its redundant                        loss of feature ECCS                              initiation initiation capability                     capability for is inoperable.                            feature(s) in both divisions B. 2    --------NOTE---------
Only applicable for Functions 3 .a and 3 .b.
Declare High Pressure                     1 hour from Coolant Injection                         discovery of (HPCI) System                             loss of HPCI inoperable.                               initiation capability B.3     Pl ace channel in                         24 hours trip .
(continued)
Dresden 2 and 3               3.3.5.1-2                              Amendment No.

ECCS Instrumentation 3 . 3 . 5.1 ACTIONS CONDITION                 REQUIRED ACTION                           COMPLETION TIME C. As required by          c. 1     - - - - - - - - NOTE&- - - - - - - -
Required Action A.l              1. Onl,y applicable and referenced in                       in ti400ES 1, 2, Table 3 . 3 . 5 . 1- 1.                 anti 3 .
                                     .&:---Only applicable for Functions l.c, l . e, 2. c, 2. e, 2 . g,              1 hour from 2.h, 2.i, and 2.k .                    discovery of loss of initiation Declare supported                      capability for feature(s) inoperable                   feature(s) in when its redundant                      both divi s ions feature ECCS initiation capability is inoperable.
24 hours C. 2     Restore channel to OPERABLE status .
(continued)
Dresden 2 and 3                   3.3.5 . 1-3                          Amendment No.

ECCS Instrumen t ation 3 . 3 . 5 .1 ACTIONS CONDITION                   REQUIRED ACTION                             COMPLETION TIME E. As required by          E. 1      - - - - - - - - NOTE.g. - - - - - - - -
Required Action A. l              1. 0Rly applicable and referenced in                 iR MODES 1, 2, aRd 3 .
Table 3 . 3 . 5 . 1-1 .
                                        &.--Only applicable for Functions l.d and 2 . f.
Declare supported                         1 hour from feature(s) inoperable                     discovery of when its redundant                        loss of feature ECCS                              initiation initiat i on capability                   capability for i s inoperable .                          sub sys tems in both divi s i ons E. 2      Re store channel to                       7 day s OPERABLE status .
( continued )
Dre sden 2 and 3                   3 . 3. 5. 1-5                            Amendment No .

ECC S In s tr ume ntation
: 3. 3. 5. 1 Table 3.3.5. 1- 1 (page 1 of 5)
Emergency Core Cooling System In strumentation APPLICABLE                     CO NDITIONS MOO ES        REQ UI RED    REFERE NCED OR OTHER        CHANNELS          FROM SPECIF ! ED          PER        REQUIRED   SURVEILLANCE             ALLOWABLE FU NCTIO N               CONO!TlO NS      FU NCTION     ACTION A. 1 REQU I RE MENTS              VA LUE
: 1. Core Spray System
: a. Reactor Vesse l Water           1,2, 3,           4'"" '           B     SR  3.3.5. l. 1      ;, - 54 . 15 Le ve l - Low Low                                                        SR  3.3.5. l.2        inches SR  3.3.5.l.3 SR  3.3 .5.1 .5 SR  3.3.5. l.6
: b. Orywe l l Pres s ure- Hig h      1,2 , 3          4'"" '           B     SR 3.3.5 .l.2        s 1.81 psig SR 3.3.5.l.4 SR 3.3.5. l.6
: c. Reactor Steam Dome               I ,2 ,3            2              c     SR 3.3.5 .l.2        ;, 308.5 ps ig Pre ss ure- Low                                                          SR 3.3.5 .l.4         and (Permi ss ive)                                                           SR 3.3. 5. l.6       s 34 l. 7 ps i g
                                                                                     ~R  J.J.&sect;.1.2           JQ!l.&sect; JlSig
                                                                                     ~R  J.J.&sect;.1.4        -4 SR  3.3.&sect;.1.e           341.7 JlSi&sect;
: d. Core Spray Pump                 1,2, 3,      1 per pump                  SR  3.3.5 .l.2       ;, 802 gpm Discharge Flow-Low                                                       SR  3.3.5. l. 3       and (Bypa ss )                                                               SR  3.3.5 .l.5       s 992 gpm SR  3.3.5. 1.6
: e. Core Sp ra y Pump                1, 2 ,3     I per pump            c     SR 3.3.5. 1.5         s 11.0 seconds Start -Time Dela y Rela y                                                SR 3.3.5 .1.6
: 2. Low Pressure Coola nt Injecti on CLPC!l Sys tem
: a. Rea ct or Vesse l Wa ter        1,2, 3,                            B     SR  3.3.5 .l.1       ;, . 54 . 15 Le ve l - Low Low                                                        SR  3.3.5. l. 2       Inche s SR  3.3.5. l. 3 SR  3.3.5.l.5 SR  3.3.5.l.6
: b. Orywe l l Pre ss ure- High       l, 2. 3                           B     SR 3.3.5 .l.2        s 1.81 ps ig SR 3.3 .5. 1. 4 SR 3.3.5 .l.6
: c. Reactor Steam Dome               1,2, 3             2             c      SR 3.3.5 .l. 2       ;, 308 .5 ps ig Pre ss ure- Low                                                          SR 3.3. 5. l. 4      and (Permissive)                                                             SR 3.3.5 . . 6       s 341 . 7 ps i g
                                                                                     ~R  :LL&sect; . . 2
                                                                                     ~R  J.J.e. 1. 4
                                                                                     ~R  J.J.e.l.e        -4 341.7     ~51&sect;
( co ntinued)
(Da ) Al so required to initiate the assoc iated die se l generator COG) .
Dr es den 2 and 3                                       3 . 3 .5.1 - 10                    Amendment No .

ECCS Instrumentation 3 . 3. 5 .1 Tabl e 3.3.5 .1 - 1 (p age 2 of 5)
Emergency Core Cooling Sys t em In strumentati on APPLIC ABLE                        CONDITION S MODE S          REOUI RED       REFERENCED OR OTHER          CH ANNEL S         FROM SPEC I FI ED           PER          REQUIRED   SURVEILLANC E           ALLOWABLE FUN CT JON              CONDITION S         FUNCTION        ACTION A. 1 REQUIREMENTS              VA LU E
: 2. LPC I Sys t em ( co ntinued)
: d. Reac t or St ea m Dome            I ,2,3                               B      SR 3.3.5. 1.2      ;,, 802 ps ig and Press ure- Low (Brea k                                                        SR 3.3.5. l.5      s 898 ps ig Dete cti on)                                                                  SR 3.3.5. 1. 6
: e. Low Pres s ure Coolant           1,2, 3,        1 per pump             c      SR 3 . 3. 5 . l. 5 s 5 .5 second s Inj ection Pump                                                              SR 3 . 3. 5 . l.6 Start- Time Dela y Rela y Pumps B and D
: f. Low Press ur e                   1,2 , 3,       1 pe r l oo p                 SR  3.3.5 .1. 2    ;,, 1107 gpm Coolant Inj ec ti on Pump                                                     SR  3.3. 5. l. 3 Di sc harg e Fl ow- Low                                                       SR  3.3.5. l. 5 (Bypass)                                                                      SR  3.3.5. 1. 6
: g. Recircul a ti on Pump             1 , 2, 3      4 pe r pump            c      SR 3.3. 5. l. 2    s 5.9 ps id Differ enti al                                                                SR 3.3.5. l. 5 Press ure- Hi gh (B re ak                                                     SR 3.3. 5. 1. 6 Detection)
: h. Rec ircul ation Ri se r           1 ,2 ,3                              c      SR 3.3.5 .1. 2     s 2. O psi d Differe nt i a 1                                                              SR 3 . 3.5.1.5 Press ure- Hi gh <Brea k                                                      SR 3.3. 5 . l. 6 Det ec ti on)
: i. Reci rcu l ati on Pump            1 ,2 ,3              2               c      SR 3.3.5. 1. 5     s 0.53 seco nd s Dif fe rent i a 1 Press ure                                                   SR 3 . 3.5. 1. 6 Time Del ay- Rel ay
           <Break De t ec ti on)
: j. Rea ct or St ea m Dome            1> 2 >3              2               B      SR 3.3. 5. 1. 5    s 2. 12 seco nd s Press ur e Time De l ay-                                                      SR 3.3.5 .1. 6 Re l ay (Brea k Det ec ti on)
: k. Recirculat i on Rise r            1, 2 , 3             2               c      SR 3.3 . 5.1. 5    s 0. 53 seco nd s Di ffere nt i a 1 Press ure                                                   SR 3.3.5. 1. 6 Time Dela y-Rela y
           <Brea k Detec ti on)
                                                                                                                <continued)
Dr es den 2 and 3                                         3 .3 . 5 .1 -1 1                    Amendment No.

ECCS In s trumentati on
: 3. 3 . 5 .1 Table 3.3.5. 1-1 (page 3 of 5)
Emergency Core Cooling System In s trumentation APPLIC ABLE                              CONDITIONS MODES OR                RE QU I RED    REFERE NCED OTHER                CHANNELS           FROM SPECIFIED                    PER         REQU I RED  SURVEILL ANCE             ALLO WABLE FUNCTION                        CONDITIONS                FUNCTION       AC TIO N A.1 REOU I REM EN TS            VA LUE
: 3. Hig h Pre ss ure Coolant Injection (HPCI) System
: a. Reactor Vesse l        Wa ter                  I*                                   B      SR   3.3.5 .1. 1    ., - 54 . 15 Le ve l - Lo w Low                                                                         SR  3.3.5. 1. 2      In c he s 2 <.wi l , 3 c.0>                                    SR   3.3.5 .1. 3 SR  3.3.5.1.5 SR  3.3.5. 1. 6
: b. Orywe 11 Pr ess ure- High                      1,                                   B      SR  3.3.5 .1.2      $   1.81 p s ig SR  3.3.5 .1.4 2<.0 J, 3 <.0 l                                      SR  3.3.5 .1.6
: c. Reactor Vessel Water                          1.                    2               c      SR  3.3.5. 1. 1     s 46. 2 inch es Le ve l - High                                                                             SR  3.3.5 .1.2 2<..ti >, 3<.0 J                                     SR  3.3. 5.1. 3 SR  3.3.5. 1.5 SR  3.3.5. 1.6
: d. Contaminated                                  1,             2 pe r CCST            0      SR  3.3.5. 1. 2     ., 11.1158 ft Condensate Storage                                                                         SR  3.3 .5.1.5       for CCST 213 A Tank ( CCSTl Le ve 1- Lo w                        3 << 0J                                   SR  3.3 .5.1.6       and ;;, 7 .5637 2'"" '
* ft for CCST 213 B
: e. Suppr ess i o n Poo l     Water               1,                    2               0      SR  3.3.5 .1 .2     $   I 5 ft Le ve l - High                                                                             SR  3.3.5 .1. 5     5.625 inch es 2 <Wi l '    3 < ~ti l                                SR  3. 3.5. 1 . 6
: f. High Pressure Coolant                         1,                                           SR  3.3.5. 1. 2     ;;, 6 16 gpm Inje c tion Pump                                                                           SR  3.3.5 .1.4 Di sc harg e Flow- Lo w              2 <Wi l ' 3 <e-b )                                    SR  3.3.5 .1. 6
              <Bypass l
: g. Manual     Initiation 1.
c      SR  3.3.5 .1.6      NA 2<<1> J. 3'*b )
(continued)
( e b ) With react o r     s t ea m do me pre ss ure > 150 ps ig .
Dr es den 2 and 3                                                         3 . 3 . 5 .1 - 12                    Ame ndme nt No .

ECCS In s trumentati on 3 . 3 . 5 .1 Table 3.3.5.1 - 1 (page 4 of 5)
Emergency Core Cooling System In s trumentation APPLIC ABLE                           CONDITIONS MODES OR               RE QUI RED    REFERENCED OTHER               CHANNELS          FROM SPECIFIED                   PER        REQUIRED    SURVEILLANCE           ALLOWABLE FUN CTI ON              CONDITIONS              FUNCTION      AC TION A. 1 REQUIREMENTS              VA LUE
: 4. Automatic Depress urization Sys tem (ADS) Trip System A
: a. Reactor Vesse l Wa ter               I,                   2                     SR  3. 3. 5 .1. I  ., - 54 . 15 Level - Low Low                                                                 SR  3.3.5. 1.2      Inches 2<.. , . 3 <** >                                   SR  3.3.5. 1.3 SR  3.3.5. 1.5 SR  3 .3.5.1.6
: b. Drywel l Pre ss ure- High            1,                   2              F      SR 3.3.5.1.2       $  1 .81 psig SR 3.3.5. 1.4 2<<1> >, 3 <<*>                                     SR 3.3.5. 1.6
: c. Automatic                            1.                                  G      SR 3.3.5. 1.5      s 113 seco nd s Depre ss urization                                                              SR 3.3 .5.1.6 System Initiation            2<-" >' 3<<1> )
Timer
: d. Core Spray Pump                      1.                   2              G      SR 3.3.5. 1. 2     ., 101. 5 psig Di sc harge                                                                     SR 3 . 3 .5.1.4    and Press ure -High              2<..ti >) 3 <<*>                                    SR 3.3.5. 1.6      $  148.5 ps ig
: e. Low Pre ss ure Coolant               1.                   4              G      SR 3 .3.5.1.2      ., 101. 5 ps ig Injecti on Pump                                                                 SR 3.3.5.1.4       and Di sc harge                  2 Cb* l ,  3 1-i-b )                               SR 3.3.5. 1. 6     $  148. 5 psig Pressure -High
: f. Automatic                            1.                                  G      SR 3.3.5 . 1.5     s 580 seco nd s Depre ssur i za tion                                                            SR 3.3 .5.1.6 System Low Low Wa ter        2<<1> >, 3 <<1> >
Le ve l Actuation Timer (continued)
( ~b l With reactor s team dome pressure > 150 psig.
Dr es den 2 an d 3                                              3 . 3 . 5. 1- 13                   Amendmen t No .

ECCS I ns trument ati on 3 . 3 . 5 .1 Table 3.3.5. 1- 1 (page 5 of 5)
Emergency Core Cooling System In str umentation APPLICABLE                             CONDITIONS MODES OR              RE QUI RED     REFERENCED OTHER               CHANNELS           FROM SPEC ! Fl ED               PER         REQUIRED    SURVEILLANCE           ALLOWA BLE FUNCTION                 CONDITIONS              FUNCTION       AC TION A. l REQUIREMENTS              VA LUE
: 5. ADS Trip Sys tem B
: a. Rea ctor Vesse l Wa ter               I,                   2               F      SR  3.3.5. 1 . 1   "' - 54 . 15 Level - Low Low                                                                   SR  3.3. 5 . 1.2   inc hes 2<H> >, 3 << 0 >                                     SR  3.3.5. 1. 3 SR  3.3.5 .1.5 SR  3.3.5 .1.6
: b. Drywe l l Pres s ure- Hi gh           1,                   2                      SR 3.3.5. 1. 2     s 1 .81 ps ig SR 3.3.5. 1.4 2<H> ). 3 ..*>                                      SR 3.3 .5.J.6 C. Automati c                            1'                                   G      SR 3.3. 5.1.5      s 11 3 seconds Depress urization                                                                 SR 3.3.5 .1.6 System Initiation             2 CHJ ) ,  3<< *>
Timer
: d. Core Sp ra y Pump                    1'                    2               G      SR 3.3.5 .1. 2     "' 101.5 psig Dis charge                                                                        SR 3.3.5 .1.4      and Pre ss ure- High              21"-' >, 3 <<b >                                    SR 3.3 .5.1.6      s 148 . 5 psig
: e. Low Pre ss ure Coolant                1,                                   G      SR 3.3.5. 1. 2     "' 101.5 psig Inje ction Pump                                                                   SR 3.3.5 .1.4      and Di sc ha rge                  2<"" >, 3 <<bJ                                      SR 3.3.5. 1. 6     s 148 .5 psig Pressure-High
: f. Automati c                           I,                                    G      SR 3.3.5. J.5      s 580 seco nd s Depre ss uri za tion                                                              SR 3 . 3 .5.1.6 Sys t em Low Low Wa t e r     2 c~ 1 ,   3 <* M Le ve l Ac tu at ion Timer (eb ) With reactor stea m dome press ure    > 150        psig .
Dr es den 2 and 3                                             3 . 3 . 5 . 1- 14                   Amendment No .

RPV Water I nven t ory Control In s trumentation 3.3 . 5 . 2 3.3       INSTRUMENTATION 3.3.5.2           Reactor Pressure Vessel                         (RPV) Water Inventory Contro l Instrumentation LCO       3.3.5.2                 The RPV Water Inventory Control instrumentation for each Function in Table 3 . 3 . 5 . 2-1 shall be OPERABLE .
APPLICABILITY:                    According to Table 3 . 3 . 5.2-1 .
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NO TE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is al lowed for each channel .
CONDITION                                             REQUIRED ACTION                                 COMPLETION TIME A. One or more channels                             A. l             Enter the Condition                          Immediately inoperable .                                                     referenced in Table 3 . 3 . 5 . 2-1 for the channel .
B. As required by                                   B. 1             Declare associated                           Immediately Required Action A . 1                                            penetration flow and referenced in                                               path(s) incapable of Table 3.3.5 . 2-1.                                               automatic isolation .
AND B. 2             Calculate DRAIN TIME .                       Immediately
: c. As required by                                    c.1          Place channel in trip .                          1 hour Required Action A . 1 and referenced in Table 3 . 3 . 5 . 2-1 .
D. As required by                                        D. 1         Restore channel to                              24 hours Required Action A . l                                          OPERABLE status .
and referenced in Table 3 . 3 . 5 . 2-1 .
(continued)           I Dre sden 2 and 3                                                    3 . 3 . 5 . 2-1                            Amendment No .

RPV Water Inventory Control Instrumentation 3 . 3. 5 . 2 ACTIONS CONDITION                                             REQUIRED ACTION                               COMPLETION TIME E. Required Action and                                  E. 1         Declare associated low                         Immediately associated Completion                                          pressure ECCS Time of Condition C or                                          injection/spray D not met .                                                    subsystem inoperable .
SURVEILLANCE REQUIREMENTS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NO TE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Refer to Table 3 . 3 . 5. 2-1 to determine which SRs apply for each ECCS Function .
SURVEILLANCE                                                                 FREQUENCY SR     3. 3 . 5. 2. 1             Perform CHANNEL CHECK .                                                            In accordance with the Surveillance Frequency Control Program SR      3 . 3. 5. 2 . 2            Perform CHANNEL FUNCTIONAL TEST .                                                  Jn accordance with the Surveillance Frequency Control Program Dresden 2 and 3                                                     3 . 3 . 5 . 2-2                          Amendment No .

RPV Water Inventory Control                In strumentation 3.3 . 5.2 Table 3.3 5.2*1 (Page 1 of 1)
RPV Water Inventory Control Instrumentation APPLICABLE                       CONDITIONS 110DES                        REFERENCED OR OTHER          REQUIRED         FROM SPECIFIED       CHANNELS PER     RE OU IRED   SURVE! L LANCE           ALLOWAB, E FUNCTION             CONDITIONS          FUNCTION     ACTION A .1   R&#xa3;0UIREl1ENTS               VALUE
: 1. Core Spray System
: a. Reactor Steam Dome          4, 5                 2             c       SR  3.3.5.2.2      ;;,: 308.5 psig Pressure-Low                                                                              and (Permissive)                                                                              s341.7 psig
: b. Core Sp1*ay Pump            4, 5               1 per           D       SR  3.3 . 5.2.2    ;;,: 802 gpm Discharge Flow-Low                          pump (a)                                      and (Bypass)                                                                                  5 992 gpm
: 2. Low Pressure Coolant Injection (LPCIJ System
: a. Reactot' Steam Dome         4, 5                2             c        SR  3.3.5.2.2      ;;,: 308.5 psig Pressure-Low                                                                              and (Permissive)                                                                              _ 341.7 psig
: b. Low Pressure Coolant        4, 5              1 per'          D        SR  3.3.5.2.2      :?:llOlgpm Injection Pump                             loop (a)
Discharge Flow-Low (Bypass J 3  Shutdown Cooling Syster~ I SJCJ fsolat1011
: a. Reactor Vesse I Water        (b)             per trip          B       SR  3.3.5.2.1      ;;,: 2. 65 incres Level Low                                   system                    SR  3.3 . 5.2.2
: 4. Reactor Water Cleanup System Isolation
: a. Reactor Vesse I Water        (b)            pe1* trip         B        SR  3.3.5 . 2.1    ;;,: 2. 65 inches Level-Low                                    system                    SR  3.3.5.2.2 (a)  Associated with an ECCS subsystem required to be OPERABLE by cCO   3.5.2, "RPV Wate1' lnvento*'y Control."
(b)  When automatic isolation of the associated penetration flow path(s) is credi~ed in calculating DRAIN Tl!ff Dre sden 2 and 3                                   3. 3 . 5.2 - 3                   Amendment No .

IC System Instrumentation 3 . 3 . 5 . .&3 3.3       INSTRUMENTATION 3 . 3 .5. -&---3        Isolation Condense r (IC) Syste m I nstr umentatio n LCO       3 . 3 . 5 . .&3          Four channe l s of Reactor Vesse l Pressure-High instrumentation shall be OPERABLE.
APPLICABILITY :                   MODE 1, MODES 2 and 3 with reac t or steam dome pressure > 150 psig .
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each channel .
CONDITION                                             REQUIRED ACTION                                COMPLETION TIME A.      One or more Reactor                             A. l             Declare IC Sys t em                         1 hour from Vessel Pressure-High                                             inoperable .                                discovery of channels inoperable.                                                                                         loss of IC initiation capability AND A.2             Place channel(s) in                          24 hours trip .
B.      Required Action and                             B.l             Declare IC System                            Immediately assoc i ated Completion                                         inoperable.
Time not met.
Dresden 2 and 3                                                     3 . 3 . 5 . 3-1                           Amendment No .

IC System Instrumentation 3 . 3.5 .iJ SURVEILLANCE REQUIREMENTS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the Reactor Vessel Pressure- High Function maintains IC initiation capability .
SURVEILLANCE                                                                 FREQUENCY S R 3 . 3 . 5 . iJ . 1             Perform CHANNEL FUNCTIONAL TEST .                                                  In accordance with the Surveillance Frequency Control Program SR      3.3.5 .iJ .2               - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - -
Not required for the time delay portion of the channel .
Perform CHANNEL CALIBRATION. The                                                    In accordance Allowable Value shall be$ 1068 psig.                                               with the Surveillance Frequency Control Program SR      3.3 . 5 .iJ . 3           Perform CHANNEL CALIBRATION for the time                                            In accordance delay portion of the channel . The                                                 with the Allowable Value s hall be$ 15 seconds.                                             Surveillance Frequency Control Program SR      3.3.5. iJ . 4             Perform LOGIC SYSTEM FUNCTIONAL TEST .                                              In accordance with the Surveillance Frequency Control Program Dre sden 2 and 3                                                    3.3.5.3-2                                 Amendment No .

Pr ima ry Cont ainment I sol at i on In s trumenta t i on 3.3.6. 1 Table 3.3.6 .1 - 1 (page 3 of 3)
Primary Containment Iso lation Instrumentation APPLICABLE                     CONDITIONS MODES OR       REQU I RED     REFERENCED OTHER        CHANNELS           FROM SPECIFIED      PER TRIP        REOUI RED   SURVE ILLANCE              ALLOWA BLE FUNCTION              CONDITIONS        SYSTEM       AC TION C. l REQUIREMENTS                 VA LUE 5_ Reacto r Wa t e r Cleanup Sys tem Iso lation
: a. SLC Sys tem Initiati on       1,2 ,3                            H      SR  3 . 3 .6 . 1. 7  NA
: b. Rea ctor Vesse l Water        1,2, 3            2                      SR  3.3.6. 1.1       ;,, 2.65 inche s Le ve l - Low                                                          SR  3.3. 6.1.2 SR  3 . 3 .6.1.3 SR  3.3 .6.1.6 SR  3.3.6. 1. 7
: 6. Shutdown Cooling System Isola tion a_    Rea ctor Vesse 1              1, 2. 3           2                      SR 3.3 .6 . 1.2     s 114 .1 ps i g Pre ss ure - High                                                      SR 3.3.6 .1.6         <Loop 1, SR 3.3.6. 1. 7       Reactor Wide Rang e Pre ss ure) s 110.4 ps ig
                                                                                                         <loop 2, Re actor Pre ss ure Feedwa ter Control)
: b. Reactor Vesse l Wat er                                                 SR  3 . 3.6. 1.1    ;,, 2.65 inches Leve l - Low                                                           SR  3.3 .6 .1 . 2 SR  3.3 .6 . 1. 3 SR  3.3 .6 . 1.6 SR  3.3. 6 . 1. 7
( h)
Dres den 2 and 3                                      3 . 3 . 6 . 1-8                     Amendment No .

Secondary Containment I so lation Instrumentation
: 3. 3. 6. 2 Tab l e 3.3.6.2 - 1 (page 1 of ll Secondary Con t ai nment Isolation In strumentation APPLIC ABLE MOD ES OR              REQUIRED OTHER               CHANNELS SPEC! FI ED                PER          SUR VE ILLANCE         ALLOWAB LE FUN CTI ON              CONDITION S           TRIP SYSTEM        REQUJ REMENTS            VA LU E
: 1. Reacto r Vesse l Water               1,2 , 3,                   2          SR   3.3.6.2. 1     <: 2.65   in ches Leve l - Low                          -+;;.+                               SR   3.3.6.2.2 SR   3.3.6.2.3 SR   3.3.6.2.5 SR   3.3.6.2.6
: 2. Drywell - Pressure- High              1' 2 ,3                   2          SR   3.3.6 . 2.2      ,; 1. 94 psi g SR   3 . 3.6.2. 4 SR   3.3.6.2.6
: 3. Reac t or Building Exhaust           1,2 , 3,                   2          SR   3.3.6.2. 1      ,; 14.9 mR/ hr Radiation- High                     Ca l.,+-9+                             SR   3.3.6.2.2 SR   3.3.6 . 2.4 SR   3.3.6.2.6
: 4. Refueling Floor                      1 , 2 '3'                  2          SR   3.3.6 . 2. l     ,; 100 mR / hr Radiation- High                     (a l.,+-9+                             SR   3.3.6.2.2 SR   3.3.6.2.4 SR   3.3.6 . 2.6
( ~a l During mo vement of recentl y irradiated fuel as semblie s in secondary containment.
Dresden 2 and 3                                           3 . 3. 6 . 2-5                    Amendment No.

CREV System Instrumentation 3 . 3. 7 . 1
: 3. 3      INSTRUMENTATION 3.3.7.1           Control Room Emergency Ventilation CCREV) System Instrumentation LCO       3.3.7 . 1               Two channels of the Reactor Building Ventilation System-High High Radiation Alarm Function shall be OPERABLE .
APPLICABILITY :                   MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, D1::1ri ng opera ti ens 11i th a potential for draining the reactor vessel ( OPDRVs) ..
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each channel .
CONDITION                                             REQUIRED ACTION                               COMPLETION TIME A.      One or more channels                            A. 1            Declare CREV System                         1 hour from inoperable.                                                     inoperable.                                 discovery of loss of CREV System Instrumentation alarm capability in both trip systems A.2             Restore channe 1 to                         6 hours OPERABLE status .
(continued)
Dresden 2 and 3                                                     3.3 . 7. 1-1                             Amendment No .

ECCS-Operating
: 3. 5 . 1 3.5       EMERGENCY CORE COOLING SYSTEMS (ECCS) , REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3 . 5. 1      ECCS-Operating LCO       3 . 5.1                 Each ECCS injection/spray subsystem and the Automatic Depressurization System (AOS) function of five relief valves shall be OPERABLE .
APPLICABILI TY:                   MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves ar e not required to be OPERABLE with reactor steam dome pressure ~ 150 psig .
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3. 0. 4.b is not applicable to HPCI .
CONDITION                                            REQUIRED ACTION                             COMPLETION TIME A.      One Low Pressure                                  A. l           Restore LPCI pump to                      30 days Coolant Injection                                                OPERABLE status .
(LPCI) pump inoperable .
B.      One LPCI subsystem                                B. 1           Restore low pressure                      7 days inoperable for reasons                                           ECCS injection/spray other than Condition A.                                          subsystem to OPERABLE status .
         .QR One Core Spray subsystem inoperable .
: c.       One LPCI pump in each                             C. 1           Restore one LPCI                          7 days subsystem i noperab l e .                                        pump to OPERABLE status.
(continued)
Dresden 2 and 3                                                       3. 5. 1-1                             Amendment No .

EGGS Sh1:1tdo*1mRPV Water Inventory Contra 7
: 3. 5. 2 3.5     EMERGENCY CORE COOLING SYSTEMS (ECCS) , REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYST EM 3.5 . 2    ~RPV        Water Inventory Control Si:n.it8s1m LCO     3 . 5.2             DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be~ 36 hours.
4-wG---One low pressure ECCS injection/spray subsystem& shall be OPERABLE .
APP LI CAB I LIT Y:         MODES 4 and 5.,
ACTIONS CONDITION                           REQUIRED ACT! ON                    COMPLETION TIME A.     ~R equired           ECCS           A. l      Restore required ECCS             4 hours injection/spray                              injection/spray subsystem inoperable.                        subsystem to OPERABLE status.
B.      Required Action and                B.l       Initiate action to                Immediately associated Completion                        establish a method of Time of Condition A not                      water injection capable met .                                        of operating without offs i te electrical power.st.ispens spePatisns 1,1i tl:i a petentjal f:ep 8pajnjn13 tl:ie PeaeteP vessel
                                                      \ GPQRlJ&)
: c.     +1,19 PeEjt.iiPeS ff CS             C.l       InHjate aetjen te                 Immesjately i n;jeeti en.lspra;Y                        st.ispens GPQRVs .
        &t.iesystem& inepePaele.
MW G. 2      RestePe ene P9Ejt.iiPeS           4 R8YP5 EGGS i n;j est i en,lsp ra;;*
5YQ5:)1 StelR te GPERMnE statt.is .
(continued)
Dresden 2 and 3                                    3.5 . 2-1                        Amendment No .

EGGS Shb1tdo 1mRPV Water Inventory Control 1
: 3. 5. 2 ACTIONS CONDITION            REQUIRED ACTION              COMPLETION TIME C. DRAIN TIME < 36 hours c. 1     Verify secondary          4 hours and;::>: 8 hours .             containment boundary is capable of being established in less than the DRAIN TIME .
C. 2     Verify each secondary     4 hours containment penetration flow path is capable of being isolated in less than the DRAIN TIME .
C. 3     Verify one standby        4 hours gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME .
(continued)
Dresden 2 and 3                 3 . 5. 2-2               Amendment No .

EGGS ShYtd01*mRPV Water Inventory Control 3.5 . 2 ACTIONS CONDITION              REQUIRED AC TI ON            COMP LE TI ON TI ME D. DRAIN TIME < 8        0.1      ------- NOTE --------
hours . Required               Required ECCS Action C. 2 and                injection/spray associated Completion          subsystem or Time not met .                 additional method of water injection shall be capable of operating without offsite electrical power .
Initiate action to       Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for
                                    ~ 36 hours . restore secondary containment to OPERABLE status.
D. 2     Initiate action to       Immediately establish secondary containment boundaryinitiate action to restore one standby gas treatment subsystem to OPERABLE status ..
D. 3     Initiate action to       Immediately restore isolation isolate each capability in each reqYired secondary containment penetration flow path
                                    ~or verify it can be manually isolated from the control room .
Dresden 2 and 3                 3 . 5. 2-3               Amendment No .

EGGS Shbltdo wnRPV Water Inventory Contra 7 3.5.2 CONDITION       REQUIRED AC TI ON           COMPLETION TIME 0.4     Initiate action to        Immediately verify one standby gas treatment system is capable of being placed in operation.
(cont i nued)
Dresden 2 and 3         3 . 5 . 2-4              Amendment No .

EGGS Shbltdo*,mRPV Water Inventory Control 3 . 5.2 ACTIONS E. Required Action and            E.l         Init i ate action to      Immediately associated Completion                      restore DRAIN TIME to Time of Condition C or D                   ~ 36 hours.
not met.
DRAIN TIME < 1 hour.
SURVEILLANC E REQUIR EMENTS SURV EILLANCE                                    FREQU ENCY SR  3.5.2.1       Verify DRAIN    TIME~  36 hours .                        In accordance with the Surveillance Frequency Control Program SR  3.5.2 .+2     Verify, for for easRthe required ECCS injection/         In accordance spray subsystem, the:                                    with the Surveillance
: a. Suppression pool water level is                    Frequency
                         ~  10 ft 4 inches; or                              Control Program b*                       "':'TC:-
Only one reqYired ECC5 injection/spray sblb&y&tem may take sredit for tRis option dblrin&sect; OPDRVs .
Contaminated condensate storage tanks water volume is~ 140,000 available gallons.
SR  3 . 5. 2. iJ Verify, for ~the required ECCS                            In accordance injection/spray subsystem, locations susceptible          with the to gas accumulation are sufficiently filled with          Surveillance water.                                                    Frequency Control Program (continued)
Dresden 2 and 3                             3.5 . 2-5                  Amendment No .

EGGS Shb1tdo 11nRPV Water Inventory Control 1
3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                          FREQUENCY SR   3 . 5 . 2 .J.4 - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - -
Not required to be met for system vent flow paths opened under administrative control .
Verify ~for the required ECCS                                                      In accordance injection/spray subsystem each manual,                                            with the power operated, and automatic valve in the                                         Surveillance flow path, that is not locked, sealed, or                                           Frequency otherwise secured in position, is in the                                           Control Program correct position.
SR   3 . 5. 2 . 5   Operate the required ECCS injection/spray                                          In accordance subsystem through the recirculation line                                           with the for ~ 10 minutes .                                                                Inservice Testing Program SR   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                                         Inservice an actual or simulated isolation signal.                                           Testing Program SR   3.5 . 2.7      - - - - - - - - - - - - - - - - - - NO TE - - - - - - - - - - - - - - - - -
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray                                           In accordance subsystem can be manually operated .                                               with the Survei I lance Frequency Control Program SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.5.2.4              Verify each reqblired EGGS j:Jblmj:J develo13s                                 In accordance the s13ecified flow rate against a test line 13ressblre                                               with the corres13onding to the s13ecified reactor 13ressblre.                                                   Inservice TEST LINE                         PRESSURE                                                            Testing Program NO. CORRESPONQING OF     TO A REACTOR SYSTEM                  FLO';,' R/\TE             :E!lM:E&#xa3; PRESSURE OF Dresden 2 and 3                                            3 . 5. 2-6                              Amendment No .

IC System
: 3. 5.3
: 3. 5      EMERGENCY CORE COOLING SYSTEMS (ECCS) , REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5 . 3       IC System LCO       3 . 5.3                 The IC System shall be OPERABLE .
APPLICABILITY :                   MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig .
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3 . 0.4.b is not applicable to IC .
CONDITION                                             REQUIRED ACTION                               COMPLETION TIME A.      IC System inoperable .                          A. l            Verify by                                   Immediately administrative means High Pressure Coolant Injection System is OPERABLE .
A.2             Restore IC System to                        14 days OP ERABLE status .
B.      Required Action and                             - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion                           LCO 3.0.4.a is not applicable Time not met.                                   when entering MODE 3.
B.l             Be in MODE 3.                               12 hours Dresden 2 and 3                                                       3.5.3-1                                 Amendment No.

PC I Vs 3 . 6.1.3 ACTIONS CONDITION              REQUIRED ACTION                        COMPLETION TIME C.   (continued)          C. 2    - - - - - - - -NOTES - - - - - - - -
: 1. Isolation devices in high radiation areas may be verified by use of administrative means.
: 2. Isolation devices that are a locked, sealed, or otherwise secured may be verified by use of administrative means.
Verify the affected                  Once per 31 days penetration flow path is isolated .
D. MSIV leakage rate     D.l     Restore leakage rate                 8 hours not within limit.             to within limit.
E. Required Action and  E. 1    Be in MODE 3.                        12 hours associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.      E.2     Be in MODE 4.                        36 hours (continued)
Dresden 2 and 3                 3.6.1.3-5                           Amendment No . 185/180

PC I Vs 3 . 6 . 1.3
/\CTIONS CONOITION                                         REQUIRED                  /l.CTIO~l                       COMPLETION TIME f
* Re q1:1 i r e d Act i on a nd               -r-f-.-.+l- ----:1:-I1+n+-ittrl-H.a,,..t~e~attC:ritrli-tOl-Hn~t.Y.o     Immediately associated Completion                                         s1:1spend operations Time of Condition A,                                          with a potential for B, C, or 0 not met for                                        draining the reactor PCIV(s) req1:1ired to be                                     vessel (OPDRVs).
OPERABLE d1:1rin9 MOOE 4
      ~                                            :GR f.2             Initiate action to                                     Immediately restore valve(s) to OPERABLE stat1:1s.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                                           FREQUENCY SR  3.6.1.3.1              - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - -
Not required to be met when the 18 inch primary containment vent and purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the drywell vent and purge valves and their associated suppression chamber vent and purge valves are not open simu ltaneou sly .
Verify each 18 inch primary containment                                                         In accordance vent and purge valve, except the torus                                                         with the purge valve, is closed.                                                                        Surveillance Frequency Control Program (continued)
Dresden 2 and 3                                               3.6.1.3-6                                                Amendment No.

Secondary Containment
: 3. 6. 4 . 1 3.6    CONTAINMENT SYSTEMS 3.6 . 4 .l   Secondary Containment LCO    3. 6.4 . 1    The secondary containment shall be OPE RABL E.
APPLICABILITY:       MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary con t ainment, Ol:lring operations 11ith a potential for draining the reactor vessel ( OPDRVs) .
ACTIONS CONDITION                            REQUIRED ACTION                            COMPLETION TIM E A. Secondary containment       A. l            Restore secondary                        4 hours inoperable in MODE 1,                      containment to 2, or 3 .                                  OPERABLE status .
B. Required Action and        - - - - - - - - - - - - NOTE- - - - - - - - - - - - -
associated Completion       LCO 3 . 0 . 4. a is not applicable Time of Condition A         when entering MODE 3 .
not met .
B. l            Be in MODE 3 .                           12 hours C. Secondary containment       C. l             - - - - - - - - NOT E- - - - - - - - -
i noperable during                         LCO 3 . 0 . 3 is not movement of recently                        applicable.
irradiated fuel assemblies in the secondary containment                       Suspend movement of                      Immediately or dl:lring OPDRVs .                        recently irradiated fuel assemblies in the secondary containment .
C.2             Initiate action to                       Immediately sl:lspend OPORVs .
Dresden 2 and 3                              3 . 6 . 4 . 1-1                           Amendment No .

SCI Vs 3.6 . 4 . 2 3.6   CONTAINMENT SYSTEMS
: 3. 6.4 . 2 Secon dary Containment Isolation Valves (SC I Vs)
LCO   3.6.4 . 2     Each SCIV shall be OP ERABLE.
APPLICABILITY:      MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel ( OPDRVs) .
ACTIONS NOTES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
: 1. Penetration flow path s may be unisolated intermittently under administrative contr ol s .
: 2. Separate Condition entry is allowed for each penetration flow path .
: 3. Enter applicable Conditions and Required Actions for sys tems made inoperable by SCIVs .
CONDITION                     REQUIRED ACTION                              COMPLETION TIME A. One or more                A.l        Isolate the affected                       8 hour s penetration flow path s              penetration flow path with one SCIV                        by use of at least inoperable.                          one closed and de-activated automatic valve, closed manual valve, or blind flange .
(continued)
Dre sden 2 and 3                      3 . 6. 4.2-1                            Amendment No .

SCI Vs 3.6.4.2 ACTIONS CONDITION                 REQUIRED ACTION           COMPLETION TIME C. Required Action and   C. l      Be in MODE 3 .          12 hours associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.      C.2       Be in MODE 4.           36 hours D. Required Action and   D. l      --------NOTE---------
associated Completion           LCO 3.0 . 3 is not Time of Condition A             applicable .
or B not met during movement of recently irradiated fuel                 Suspend movement of     Immediately assemblies in the               recently irradiated secondary containment           fuel assemblies in or d~rin&sect; OPDRVs .              the second ary containment.
D. 2      Initiate action to      Immediately s~sf)end  OPDRVs.
Dresden 2 and 3                  3 . 6.4.2-3              Amendment No .

SGT System 3 . 6.4 . 3 3.6    CONTAINMENT SYSTEMS 3.6 . 4 . 3  Standby Gas Treatment (SGT) System LCO    3.6.4.3        Two SGT subsystems sha ll be OPERABLE .
APPLICABILITY:        MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, D1:1rin&sect; operations *,1ith a potential for drainin&sect; the reactor vessel ( OPDRVs) .
ACTIONS CONDITION                            REQUIRED ACTION                            COMPLETION TIME A. One SGT subsystem            A. 1             Restore SGT                             7 days inoperable.                                  subsystem to OP ERABLE status .
B. Re qui red Action and        - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion         LCO 3 . 0 . 4 . a is not applicable Time of Condition A          when entering MODE 3.
not met in MODE 1, 2, or 3.
B.l              Be in MODE 3 .                          12 hours C. Required Action and           - - - - - - - - - - - - NOTE - - - - - - - - - - - -
associated Completion         LCO 3.0 . 3 is not applicable.
Time of Condition A not met during movement of recently         C. 1             Place OPERABLE SGT                      Immediately irradiated fuel                               subsystem in assemblies in the                             operation .
secondary containment or d1:1rin&sect; OPDRVs .         Q.R (continued)
Dresden 2 and 3                                 3.6 . 4 . 3-1                             Amendment No.

SGT System 3.6.4.3 ACTIONS CONDITION                      REQUIRED ACTION                            COMPLETION TIME C.   (continued)           C. 2....+/-       Suspend movement of                     Immediately recently irradiated fuel assemblies in secondary containment .
C. 2.2          IRitiate actioR to                      hrniedi atel,y SblspeRd OPDRl/s .
D. Two SGT subsystems    D. l            Restore one SGT                         1 hour inoperable in MODE 1,                 subsystem to 2, or 3 .                             OPERABLE status .
E. Required Action and   - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion LCO 3 . 0 . 4 . a is not applicable Time of Condition D   when entering MODE 3 .
not met.
E .1            Be in MODE 3 .                          12 hours F. Two SGT subsystems     F. 1            --- - ----NOTE--------
inoperable during                     LCO 3 . 0.3 is not movement of recently                   applicable .
irradiated fuel assemblies in the secondary containment                 Suspend movement of                     Immediately or dblriRg OPDRVs .                    recently irradiated fuel assemblies in secondary containment .
F. 2            IRitiate actioR to                      Immediately sblspeRd OPDRl/s.
Dresden 2 and 3                        3. 6. 4 . 3-2                             Amendment No .

CREV System 3.7 . 4
: 3. 7     PLANT SYSTEMS 3 . 7. 4   Contro l Room Emergency Ventilation CCREV) System LCO     3.7.4         The CREV System shall be OPERABL E.
                      - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - -
The main control room envelope (CRE) boundary may be opened intermit t ently under administrative control .
APPLICABILITY :       MOD ES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, Duri n9 operations 'iii th a potential for drai ni n9 the reactor
                               'l essel ( OPDRVs) .
ACTIONS CONDITION                                      REQUIRED ACTION                         COMPLETION TIME A.      CREV System inoperable               A.1             Restore CREV System                   7 days in MODE 1' 2' or 3 for                               to OPERABLE status.
reasons other than Condition c.
B.      Required Action and                  - - - - - - - - - - - -NOTE- - - - - - - - - - - - -
associated Completion                LCO 3 . 0. 4.a is not applicable Time of Condition A                   when entering MODE 3 .
not met in MODE 1' 2'                ------ ------- - ---- - - - - - ---- --
or 3.
B. 1            Be in MODE 3.                         12 hours (continued)
Dresden 2 and 3                                           3 . 7.4-1                             Amendment No.

CREV System
: 3. 7. 4 ACTIONS (continued)
CONDITION                       REQUIRED ACTION                           COMPLETION TIME C. CR EV system inoperable  C.l            Initiate action to                     Immediately due to inoperable CRE                   implement mitigating boundary in MODE 1, 2,                  actions .
or 3 .
C. 2           Verify mitigating                      24 hours actions ensure CRE occupant exposures to radiological, chemical , and smoke hazards wi 11 not exceed limits .
C. 3            Restore CRE boundary                   90 days to OPERABLE status.
D. Required Action and     D. l            Be in MODE 3 .                         12 hours associated Completion Time of Condition C not met in MODE 1, 2, or 3.                    D.2             Be in MODE 4 .                         36 hours E. CREV System inoperable    ------------NOTE-------------
during movement of        LCO 3.0 . 3 is not applicable .
recently irradiated      -----------------------------
fuel assemblies in the secondary containment    E .1            Suspend movement of                    Immediately or dYring OPDRVs .                       recently irradiated fuel assemblies in the secondary containment .
CREV System inoperable due to an inoperable     M>m CRE boundary during movement of recently     ~E~.~2~~__._,rn~1r*t~1H*a~trle~a~c~trli~o~n__.,t~o     Immediately irradiated fuel                          sYspend OPDRVs .
assemblies in the secondary containment or dYring OPDRVs .
Dresden 2 and 3                          3 . 7. 4-2                              Amendment No.

Control Room Emergency Ventilation AC System 3 . 7.5 3.7     PLANT SYSTEMS
: 3. 7. 5     Control Room Emergency Ventilation Air Conditioning (AC) System LCO     3 . 7. 5        The Control Room Emergency Ventilation AC System shall be OPERABLE .
APPLICABILITY :         MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, Ol:H'i n&sect; operati ens 'n'i th a potential for drai ni n&sect; the reactor vessel ( OPDRVs) .
ACTIONS CONDITION                             REQUIRED ACTION                          COMPLETION TIME A. Control Room Emergency          A.l             Restore Control Room                   30 days Ventilation AC System                          Emergency Ventilation i noperable in MODE 1,                         AC System to OPERABLE 2, or 3.                                        status.
B. Required Action and             - - - - - - - - - - - - NOTE- - - - - - - - - - - - -
associated Completion           LCO 3.0 . 4.a is not applicable Time of Condition A             when entering MODE 3 .
not met in MODE 1, 2, or 3.
B.l             Be in MODE 3 .                         12 hours C. Control Room Emergency          - - - - - - - - - - - - NOTE- - - - - - - - - - - - -
Ventilation AC System           LCO 3 . 0.3 is not applicable .
inoperable during movement of recently irradiated fuel                 C. l            Suspend movement of                    Immediately assemblies in the                               recently irradiated secondary containment                           fuel assemblies in or    d~rin&sect;  OPDRVs .                          the secondary con t ainment .
C.2             Initiate action to                     Immediately s~spend     OPDRVs.
Dresden 2 and 3                                    3 . 7. 5-1                             Amendment No .

AC Sources-Shutdown 3.8 . 2 ACTIONS CONDITION            REQUIRED ACTION                COMPLETION TIME A.   (continued)    A. 2 . 2     Suspend movement of         Immediately recently irradiated fuel assemblies in the secondary containment .
A.2 . 3      IRitiate actioR to          Immediately SYSpeRd opera t iORS
                                 'n 'ith a poteRtial for draiRiR&sect; the reactor vessel ( OPDRVs) .
A. 2 . 43    In i ti ate act i on to     Immediately restore required offsite power circuit to OP ERABLE status .
(continued)
Dresden 2 and 3                3.8 . 2-3                  Amendment No .

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION         REQUIRED ACTION             COMPLETION TIME B. One required DG B. 1   Suspend CORE              Immediately inoperable.            ALTERATIONS.
B. 2   Suspend movement of       Immediately recently irradiated fuel assemblies in secondary containment.
B.3    Initiate action to        Immediately st1spend OPDRVs.
B.43   Initiate action to        Immediately restore required DG to OPERABL E status .
Dresden 2 and 3            3.8.2-4                 Amendment No .

DC Sources-Shutdow n 3.8 . 5 ACTIONS COND IT ION                                      REQUIRED ACTION                              COMPL ETION TI ME A.   (continued)                              A.2.3           Initiate action to                        Immediately s~spend      operations 11i th a potential for draining the reactor vessel.
A. 2 . 43       I n i t i ate a ct i on to                I mmedi at e ly restor e r equ i r ed DC electrical power subsystems to OPERABLE status .
SURV EI LLANCE REQU I REMENTS SURVEILLANCE                                                              FREQUENCY SR   3.8.5.1        - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - -
The following SR s are not required to be performed for the 250 voe electrical power subsystem: SR 3 . 8.4.2 and SR 3 . 8.4.4 .
For DC electrical power subsystems required                                          In accordance to be OP ERA BLE the following SRs are                                               wi t h applicable applicable :                                                                         SRs SR 3.8.4.1, SR 3.8 . 4.2, SR 3.8.4.3, and SR 3 . 8.4.4 .
Dresden 2 and 3                                            3 . 8 . 5-2                            Amendment No .

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION                          REQUIRED ACTION                       COMPLETION TIME A.   (continued)                 A. 2 . 2       Suspend movement of                Immediately recently irradiated fuel assemblies in the secondary containment.
A. 2. 3        Initiate action to                 IFRFRediately sYspend operations
                                                *,1 i th a potent i al for draining the reactor vessel.
A. 2 . 43      I n i t i a t e a ct i on s to     Immediately restore required AC and DC electrical power distribution subsystems to OPERABLE status .
A.2 .-94      Declare associated                  Immediately required shutdown cooling subsystem(s) inoperable and not in operation.
SURVEILLANCE REQUIREMENTS SURV EILLANCE                                               FREQUENCY SR  3.8 . 8 . 1   Verify correct breaker alignments and                             In accordance voltage to required AC and DC electrical                         with the power distribution subsystems .                                   Surveillance Frequency Control Program Dresden 2 and 3                             3 . 8.8-2                           Amendment No.

Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 3 - REVISED TECHNICAL SPECIFICATIONS PAGES TOC Page i                      3.3.5.1-11                      3.6.1.3-5 TOC Page ii                      3.3.5.1-12                      3.6.1.3-6 1.1-2                         3.3.5.2-1                      3.6.1.3-7 1.1-3                         3.3.5.2-2                      3.6.1.3-8 1.1-4                         3.3.5.2-3                      3.6.4.1-1 1.1-5                         3.3.5.3-1                      3.6.4.2-1 1.1-6                         3.3.5.3-2                      3.6.4.2-3 1.1-7                         3.3.6.1-8                      3.6.4.3-1 3.3.5.1-2                       3.3.6.2-5                      3.6.4.3-2 3.3.5.1-3                       3.3.7.1-1                       3.7.4-1 3.3.5.1-4                        3.5.1-1                        3.7.4-2 3.3.5.1-5                        3.5.2-1                        3.7.5-1 3.3.5.1-6                        3.5.2-2                        3.8.2-2 3.3.5.1-7                        3.5.2-3                        3.8.2-3 3.3.5.1-8                        3.5.2-4                        3.8.5-1 3.3.5.1-9                        3.5.2-5                        3.8.5-2 3.3.5.1-10                        3.5.3-1                        3.8.8-2

TABLE OF CONTENTS
: 1. 0       USE AND APPLICATION 1.1            Definitions .............................................. 1.1-1
: 1. 2           Logical Connectors ....................................... 1.2-1
: 1. 3           Completion Times ......................................... 1. 3-1 1.4            Frequency ................................................ 1.4-1 2.0        SAFETY LIMITS CSLs) 2.1           SLs ...................................................... 2.0-1 2.2           SL Violations ............................................ 2.0-1 3.0        LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ........ 3.0-1 3.0        SURVEILLANCE REQUIREMENT CSR) APPLICABILITY ................. 3.0-4 3.1        REACTIVITY CONTROL SYSTEMS 3 .1.1        SHUTDOWN MARGIN CSDM) .................................... 3.1.1-1 3 .1. 2        Reactivity Anomalies ..................................... 3.1.2-1 3 .1. 3       Control Rod OPERABILITY .................................. 3.1.3-1 3 .1.4        Control Rod Scram Times .................................. 3.1.4-1 3 .1. 5        Control Rod Scram Accumulators ........................... 3.1.5-1 3 .1. 6        Rod Pattern Control ...................................... 3.1.6-1 3 .1. 7       Standby Liquid Control (SLC) System ...................... 3.1.7-1 3 .1.8        Scram Discharge Volume (SDV) Vent and Drain Valves ....... 3.1.8-1 3.2        POWER DISTRIBUTION LIMITS 3.2.1         AVERAGE PLANAR LINEAR HEAT GENERATION RATE CAPLHGR) ...... 3.2.1-1 3.2.2         MINIMUM CRITICAL POWER RATIO (MCPR) ...................... 3.2.2-1 3.2.3          LINEAR HEAT GENERATION RATE (LHGR) ...................... 3.2.3-1 3.3        INSTRUMENTATION 3.3.1.l       Reactor Protection System (RPS) Instrumentation .......... 3.3.1.1-1 3.3.1.2       Source Range Monitor (SRM) Instrumentation ............... 3.3.1.2-1 3.3.1.3       Dscillation Power Range Monitor (OPRM) Instrumentation ... 3.3.1.3-1
: 3. 3. 2 .1    Control Rod Block Instrumentation ........................ 3.3.2.1-1 3.3.2.2        Feedwater System and Main Turbine High Water Level Trip Instrumentation ................................... 3.3.2.2-1 3.3.3.1        Post Accident Monitoring (PAM) Instrumentation ........... 3.3.3.1-1 3.3.4.1       Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation ................... 3.3.4.1-1
: 3. 3. 5. 1     Emergency Core Cooling System CECCS) Instrumentation ..... 3.3.5.1-1 3.3.5.2       Reactor Pressure Vessel CRPV) Water Inventory Control I nst rumen tat i on ........................................ 3 . 3 . 5 . 2 - 1 3.3.5.3        Isolation Condenser (IC) System Instrumentation .......... 3.3.5.3-1 3.3.6.1       Primary Containment Isolation Instrumentation ............ 3.3.6.1-1 3.3.6.2       Secondary Containment Isolation Instrumentation .......... 3.3.6.2-1 3.3.6.3       Relief Valve Instrumentation ............................. 3.3.6.3-1
: 3. 3. 7 .1    Control Room Emergency Ventilation (CREV) System Instrumentation ........................................ 3.3.7.1-1 3.3.7.2       Mechanical Vacuum Pump Trip Instrumentation .............. 3.3.7.2-1 (continued)
Dresden 2 and 3                                                   Amendment No.

TABLE OF CONTENTS 3.3       INSTRUMENTATION (continued) 3.3.8.1       Loss of Power (LOP) Instrumentation ...................... 3.3.8.1-1 3.3.8.2      Reactor Protection System (RPS) Electric Power Monitoring ............................................. 3.3.8.2-1 3.4       REACTOR COOLANT SYSTEM (RCS) 3.4.1        Recirculation Loops Operating ............................ 3.4.1-1 3.4.2        Jet Pumps ................................................ 3.4.2-1 3.4.3        Safety and Relief Valves ................................ 3.4.3-1 3.4.4        RCS Operational LEAKAGE .................................. 3.4.4-1 3.4.5        RCS Leakage Detection Instrumentation .................... 3.4.5-1 3.4.6        RCS Specific Activity .................................... 3.4.6-1 3.4.7        Shutdown Cooling (SOC) System-Hot Shutdown ............... 3.4.7-1 3.4.8        Shutdown Cooling (SOC) System-Cold Shutdown .............. 3.4.8-1 3.4.9        RCS Pressure and Temperature CP/T) Limits ................ 3.4.9-1 3.4.10       Reactor Steam Dome Pressure .............................. 3.4.10-1 3.5       EMERGENCY CORE COOLING SYSTEMS CECCS), REACTOR PRESSURE VESSEL CRPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.1        ECCS-Operati ng ........................................... 3. 5 .1-1 3.5.2        RPV Water Inventory Control .............................. 3.5.2-1 3.5.3        IC System ................................................ 3.5.3-1 3.6       CONTAINMENT SYSTEMS 3.6.1.1      Primary Containment ...................................... 3.6.1.1-1 3.6.1.2      Primary Containment Air Lock ............................. 3.6.1.2-1 3.6.1.3      Primary Containment Isolation Valves (PCIVs) ............. 3.6.1.3-1 3.6.1.4      Drywell Pressure ......................................... 3.6.1.4-1 3.6.1.5      Drywell Air Temperature .................................. 3.6.1.5-1 3.6.1.6      Low Set Relief Valves .................................... 3.6.1.6-1 3.6.1.7      Reactor Building-to-Suppression Chamber Vacuum Breakers ............................................... 3.6.1. 7-1 3.6.1.8      Suppression Chamber-to-Drywell Vacuum Breakers ........... 3.6.1.8-1 3.6.2.1      Suppression Pool Average Temperature ..................... 3.6.2.1-1 3.6.2.2      Suppression Pool Water Level ............................. 3.6.2.2-1 3.6.2.3      Suppression Pool Cooling ................................. 3.6.2.3-1 3.6.2.4      Suppression Pool Spray ................................... 3.6.2.4-1 3.6.2.5      Drywell-to-Suppression Chamber Differential Pressure ..... 3.6.2.5-1 3.6.3.1      Primary Containment Oxygen Concentration ................. 3.6.3.1-1
: 3. 6 .4.1    Secondary Containment .................................... 3.6.4.1-1 3.6.4.2      Secondary Containment Isolation Valves (SCIVs) ........... 3.6.4.2-1 3.6.4.3      Standby Gas Treatment (SGT) System ....................... 3.6.4.3-1 (continued)
Dresden 2 and 3                          ii                 Amendment No.

Definitions 1.1 1.1   Definitions  (continued)
CHANNEL FUNCTIONAL TEST      A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.
CORE ALTERATION              CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. The following exceptions are not considered to be CORE ALTERATIONS:
: a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);
and
: b. Control rod movement, provided there are no fuel assemblies in the associated core cell.
Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.
CORE OPERATING LIMITS        The COLR is the unit specific document that REPORT (COLR)                provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.
DOSE EQUIVALENT I-131        DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The dose conversion factors used for this calculation shall be the inhalation committed dose conversion factors in Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1989.
(continued)
Dresden 2 and 3                        1.1-2              Amendment No.

Definitions 1.1 1.1   Definitions 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.g., seismic event, loss of normal power, single human error),
for all penetration flow paths below the TAF except:
: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured 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
: 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             1.1-3               Amendment No.

Definitions 1.1 1.1   Definitions DRAIN TIME        c)   The penetration flow paths required to be (continued)        evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d)   No additional draining events occur; and e)   Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
LEAKAGE           LEAKAGE shall be:
: a. Identified LEAKAGE
: 1. LEAKAGE into the drywe 11, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or
: 2. LEAKAGE into the drywel l atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;
: b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;
: c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE; and
: d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.
(continued)
Dresden 2 and 3            1.1-4                Amendment No.

Definitions 1.1 1.1   Definitions  (continued)
LINEAR HEAT GENERATION       The LHGR shall be the heat generation rate per RATE (LHGR)                  unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.
LOGIC SYSTEM FUNCTIONAL      A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST                         of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.
MINIMUM CRITICAL POWER       The MCPR shall be the smallest critical power RATIO (MCPR)                 ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE                         A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE-OPERABILITY         A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
(continued)
Dresden 2 and 3                       1.1-5                Amendment No.

Definitions 1.1 1.1   Definitions  (continued)
RATED THERMAL POWER          RTP shall be a total reactor core heat transfer (RTP)                        rate to the reactor coolant of 2957 MWt.
REACTOR PROTECTION           The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE        from the opening of the sensor contact until the TIME                         opening of the trip actuator. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
SHUTDOWN MARGIN (SOM)        SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:
: a. The reactor is xenon free;
: b. The moderator temperature is~ 68&deg;F, corresponding to the most reactive state; and
: c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.
With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SOM.
THERMAL POWER                THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.
TURBINE BYPASS SYSTEM        The TURBINE BYPASS SYSTEM RESPONSE TIME shall be RESPONSE TIME                that time interval from when the turbine bypass control unit generates a turbine bypass valve flow signal until the turbine bypass valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
Dresden 2 and 3                       1.1-6               Amendment No.

Definitions 1.1
                           ~able  1.1-1 (page 1 of 1)
MODES REACTOR MODE           AVERAGE REACTOR MODE             TITLE             SWITCH POSITION        COOLANT TEMPERATURE
( o F) 1    Power Operation      Run                                      NA 2    Startup              Refue1<al or Startup/Hot                 NA Standby 3    Hot Shutdown<al      Shutdown                            > 212 4    Cold Shutdown<al     Shutdown                            :::;  212 5    Refuel i ng<bl       Shutdown or Refuel                       NA (a)   All reactor vessel head closure bolts fully tensioned.
(b)   One or more reactor vessel head closure bolts less than fully tensioned.
Dresden 2 and 3                        1.1- 7             Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 ACTIONS CONDITION            REQUIRED ACTION           COMPLETION TIME B. As required by      B.1    --------NOTE--------
Required Action A.l        Only applicable for and referenced in          Functions 1.a, 1.b, Table 3.3.5.1-1.           2.a, 2.b, 2.d, and
: 2. j.
Declare supported       1 hour from feature(s) inoperable   discovery of when its redundant      loss of feature ECCS            initiation initiation capability   capability for is inoperable.          feature(s) in both divisions B.2    --------NOTE---------
Only applicable for Functions 3.a and 3.b.
Declare High Pressure   1 hour from Coolant Injection       discovery of (HPCI) System           loss of HPCI inoperable.             initiation capability B.3    Place channel in        24 hours trip.
(continued)
Dresden 2 and 3              3.3.5.1-2              Amendment No.

ECCS Instrumentation 3.3.5.1 ACTIONS CONDITION                 REQUIRED ACTION            COMPLETION TIME C. As required by      C.1         --------NOTE--------
Required Action A.1             Only applicable for and referenced in               Functions 1.c, l.e, Table 3.3.5.1-1.                2.c, 2.e, 2.g, 2.h, 2.i, and 2.k.
Declare supported        1 hour from feature(s) inoperable    discovery of when its redundant       loss of feature ECCS             initiation initiation capability    capability for is inoperable.           feature( s) in both divisions C.2         Restore channel to       24 hours OPERABLE status.
D. As required by      D.1         --------NOTE---------
Required Action A.1             Only applicable if and referenced in               HPCI pump suction is Table 3.3.5.1-1.                not aligned to the suppression pool.
Declare HPCI System      1 hour from inoperable.              discovery of loss of HPCI initiation capability D. 2 .1     Pl ace channel in        24 hours trip.
D.2.2       Align the HPCI pump      24 hours suction to the suppression pool.
(continued)
Dresden 2 and 3                  3.3.5.1-3               Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 ACTIONS CONDITION             REQUIRED ACTION           COMPLETION TIME E. As required by       E.1     --------NOTE--------
Required Action A.l         Only applicable for and referenced in           Functions 1.d Table 3.3.5.1-1.             and 2.f.
Declare supported       1 hour from feature(s) inoperable   discovery of when its redundant      loss of feature ECCS            initiation initiation capability   capability for is inoperable.          subsystems in both divisions E.2     Restore channel to      7 days OPERABLE status.
F. As required by       F.1     Declare Automatic       1 hour from Required Action A.1          Depressurization        discovery of and referenced in            System CADS) valves     loss of ADS Table 3.3.5.1-1.             inoperable.             initiation capability in both trip systems F.2     Pl ace channel in       96 hours from trip.                   discovery of inoperable channel concurrent with HPCI or isolation condenser CIC) inoperable 8 days (continued)
Dresden 2 and 3               3.3.5.1-4               Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 ACTIONS CONDITION              REQUIRED ACTION           COMPLETION TIME G. As required by        G.l    Declare ADS valves      1 hour from Required Action A.l         inoperable.             discovery of and referenced in                                    loss of ADS Table 3.3.5.1-1.                                     initiation capability in both trip systems G.2    Restore channel to      96 hours from OPERABLE status.        discovery of inoperable channel concurrent with HPCI or IC inoperable 8 days H. Required Action and   H.l    Declare associated      Immediately associated Completion        supported feature(s)
Time of Condition B,         inoperable.
C, D, E, F, or G not met.
Dresden 2 and 3                3.3.5.1-5              Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 SURVEILLANCE REQUIREMENTS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
: 1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.
: 2.      When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours for Functions 3.c, 3.f, and 3.g; and (b) for up to 6 hours for Functions other than 3.c, 3.f, and 3.g provided the associated Function or the redundant Function maintains ECCS initiation capability.
SURVEILLANCE                                                              FREQUENCY In accordance with the SR      3.3.5.1.1                 Perform CHANNEL CHECK.                                                          Surveillance Frequency Control Program SR       3.3.5.1.2                 Perform CHANNEL FUNCTIONAL TEST.                                                In accordance with the Surveillance Frequency Contra l Program SR      3.3.5.1.3                 Calibrate the trip unit.                                                         In accordance with the Surveillance Frequency Control Program SR      3.3.5.1.4                  Perform CHANNEL CALIBRATION.                                                    In accordance with the Surveillance Frequency Contra l Program (continued)
Dresden 2 and 3                                                     3.3.5.1-6                             Amendment No.

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR  3.3.5.1.5    Perform CHANNEL CALIBRATION.               In accordance with the Surveillance Frequency Control Program SR  3.3.5.1.6    Perform LOGIC SYSTEM FUNCTIONAL TEST.      In accordance with the Surveillance Frequency Control Program Dresden 2 and 3                    3.3.5.1-7            Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 Table 3.3.5.1-1 (page 1 of 5)
Emergency Core Cooling System Instrumentation APPLICABLE                  CONDITIONS MODES        REQUIRED    REFERENCED OR OTHER      CHANNELS        FROM SPECIFIED          PER       REQUIRED     SURVEILLANCE         ALLOWABLE FUNCTION              CONDITIONS      FUNCTION    ACTION A.1    REQUIREMENTS           VALUE L  Core Spray System a_   Reactor Vessel Water         1,2,3          4Ca>           B        SR  3.3.5.Ll    ;,, -54.15 Leve 1-Low Low                                                      SR  3.3.5.L2     inches SR  3.3.5.L3 SR  3.3.5.1.5 SR  3.3.5.1.6
: b. Drywell Pressure-High        1,2,3           4<*>          B        SR 3.3.5.1.2     $  L81 psig SR 3.3.5.1.4 SR 3.3.5.1.6
: c. Reactor Steam Dome           1,2,3            2            c        SR 3.3.5.L2     ;,, 308.5 psig Pressure-Low                                                        SR 3.3.5.1.4     and (Permissive)                                                        SR 3.3.5.1.6    $ 341.7 psig
: d. Core Spray Pump              1,2,3      1 per pump         E        SR  3.3.5.1.2   ;,, 802 gpm Discharge Flow-Low                                                  SR  3.3.5.1.3    and (Bypass)                                                            SR  3.3.5.1.5    $ 992 gpm SR  3.3.5.L6
: e. Core Spray Pump              1,2,3      1 per pump         c        SR 3.3.5.1.5     $  lL O seconds Start-Time Delay Relay                                              SR 3.3.5.1.6
: 2. Low Pressure Coolant Injection (LPCI) System
: a. Reactor Vessel Water         1,2,3            4            B        SR  3.3.5.Ll    ;,, -54 .15 Level-Low Low                                                       SR  3.3.5.1.2    Inches SR  3.3.5.L3 SR  3.3.5.1.5 SR  3.3.5.1.6
: b. Drywel l Pressure-High       1,2,3            4            B        SR 3.3.5.1.2    $   1.81 psig SR 3.3.5.1.4 SR 3.3.5.1.6
: c. Reactor Steam Dome           1,2,3            2            c        SR 3.3.5.1.2    ;,, 308.5 psig Pressure-Low                                                        SR 3.3.5.1.4     and
( Permissive)                                                       SR 3.3.5.1.6    $ 341.7 psig (continued)
(a)  Also required to initiate the associated diesel generator COG).
Dresden 2 and 3                                   3.3.5.1-8                        Amendment No.

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 5)
Emergency Core Cooling System Instrumentation APPLICABLE                  CONDITIONS MODES        REQUIRED    REFERENCED OR OTHER      CHANNELS        FROM SPEC I FI ED       PER       REQUIRED     SURVEILLANCE          ALLOWABLE FUNCTION             CONDITIONS      FUNCTION    ACTION A.1    REQUIREMENTS            VALUE
: 2. LPCI System (continued)
: d. Reactor Steam Dome          1,2,3            4            B        SR 3.3.5.1-2    ~    802 psig and Pressure-Low (Break                                                SR 3_3_5_ 1-5   5 898     psig Detection)                                                         SR 3.3.5.1-6
: e. Low Pressure Coolant        1,2,3      1 per pump         c        SR 3.3.5.1-5    5 5.5     seconds Injection Pump                                                    SR 3.3.5.1.6 Start-Time Delay Relay Pumps B and D f_   Low Pressure                1,2,3      1 per loop         E        SR  3.3.5.1-2   ;?;  1107 gpm Coolant Injection Pump                                             SR  3.3.5.1.3 Discharge Flow-Low                                                 SR  3.3.5.1.5 (Bypass)                                                           SR  3.3.5.1.6 g_   Recirculation Pump          1,2,3      4 per pump         c        SR 3.3.5.1-2    ,;; 5.9 psid Differential                                                       SR 3.3.5.1-5 Pressure-High (Break                                               SR 3.3.5.1-6 Detection l
: h. Recirculation Riser         1,2,3            4            c        SR 3.3.5.1-2    ,;; 2.0 psid Differential                                                       SR 3.3.5.1-5 Pressure-High (Break                                               SR 3.3.5.1.6 Detection)
: i. Recirculation Pump          1,2,3                         c        SR 3.3.5.1.5     5 0.53    seconds Differential Pressure                                              SR 3.3.5.1-6 Time Delay-Relay (Break Detection) j -  Reactor Steam Dome          1,2,3            2            B        SR 3.3.5.1.5     ,;; 2.12 seconds Pressure Time Delay-                                               SR 3.3.5.1.6 Relay (Break Detection)
: k. Recirculation Riser         1,2,3            2            c        SR 3.3.5.1.5     ,;; 0.53 seconds Differential Pressure                                              SR 3.3.5.1.6 Time Delay-Relay (Break Detection)
(continued)
Dresden 2 and 3                                 3.3.5.1-9                       Amendment No.

ECCS Instrumentation 3.3.5.l Table 3.3.5.1-1 (page 3 of 5)
Emergency Core Cooling System Instrumentation APPLICABLE                    CONDITIONS MODES OR         REQUIRED    REFERENCED OTHER        CHANNELS        FROM SPECIFIED          PER        REQUIRED   SURVEILLANCE           ALLOWABLE FUNCTION              CONDITIONS        FUNCTION    ACTION A. l REQUIREMENTS             VALUE
: 3. High Pressure Coolant Injection (HPCI) System
: a. Reactor Vesse 1 Water           1,             4             B      SR  3.3.5.1.l    ;;,: -54.15 Leve 1-Low Low                                                      SR  3.3.5.1.2     Inches 2tbl, 3tb)                              SR  3.3.5.1.3 SR  3.3.5.1.5 SR  3.3.5.1.6
: b. Drywel l Pressure-High          1,             4             B      SR 3.3.5.1.2    ,;; 1.81 psig SR 3.3.5.1.4 2tbl, 3tb)                              SR 3.3.5.1.6
: c. Reactor Vessel Water            1,             2             c      SR  3.3.5.1.1   ,;; 46.2 inches Level-High                                                          SR  3.3.5.1.2 2(b), 3tb)                              SR SR SR 3.3.5.1.3 3.3.5.1.5 3.3.5.1.6 I
: d. Contaminated                    1,        2 per CCST         D      SR 3.3.5.1.2    ;;,: 11.1158 ft Condensate Storage                                                  SR 3.3.5.1.5     for CCST 2/3 A Tank (CCSTl Level-Low      2(b)' 3tb)                               SR 3.3.5.1.6     and ;o, 7.5637 ft for CCST 2/3 B
: e. Suppression Pool llater         1,             2             D      SR 3.3.5.1.2    ,;; 15 ft Level-High                                                          SR 3.3.5.1.5    5.625 inches 2tb), 3tb)                               SR 3.3.5.1.6
: f. High Pressure Coolant           1,                           E      SR 3.3.5.1.2    ;o,   616 gpm Injection Pump                                                      SR 3.3.5.1.4 Discharge Flow-Low         2tb), 3(b)                               SR 3.3.5.1.6 (Bypass)
: g. Manual Initiation               1,                           c      SR 3.3.5.1.6     NA 2(b)' 3t*.l (continued)
(bl  With reactor steam dome pressure > 150 psig.
Dresden 2 and 3                                    3.3.5.1-10                     Amendment No.

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 5)
Emergency Core Cooling System Instrumentation APPLICABLE                     CONDITIONS MODES DR         REQUIRED    REFERENCED OTHER         CHANNELS        FROM SPECIFIED            PER       REQUIRED  SU RV EI LLANCE        ALLOWABLE FUNCTION             CONDITIONS         FUNCTION    ACTION A.1 REQUIREMENTS             VALUE
: 4. Automatic Oepressurization System (ADS) Trip System A
: a. Reactor Vessel Water            1,               2            F     SR    3.3.5.1.1    ;, -54.15 Leve 1-Low Low                                                      SR   3.3.5.1.2      Inches 2(b), 3(b)                              SR    3.3.5.1.3 SR    3.3.5.1.5 SR    3.3.5.l.6
: b. Drywel 1 Pressure-High          1,               2            F     SR 3.3.5.1.2       $  1.81 psig SR 3.3.5.1.4 2<bJ,  3(b)                             SR 3.3.5.l.6
: c. Automatic                       1,                            G     SR 3.3.5.l.5       $  113 seconds Depressurization                                                    SR 3.3.5.l.6 System Initiation          2(b), 3(b)
Timer
: d. Core Spray Pump                 1,               2            G     SR 3.3.5.l.2      ;, 101. 5 psig Discharge                                                           SR 3.3.5.l.4       and Pressure-High               2(b), 3U>)                              SR 3.3.5.l.6       $ 148.5 psig e_   Low Pressure Coolant            1,               4            G     SR 3_3.5.1.2      ;, 101. 5 psi g Injection Pump                                                      SR 3.3.5.1.4       and Di sch a rge               2(b)' 3(b)                               SR 3.3.5.1.6      $ 148.5 psig Pressure-High
: f. Automatic                       1,                            G     SR 3.3.5.l.5      ,,; 580 seconds Depressurization                                                    SR 3.3.5.1.6 System Low Low Water       2(b)' 3(b)
Level Actuation Timer (continued)
(bl  With reactor steam dome pressure > 150 psig.
Dresden 2 and 3                                     3.3.5.1-11                      Amendment No.

ECCS Instrumentation
: 3. 3. 5 .1 Table 3.3.5.1-1 (page 5 of 5)
Emergency Core Cooling System Instrumentation APPLICABLE                     CONDITIONS MODES OR          REQUIRED    REFERENCED OTHER         CHANNELS        FROM SPECIFIED           PER        REQUIRED  SURVEILLANCE         ALLOWABLE FUNCTION              CONDITIONS         FUNCTION    ACTION A.1 REQUIREMENTS           VALUE 5_ ADS Trip System B a-   Reactor Vessel Water             1,             2             F     SR  3.3.5.Ll     " -54 .15 Leve 1-Low Low                                                      SR  3.3.5.1.2    inches 2<b>, 3<bl                              SR  3.3.5.1.3 SR  3.3.5.1.5 SR  3.3.5.1.6
: b. Drywell Pressure-High            1,             2             F     SR 3.3.5.1.2    ,;; 1.81 psig SR 3.3.5.1.4 2<bl' 3<bl                              SR 3.3.5.l.6
: c. Automatic                       1,                            G     SR 3.3.5.1.5    ,;; 113 seconds Depressurization                                                    SR 3.3.5.1.6 System Initiation          2<bl' 3<bl Timer
: d. Core Spray Pump                 1,              2             G     SR 3.3.5.l.2    " 101.5 psig Discharge                                                           SR 3.3.5.1.4     and Pressure-High               2<b) ~  3<bl                            SR 3.3.5.1.6    ,;; 148.5 psig e_   Low Pressure Coolant            1,              4             G     SR 3.3.5.1.2    " 101.5 psig Injection Pump                                                      SR 3.3.5.1.4     and Discharge                  2<bl,    3<bl                            SR 3.3.5.1.6    ,;; 148. 5 psi g Pressure-High
: f. Automatic                       1'                            G     SR 3.3.5.1.5    ,;; 580 seconds Depressurization                                                    SR 3. 3. 5.1. 6 System Low Low Water       2(b),    3<bl Level Actuation Timer (bl  With reactor steam dome pressure > 150 psig.
Dresden 2 and 3                                     3.3.5.1-12                    Amendment No.

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.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each channel.
                , CONDITION                                              REQUIRED ACTION                               COMPLETION TIME A. One or more channels                             A. l            Enter the Condition                         Immediately inoperable.                                                     referenced in Table 3.3.5.2-1 for the channel.
B. As required by                                   B.l             Declare associated                          Immediately Required Action A. l                                            penetration flow and referenced in                                                path(s) incapable of Table 3.3.5.2-1.                                                 automatic isolation.
AND B.2             Calculate DRAIN TIME.                       Immediately
: c. As required by                                    C.l          Place channel in trip.                         1 hour Required Action A. l and referenced in Table 3.3.5.2-1.
D. As required by                                       D.l          Restore channel to                             24 hours Required Action A. l                                           OPERABLE status.
and referenced in Table 3.3.5.2-1.
(continued)           I Dresden 2 and 3                                                     3.3.5.2-1                                Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS CONDITION                                             REQUIRED ACTION                              COMPLETION TIME E. Required Action and                                  E.1           Declare associated low                       Immediately associated Completion                                          pressure ECCS Time of Condition C or                                         injection/spray D not met.                                                     subsystem inoperable.
SURVEILLANCE REQUIREMENTS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.
SURVEILLANCE                                                                FREQUENCY SR     3.3.5.2.1                  Perform CHANNEL CHECK.                                                            In accordance with the Surveillance Frequency Control Program SR      3.3.5.2.2                  Perform CHANNEL FUNCTIONAL TEST.                                                  In accordance with the Surveillance Frequency Control Program Dresden 2 and 3                                                     3.3.5.2-2                               Amendment No.

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (Page 1 of 1)
RPV Water Inventory Control Instrumentation APPLICABLE                        CONDITIONS MODES                           REFERENCED OR OTHER           REQUIRED         FROM SPEC I Fl ED     CHANNELS PER      REQUIRED  SU RV El LLANCE      ALLOWABLE FUNCTION             CONDITIONS           FUNCTION     ACTION A.1  REQUIREMENTS           VALUE L  Core Spray System
: a. Reactor Steam Dome          4, 5                 2              c     SR    3_3_5_2_2 ;,, 308.5 psig Pressure-Low                                                                           and (Permissive)                                                                          ,;; 341.7 psig
: b. Core Spray Pump             4, 5               1 per            D     SR    3_3_5_2_2 ;,, 802 gpm Discharge Flow-Low                           pump (a)                                  and
          <Bypass)                                                                              ,;; 992 gpm
: 2. Low Pressure Coolant Injection (LPCll System a_   Reactor Steam Dome          4> 5                               c      SR 3_3_5_2_2    ;,, 308.5 psig Pressure-Low                                                                           and (Permissive)                                                                          ,;; 341-7 psig
: b. Low Pressure Coolant        4, 5              1 per            D      SR 3_3_5_2_2    ;,, 1107 gpm Injection Pump                              loop (a)
Discharge Fl ow-Low
          <Bypass) 3_  Shutdown Cooling System (SDCl Isolation
: a. Reactor Vessel Water          (b)             per trip           B     SR 3_3_5_2_1    ;,, 2.65 inches Level-Low                                   system                   SR 3_3_5_2_2 4_  Reactor Water Cleanup System Isolation a-   Reactor Vessel Water         (b)             per trip          B      SR 3_3_5_2_1    ;,, 2.65 inches Level-Low                                    system                   SR 3_3_5_2_2 (a)  Associated with an ECCS subsystem required to be OPERABLE by LCD 3.5.2, "RPV Water Inventory Control."
(bl  When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.
Dresden 2 and 3                                     3.3.5.2-3                       Amendment No.

IC System Instrumentation 3.3.5.3 3.3       INSTRUMENTATION 3.3.5.3           Isolation Condenser (IC) System Instrumentation LCO       3.3.5.3                 Four channels of Reactor Vessel Pressure-High instrumentation shall be OPERABLE.
APPLICABILITY:                    MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each channel.
CONDITION                                             REQUIRED ACTION                                COMPLETION TIME A.      One or more Reactor                             A. l            Declare IC System                            1 hour from Vessel Pressure-High                                             inoperable.                                 discovery of channels inoperable.                                                                                         loss of IC initiation capability AND A.2              Place channel (s) in                        24 hours trip.
B.      Required Action and                             B.1             Declare IC System                            Immediately associated Completion                                           inoperable.
Time not met.
Dresden 2 and 3                                                     3.3.5.3-1                                 Amendment No.

IC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the Reactor Vessel Pressure-High Function maintains IC initiation capability.
SURVEILLANCE                                                                 FREQUENCY SR       3.3.5.3.1                 Perform CHANNEL FUNCTIONAL TEST.                                                   In accordance with the Surveillance Frequency Contra l Program SR       3.3.5.3.2                 - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - -
Not required for the time delay portion of the channel.
Perform CHANNEL CALIBRATION. The                                                   In accordance Allowable Value shall be~ 1068 psig.                                                with the Surveillance Frequency Control Program SR      3.3.5.3.3                  Perform CHANNEL CALIBRATION for the time                                           In accordance delay portion of the channel. The                                                   with the Allowable Value shall be~ 15 seconds.                                              Surveillance Frequency Control Program SR      3.3.5.3.4                 Perform LOGIC SYSTEM FUNCTIONAL TEST.                                               In accordance with the Surveillance Frequency Control Program Dresden 2 and 3                                                     3.3.5.3-2                                Amendment No.

I Primary Containment Isolation Instrumentation 3.3.6.l Table 3.3.6.1-1 (page 3 of 3)
Primary Containment Isolation Instrumentation APPLICABLE                  CONDITIONS MODES OR       REQUIRED    REFERENCED OTHER        CHANNELS       FROM SPECIF! ED     PER TRIP     REQUIRED   SURVEILLANCE          ALLOWABLE FUNCTION             CONDITIONS       SYSTEM     ACTION C.l  REQUIREMENTS            VALUE
: 5. Reactor Water Cleanup System Isolation
: a. SLC System Initiation       1,2,3                         H      SR 3.3.6.1.7    NA
: b. Reactor Vessel Water        1,2,3                         F      SR  3.3.6.1.1  ;,,: 2.65 inches Level-Low                                                        SR  3.3.6.1.2 SR  3.3.6.1.3 SR  3.3.6.1.6 SR  3.3.6.1.7
: 6. Shutdown Cooling System Isolation
: a. Reactor Vessel              1,2,3                         F      SR 3.3.6.1.2   ,;; 114.1 psig Pressure - High                                                  SR 3.3_6_1.6    (Loop 1, SR 3.3.6.1.7    Reactor Wide Range Pressure)
                                                                                           ,;; 110.4 psig (Loop 2, Reactor Pressure Feedwater Control)
: b. Reactor Vessel Water          3                                  SR  3.3.6.1.1  ;,,: 2.65 inches Level-Low                                                        SR  3.3.6.1.2 SR  3.3.6.1.3 SR  3.3.6.l.6 SR  3.3.6.1.7 Dresden 2 and 3                                  3.3.6.1-8                      Amendment No.

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of 1)
Secondary Containment Isolation Instrumentation APPLICABLE MODES OR          REQUIRED OTHER           CHANNELS SPECIFIED            PER            SURVEILLANCE          ALLOWABLE FUNCTION                 CONDITIONS       TRIP SYSTEM         REQUIREMENTS            VALUE
: 1. Reactor Vessel Water               1,2,3                2            SR  3.3.6.2.1     ;,, 2.65 inches Level-Low                                                            SR  3.3.6.2.2 SR  3.3.6.2.3 SR  3.3.6.2.5 SR  3.3.6.2.6
: 2. Drywell-Pressure-High              1,2,3                             SR 3.3.6.2.2         ,; 1.94 psig SR 3.3.6.2.4 SR 3.3.6.2.6
: 3. Reactor Building Exhaust          1,2 ,3,               2            SR  3.3.6.2.1      ,; 14.9 mR/hr Radiation-High                      (a)                              SR  3.3.6.2.2 SR  3.3.6.2.4 SR  3.3.6.2.6
: 4. Refueling Floor                   1,2,3,                             SR  3.3.6.2.1        ,; 100 mR/hr Radiation-High                      (a)                              SR  3.3.6.2.2 SR  3.3.6.2.4 SR  3.3.6.2.6 (a) During movement of recently irradiated fuel assemblies in secondary containment.
Dresden 2 and 3                                   3.3.6.2-5                       Amendment No.

CREV System Instrumentation
: 3. 3. 7 .1 3.3       INSTRUMENTATION 3.3.7.1           Control Room Emergency Ventilation (CREV) System Instrumentation LCO       3.3.7.1                 Two channels of the Reactor Building Ventilation System-High High Radiation Alarm Function shall be OPERABLE.
APPLICABILITY:                    MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each channel.
CONDITION                                             REQUIRED ACTION                                COMPLETION TIME A.      One or more channels                            A.1             Declare CREV System                          1 hour from inoperable.                                                      inoperable.                                 discovery of loss of CREV System Instrumentation alarm capability in both trip systems A.2             Restore channel to                           6 hours OPERABLE status.
(continued)
Dresden 2 and 3                                                     3.3.7.1-1                                 Amendment No.
I

ECCS-Operating 3.5.l 3.5       EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.1         ECCS-Operating LCO       3.5.1                   Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five relief valves sha 11 be OPERABLE.
APPLICABILITY:                    MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure~ 150 psig.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3.0.4.b is not applicable to HPCI.
CONDITION                                            REQUIRED ACTION                             COMPLETION TIME A.      One Low Pressure                                  A.1            Restore LPCI pump to                     30 days Coolant Injection                                                 OPERABLE status.
(LPCI) pump inoperable.
B.      One LPCI subsystem                                B.1            Restore low pressure                      7 days inoperable for reasons                                           ECCS injection/spray other than Condition A.                                           subsystem to OPERABLE status.
OR One Core Spray subsystem inoperable.
: c.      One LPCI pump in each                              C.1            Restore one LPCI                         7 days subsystem inoperable.                                             pump to OPERABLE status.
(continued)
Dresden 2 and 3                                                       3.5.1-1                               Amendment No.

RPV Water Inventory Control 3.5.2 3.5   EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.2   RPV Water Inventory Control LCO   3.5.2        DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be~ 36 hours.
One low pressure ECCS injection/spray subsystem shall be OPERABLE.
APPLICABILITY:     MODES 4 and 5.
ACTIONS CONDITION                  REQUIRED ACTION            COMPLETION TIME A. Required ECCS            A. l    Restore required ECCS    4 hours injection/spray                  injection/spray subsystem inoperable.            subsystem to OPERABLE status.
B. Required Action and      B.l     Initiate action to       Immediately associated Completion            establish a method of Time of Condition A              water injection not met.                         capable of operating without offs ite electrical power.
(continued)
Dresden 2 and 3                      3.5.2-1               Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION           REQUIRED ACTION              COMPLETION TIME C. DRAIN TIME < 36 hours C.1   Verify secondary           4 hours and ;::: 8 hours.           containment boundary is capable of being established in less than the DRAIN TIME.
C.2   Verify each secondary      4 hours containment penetration flow path is capable of being isolated in less than t he DRA I N TI ME*
C.3   Verify one standby         4 hours gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.
(continued)
Dresden 2 and 3                3.5.2-2                 Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION            REQUIRED ACTION           COMPLETION TIME D. DRAIN TIME< 8 hours. D.1   ------- NOTE --------
Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.
Initiate action to      Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for
                                ~ 36 hours.
AND D.2   Initiate action to      Immediately establish secondary containment boundary.
AND D.3   Initiate action to      Immediately isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.
AND D.4   Initiate action to      Immediately verify one standby gas treatment system is capable of being placed in operation.
(continued)
Dresden 2 and 3               3.5.2-3               Amendment No.

RPV Water Inventory Control 3.5.2 ACTIONS E. Required Action and       E.1      Initiate action to      Immediately associated Completion               restore DRAIN TIME to Time of Condition C or              2 36 hours.
D not met.
DRAIN TIME < 1 hour.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                               FREQUENCY SR  3.5.2.1     Verify DRAIN TIME   2 36  hours.                 In accordance with the Surveillance Frequency Control Program SR  3.5.2.2     Verify, for the required ECCS injection/         In accordance spray subsystem, the:                            with the Surveillance
: a. Suppression pool water level is            Frequency 2  10 ft 4 inches; or                       Control Program
: b. Contaminated condensate storage tanks water volume is 2 140,000 available gallons.
SR  3.5.2.3     Verify, for the required ECCS                    In accordance injection/spray subsystem, locations             with the susceptible to gas accumulation are              Surveillance sufficiently filled with water.                  Frequency Control Program (continued)
Dresden 2 and 3                       3.5.2-4               Amendment No.

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                         FREQUENCY SR  3.5.2.4    - - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -
Not required to be met for system vent flow paths opened under administrative control.
Verify for the required ECCS                                                      In accordance injection/spray subsystem each manual,                                           with the power operated, and automatic valve in the                                        Surveillance flow path, that is not locked, sealed, or                                         Frequency otherwise secured in position, is in the                                          Control Program correct position.
SR  3.5.2.5    Operate the required ECCS injection/spray                                         In accordance subsystem through the recirculation line                                          with the for ~ 10 minutes.                                                                 Inservice Testing Program SR  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                                        Inservice an actual or simulated isolation signal.                                          Testing Program SR  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 Surveillance Frequency Control Program Dresden 2 and 3                                       3.5.2-5                                Amendment *No.

IC System 3.5.3 3.5       EMERGENCY CORE COOLING SYSTEMS CECCS), REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER CIC) SYSTEM 3.5.3         IC System LCO       3.5.3                   The IC System shall be OPERABLE.
APPLICABILITY:                    MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3.0.4.b is not applicable to IC.
CONDITION                                             REQUIRED ACTION                               COMPLETION TIME A.      IC System inoperable.                           A.1             Verify by                                   Immediately administrative means High Pressure Coolant Injection System is OPERABLE.
A.2             Restore IC System to                        14 days OPERABLE status.
B.      Required Action and                             - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion                           LCO 3.0.4.a is not applicable Time not met.                                   when entering MODE 3.
B.1             Be in MODE 3.                               12 hours Dresden 2 and 3                                                       3.5.3-1                                 Amendment No.

PC I Vs 3.6.1.3 ACTIONS CONDITION             REQUIRED ACTION            COMPLETION TIME C.   (continued)          C.2    --------NOTES--------
: 1. Isolation devices in high radiation areas may be verified by use of administrative means.
: 2. Isolation devices that are a locked, sealed, or otherwise secured may be verified by use of administrative means.
Verify the affected      Once per 31 days penetration flow path is isolated.
D. MSIV leakage rate     D.1    Restore leakage rate     8 hours not within limit.            to within limit.
E. Required Action and  E.1    Be in MODE 3.            12 hours associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3.      E.2    Be in MODE 4.            36 hours Dresden 2 and 3                3.6.1.3-5               Amendment No.

PC I Vs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                          FREQUENCY SR  3.6.1.3.1    - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - -
Not required to be met when the 18 inch primary containment vent and purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the drywell vent and purge valves and their associated suppression chamber vent and purge valves are not open simultaneously.
Verify each 18 inch primary containment                                       In accordance vent and purge valve, except the torus                                        with the purge valve, is closed.                                                       Surveillance Frequency Contra l Program SR  3.6.1.3.2    ------------------NOTES------------------
: 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
: 2.      Not required to be met for PCIVs that are open under administrative controls.
Verify each primary containment isolation                                     In accordance manual valve and blind flange that is                                         with the located outside primary containment and                                       Surveillance not locked, sealed, or otherwise secured                                      Frequency and is required to be closed during                                           Control Program accident conditions is closed.
(continued)
Dresden 2 and 3                                   3.6.1.3-6                                Amendment No.

PC I Vs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                         FREQUENCY SR   3.6.1.3.3    - - - - - - - - - - - - - - - - - - NOTES- - - - - - - - - - - - - - - - - -
: 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
: 2.      ,Not required to be met for PCIVs that are open under administrative controls.
Verify each primary containment manual                                        Prior to isolation valve and blind flange that is                                      entering MODE 2 located inside primary containment and                                        or 3 from not locked sealed, or otherwise secured                                       MODE 4 i f and is required to be closed during                                           primary accident conditions is closed.                                                containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR  3.6.1.3.4    Verify continuity of the traversing                                           In accordance incore probe (TIP) shear isolation valve                                      with the explosive charge.                                                             Surveillance Frequency Control Program SR  3.6.1.3.5    Verify the isolation time of each power                                       In accordance operated, automatic PCIV, except for                                          with the MSIVs, is within limits.                                                      Inservice Testing Program SR  3.6.1.3.6    Verify the isolation time of each MSIV is                                     In accordance 2   3 seconds and~ 5 seconds.                                                 with the Inservice Testing Program (continued)
Dresden 2 and 3                                    3.6.1.3-7                               Amendment No.

PC I Vs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR  3.6.1.3.7    Verify each automatic PCIV actuates to       In accordance the isolation position on an actual or       with the simulated isolation signal.                  Surveillance Frequency Control Program SR  3.6.1.3.8    Verify a representative sample of reactor    In accordance instrumentation line EFCVs actuate to the   with the isolation position on an actual or          Surveillance simulated instrument line break signal.      Frequency Control Program SR  3.6.1.3.9    Remove and test the explosive squib from     In accordance each shear isolation valve of the TIP       with the System.                                      Surveillance Frequency Control Program SR  3.6.1.3.10   Verify the leakage rate through each MSIV    In accordance leakage path is s 34 scfh when tested at    with the
                  ~ 25 psig, and the combined leakage rate     Primary for all MSIV leakage paths is s 86 scfh     Containment when tested at ~ 25 psig.                    Leakage Rate Testing Program Dresden 2 and 3                    3.6.1.3-8              Amendment No.

Secondary Containment
: 3. 6. 4 .1 3.6  CONTAINMENT SYSTEMS 3.6.4.1  Secondary Containment LCO  3.6.4.1      The secondary containment shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS CONDITION                          REQUIRED ACTION                           COMPLETION TIME A. Secondary containment    A.1             Restore secondary                       4 hours inoperable in MODE 1,                    containment to 2, or 3.                                 OPERABLE status.
B. Required Action and      - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion     LCO 3.0.4.a is not applicable Time of Condition A      when entering MODE 3.
not met.
B.1             Be in MODE 3.                           12 hours C. Secondary containment    C.1             - - - - - - - - NOTE - - - - - - - - -
inoperable during                        LCO 3.0.3 is not movement of recently                     applicable.
irradiated fuel assemblies in the secondary containment.                   Suspend movement of                     Immediately recently irradiated fuel assemblies in the secondary containment.
Dresden 2 and 3                         3.6.4.1-1                                 Amendment No.

SCI Vs 3.6.4.2 3.6  CONTAINMENT SYSTEMS 3.6.4.2  Secondary Containment Isolation Valves (SCIVs)
LCO  3.6.4.2      Each SCIV shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS NOTES- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
: 1. Penetration flow paths may be unisolated intermittently under administrative controls.
: 2. Separate Condition entry is allowed for each penetration flow path.
: 3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.
CONDITION                   REQUIRED ACTION                              COMPLETION TIME A. One or more              A.1      Isolate the affected                       8 hours penetration flow paths            penetration flow path with one SCIV                     by use of at least inoperable.                       one closed and de-activated automatic valve, closed manual valve, or blind flange.
(continued)
Dresden 2 and 3                     3.6.4.2-1                            Amendment No.

SCI Vs 3.6.4.2 ACTIONS CONDITION               REQUIRED ACTION                          COMPLETION TIME C. Required Action and    C.1    Be in MODE 3.                          12 hours associated Completion Time of Condition A or B not met in MODE 1, 2, or 3.       C.2    Be in MODE 4.                          36 hours D. Required Action and    D.1    - - - - - - - - NOTE - - - - - - - - -
associated Completion         LCO 3.0.3 is not Time of Condition A            applicable.
or B not met during movement of recently irradiated fuel               Suspend movement of                    Immediately assemblies in the             recently irradiated secondary containment.        fuel assemblies in the secondary containment.
Dresden 2 and 3                  3.6.4.2-3                             Amendment No.

SGT System 3.6.4.3 3.6  CONTAINMENT SYSTEMS 3.6.4.3   Standby Gas Treatment (SGT) System LCO  3.6.4.3      Two SGT subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS CONDITION                         REQUIRED ACTION                          COMPLETION TIME A. One SGT subsystem       A. l            Restore SGT                           7 days inoperable.                             subsystem to OPERABLE status.
B. Required Action and     - - - - - - - - - - - -NOTE- - - - - - - - - - - - -
associated Completion    LCO 3.0.4.a is not applicable Time of Condition A      when entering MODE 3.
not met in MODE 1, 2, or 3.
B.l             Be in MODE 3.                         12 hours C. Required Action and     ------------NOTE------------
associated Completion    LCO 3.0.3 is not applicable.
Time of Condition A not met during movement of recently     C.l             Place OPERABLE SGT                    Immediately irradiated fuel                          subsystem in assemblies in the                        operation.
secondary containment.
C.2             Suspend movement of                   Immediately recently irradiated fuel assemblies in secondary containment.
(continued)
Dresden 2 and 3                          3.6.4.3-1                               Amendment No.

SGT System 3.6.4.3 ACTIONS CONDITION                       REQUIRED ACTION                            COMPLETION TIME D. Two SGT subsystems     D.1             Restore one SGT                         1 hour inoperable in MODE 1,                 subsystem to 2, or 3.                              OPERABLE status.
E. Required Action and   - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion LCO 3.0.4.a is not applicable Time of Condition D    when entering MODE 3.
not met.
E.1             Be in MODE 3.                           12 hours F. Two SGT subsystems     F.1             --------NOTE--------
inoperable during                     LCO 3.0.3 is not movement of recently                   applicable.
irradiated fuel assemblies in the secondary                              Suspend movement of                     Immediately containment.                           recently irradiated fuel assemblies in secondary containment.
Dresden 2 and 3                        3.6.4.3-2                                 Amendment No.

CREV System 3.7.4 3.7   PLANT SYSTEMS 3.7.4   Control Room Emergency Ventilation (CREV) System LCO   3.7.4        The CREV System shall be OPERABLE.
                   - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - -
The main control room envelope CCRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:     MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS CONDITION                                      REQUIRED ACTION                           COMPLETION TIME A. CREV System inoperable               A.1              Restore CREV System                    7 days in MODE 1, 2, or 3 for                               to OPERABLE status.
reasons other than Condition c.
B. Required Action and                  - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion                LCO 3.0.4.a is not applicable Time of Condition A                  when entering MODE 3.
not met in MODE 1, 2'                -----------------------------
or 3.
B.1             Be in MODE 3.                           12 hours (continued)
Dresden 2 and 3                                        3.7.4-1                                 Amendment No.

CREV System 3.7.4 ACTIONS (continued)
CONDITION                      REQUIRED ACTION                           COMPLETION TIME C. CREV system inoperable C.1              Initiate action to                    Immediately due to inoperable CRE                   implement mitigating boundary in MODE 1, 2,                  actions.
or 3.
C.2             Verify mitigating                      24 hours actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
C.3             Restore CRE boundary                   90 days to OPERABLE status.
D. Required Action and    D.1             Be in MODE 3.                          12 hours associated Completion Time of Condition C not met in MODE 1, 2, or 3.                   D.2             Be in MODE 4.                          36 hours E. CREV System inoperable  - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
during movement of      LCO 3.0.3 is not applicable.
recently irradiated fuel assemblies in the secondary containment. E.1             Suspend movement of                    Immediately recently irradiated fuel assemblies in the secondary CREV System inoperable                 containment.
due to an inoperable CRE boundary during movement of recently irradiated fuel assemblies in the secondary containment.
Dresden 2 and 3                         3.7.4-2                                 Amendment No.

Control Room Emergency Ventilation AC System 3.7.5 3.7   PLANT SYSTEMS 3.7.5    Control Room Emergency Ventilation Air Conditioning (AC) System LCO   3.7.5         The Control Room Emergency Ventilation AC System shall be OPERABLE.
APPLICABILITY:      MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS CONDITION                          REQUIRED ACTION                           COMPLETION TIME A. Control Room Emergency    A.1             Restore Control Room                    30 days Ventilation AC System                      Emergency Ventilation inoperable in MODE 1,                     AC System to OPERABLE 2, or 3.                                  status.
B. Required Action and       - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
associated Completion     LCO 3.0.4.a is not applicable.
Time of Condition A       when entering MODE 3.
not met in MODE 1, 2, or 3.
B.1             Be in MODE 3.                           12 hours C. Control Room Emergency    - - - - - - - - - - - - NOTE - - - - - - - - - - - - -
Ventilation AC System     LCO 3.0.3 is not applicable.
inoperable during movement of recently irradiated fuel           C.1             Suspend movement of                     Immediately assemblies in the                         recently irradiated secondary containment.                    fuel assemblies in the secondary containment.
Dresden 2 and 3                             3.7.5-1                                 Amendment No.

AC Sources-Shutdown 3.8.2 ACTIONS
-------------------------------------NOTE-------------------------------------
LCO 3.0.3 is not applicable.
CONDITION                          REQUIRED ACTION                            COMPLETION TIME A. One required offsite      - - - - - - - - - - - -NOTE - - - - - - - - - - - - -
circuit inoperable.      Enter applicable Condition and Required Actions of LCO 3.8.8, when any required division is de-energized as a result of Condition A.
A.1             Declare affected                        Immediately required feature(s),
with no offsite power available, inoperable.
OR A.2.1           Suspend CORE                            Immediately ALTERATIONS.
A.2.2            Suspend movement of                     Immediately recently irradiated fuel assemblies in the secondary containment.
A.2.3           Initiate action to                      Immediately restore required offsite power circuit to OPERABLE status.
(continued)
Dresden 2 and 3                            3.8.2-2                                Amendment No.

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION                                      REQUIRED ACTION                             COMPLETION TIME B. One required DG                        B .1          Suspend CORE                              Immediately inoperable.                                         AL TERA TI ONS.
AND B.2           Suspend movement of                       Immediately recently irradiated fuel assemblies in secondary containment.
AND B.3           Initiate action to                        Immediately restore required DG to OPERABLE status.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                           FREQUENCY SR  3.8.2.1      - - - - - - - - - - - - - - - - - - -NOTES- - - - - - - - - - - - - - - - - - -
: 1.        The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.19.
: 2.        SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown."
For AC sources required to be OPERABLE the                                         In accordance SRs of Specification 3.8.1, except                                                 with applicable SR 3.8.1.9, SR 3.8.1.20, and SR 3.8.1.21                                           SRs are applicable.
Dresden 2 and 3                                         3.8.2-3                              Amendment No.

DC Sources-Shutdown 3.8.5 3.8       ELECTRICAL POWER SYSTEMS 3.8.5         DC Sources-Shutdown LCO       3.8.5                   One 250 VDC and one 125 VDC electrical power subsystem shall be OPERABLE to support the 250 VDC and one 125 VDC Class lE electrical power distribution subsystems required by LCO 3.8.8, "Distribution Systems-Shutdown."
APPLICABILITY:                    MODES 4 and 5, During movement of recently irradiated fuel assemblies in the secondary containment.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
LCO 3.0.3 is not applicable.
CONDITION                                             REQUIRED ACTION                                COMPLETION TIME A.      One or more required                            A.1              Declare affected                            Immediately DC electrical power                                              required feature(s) subsystems inoperable.                                           inoperable.
A.2.1           Suspend CORE                                 Immediately ALTERATIONS.
A.2.2           Suspend movement of                          Immediately recently irradiated fuel assemblies in the secondary containment.
A.2.3            Initiate action to                          Immediately restore required DC electrical power subsystems to OPERABLE status.
Dresden 2 and 3                                                        3.8.5-1                                 Amendment No.

DC Sources-Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                              FREQUENCY SR  3.8.5.1    - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - -
The following SRs are not required to be performed for the 250 voe electrical power subsystem: SR 3.8.4.2 and SR 3.8.4.4.
For DC electrical power subsystems required                                           In accordance to be OPERABLE the following SRs are                                                  with applicable applicable:                                                                           SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.
Dresden 2 and 3                                       3.8.5-2                                 Amendment No.

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION                     REQUIRED ACTION            COMPLETION TIME A.   (continued)               A.2.2    Suspend movement of      Immediately recently irradiated fuel assemblies in the secondary containment.
A.2.3    Initiate actions to      Immediately restore required AC and DC electrical power distribution subsystems to OPERABLE status.
A.2.4    Declare associated       Immediately required shutdown cooling subsystem(s) inoperable and not in operation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR  3.8.8.1      Verify correct breaker alignments and            In accordance voltage to required AC and DC electrical         with the power distribution subsystems.                   Surveillance Frequency Control Program Dresden 2 and 3                       3.8.8-2                 Amendment No.

Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 4 -
PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UP)
TOC Page i                     B 3.3.6.2-5                     B 3.6.2.2-2 TOC Page ii                    B 3.3.6.2-7                     B 3.6.4.1-2 B 3.3.5.1-10                   B 3.3.7.1-3                     B 3.6.4.1-4 B 3.3.5.1-12                   B 3.5.1-1                       B 3.6.4.2-2 B 3.3.5.1-14                   B 3.5.2-1                       B 3.6.4.2-5 B 3.3.5.1-15                   B 3.5.2-2                       B 3.6.4.3-3 B 3.3.5.1-30                   B 3.5.2-3                       B 3.6.4.3-4 B 3.3.5.1-32                   B 3.5.2-4                       B 3.6.4.3-5 B 3.3.5.1-35                   B 3.5.2-5                       B 3.6.4.3-6 B 3.3.5.2-1                    B 3.5.2-6                       B 3.7.4-7 B 3.3.5.2-2                    B 3.5.2-7                       B 3.7.4-10 B 3.3.5.2-3                    B 3.5.2-8                       B 3.7.5-3 B 3.3.5.2-4                    B 3.5.2-9                       B 3.7.5-4 B 3.3.5.2-5                    B 3.5.2-10                      B 3.7.5-5 B 3.3.5.2-6                    B 3.5.2-11                      B 3.8.2-1 B 3.3.5.2-7                    B 3.5.2-12                      B 3.8.2-3 B 3.3.5.2-8                    B 3.5.2-13                      B 3.8.2-4 B 3.3.5.2-9                    B 3.5.2-14                      B 3.8.2-5 B 3.3.5.2-10                   B 3.5.2-15                      B 3.8.2-6 B 3.3.5.3-1                    B 3.5.2-16                      B 3.8.2-7 B 3.3.5.3-2                    B 3.5.2-17                      B 3.8.5-1 B 3.3.5.3-3                    B 3.5.2-18                      B 3.8.5-3 B 3.3.5.3-4                    B 3.5.2-19                      B 3.8.5-4 B 3.3.5.3-5                    B 3.5.3-1                       B 3.8.8-2 B 3.3.5.3-6                    B 3.5.3-2                       B 3.8.8-3 B 3.3.6.1-19                   B 3.6.1.3-4                     B 3.8.8-4 B 3.3.6.1-21                   B 3.6.1.3-9 B 3.3.6.2-4                    B 3.6.1.3-10

TABLE OF CONTENTS B 2. 0         SAFETY LIMITS (SLs)
B 2 .1.1           Reactor Core SLs .. . ...... ........ ....... ............ B 2.1.1-1 B 2 .1. 2          Reactor Coolant System (RCS) Pressure SL ........... B 2 . 1 . 2-1 B 3.0          LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ... B 3.0-1 B 3.0          SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............ B 3.0-13 B 3.1          REACTIVITY CONTROL SYSTEMS B 3 . 1.1          SHUTDOWN MARGIN (SOM) ............................... B 3.1.1-1 B 3 .1. 2          Reactivity Anomalies ...... . ......................... B 3.1.2-1 B 3 .1. 3          Control Rod OPERABILITY ............................. B 3.1.3-1 B 3 .1. 4          Control Rod Scram Times .............. . ....... .... ... B 3 .1. 4-1 B 3 .1. 5          Control Rod Scram Accumulators . ........ .......... . .. B 3 . 1 . 5-1 B 3 . 1. 6         Rod Pattern Control ................................. B 3 . 1.6-1 B 3 .1. 7          Standby Liquid Control (SLC) System ................. B 3.1.7-1 B 3 . 1.8          Scram Discharge Volume (SOV) Vent and Drain Valves . . B 3 .1. 8-1 B 3.2          POWER DISTRIBUTION LIMITS B 3. 2 .1         AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) .. . ..... ....... ... ........................ B 3.2 . 1-1 B 3.2 . 2          MINIMUM CRITICAL POWER RATIO (MCPR) ................. B 3.2 . 2-1 B 3.2.3            LIN EAR HEAT GENERATION RATE (LHGR) ................. B 3.2 . 3-1 B 3.3          INSTRUMENTATION B 3.3.1.1          Reactor Protection System (RPS) Instrumentation ..... B 3 . 3 . 1 . 1-1 B 3.3 . 1.2       Source Range Monitor (SRM) Instrumentation ... .... . . . B 3.3.1.2-1 B 3 . 3 .1. 3     Oscillation Power Range Monitor (OPRM)
Instrumentation ................................... B 3 . 3.1.3-1 B 3. 3 . 2 . 1    Control Rod Block Instrumentation .... ............... B 3.3 . 2.1-1 B 3 . 3 . 2. 2     Feedwater System and Main Turbine High Water Level Trip Instrumentation . . ..... .... .......... .. . . . .... B 3.3 . 2.2-1 B 3.3.3. 1         Post Accident Monitoring (PAM) Instrumentation ...... B 3.3 . 3.1-1 B 3.3.4. 1        Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation ..... .. . .. .... B 3.3.4 . 1-1 B 3 . 3.5.1        Emergency Core Cooling System (ECCS)
Instrumentation . .......... . ...... ........ . . .... ... B 3.3 . 5.1-1 B 3.3.5 . 2        Isolation Condenser CIC) System Instr~mentationReactor Pressure Vessel (RPVJ Water Inventory Control Instrumentation ....... . ....... ..... ............. . . B 3 . 3 . 5.2-1 B 3. 3 . 5. 3      Isolation Condenser (IC) System Instrumentation ..... B 3 . 3 . 5.3-1 B 3.3.6.l          Primary Containment Isolation Instrumentation ... .... B 3.3.6.1-1 B 3.3 . 6 . 2     Secondary Containment Isolation Instrumentation ..... B 3 . 3 . 6 . 2-1 B 3.3.6.3         Relief Valve Instrumentation . . .. . ............. . ..... B 3 . 3 . 6 . 3-1 B 3.3.7.1         Control Room Emergency Ventilation (CREV)
System Instrumentation ..... .... ....... ......... ... B 3 . 3 . 7 . 1-1 B 3. 3. 7 . 2     Mechanical Vacuum Pump Trip Instrumentation ......... B 3 . 3 . 7 . 2-1 B 3. 3. 8 . 1      Loss of Power (LOP) Instrumentation ................. B 3.3.8 . 1-1 B 3.3.8.2         Reactor Protection System (RPS) Electric Power Monitoring ...... . ..... ...... . .. ..... . ...... ....... B 3.3 . 8.2-1 (continued)
Dresden 2 and 3                                                                    Revision

TABLE OF CONTENTS         (continued)
B 3.4          REACTOR COOLANT SYSTEM (RCS)
B 3.4 . 1         Recirculation Loops Operating ........... . . ... ...... . B                                         3 . 4 . 1-1 B 3.4 . 2         Jet Pumps ......... . ...... . . . . . ..... . ...... .. ..... . .. B                                3.4 . 2-1 B 3.4 . 3         Safety and Relief Valves ............. . .. .. .. .. . . ... B                                       3.4 . 3-1 B 3. 4 . 4        RCS Operational LEAKAGE . .. . . .. .. . . . . .. .... ... . .. .... B                               3 . 4 . 4-1 B 3.4 . 5         RCS Leakage Detection Instrumentation ... . . ... ....... B                                          3.4 . 5-1 B 3.4 . 6         RCS Specific Activity .. ........... . .. . . ... .... . . . .. . B                                  3 . 4 . 6-1 B 3.4 . 7         Shutdown Cooling (SDC) System-Hot Shutdown . . .. . . . . .. B                                       3.4 . 7-1 B 3.4 .8          Shutdown Cooling CSDC) System-Cold Shutdown .. .... ... B                                            3 . 4 . 8-1 B 3.4 . 9         RCS Pressure and Temperature (PIT) Limits ........... B                                              3 . 4 . 9-1 B 3 . 4 . 10      Reactor Steam Dome Pressure ..... ... ......... .. .... . . B                                        3 . 4 . 10-1 B 3. 5         EMERGENCY CORE COOLING SYSTEMS CECCS) , REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, - AND ISOLATION COND ENSER CIC) SYSTEM B 3. 5 . 1        EC CS- 0 pe r a t i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B 3 . 5 . 1 - 1 B 3.5 . 2         EGGS ShtltdmmRPV Water Inventory Control ... ...... .. . B 3.5 . 2-1 B 3 . 5.3         IC System . . .. . ... . . .. ... .. .. .... . ... .... ... . .. . . . .. . B 3.5 . 3-1 B 3.6          CONTAINMENT SYSTEMS B 3 . 6 . 1.1     Primary Containment . .. . .... . . .. ..................... B 3 . 6.1 . 1-1 B 3 . 6 .1. 2     Primary Containment Air Lock .......... . ............. B 3 . 6 . 1. 2-1 B 3 . 6 . 1.3     Primary Containment Isolation Valves (PCIVs) . . . . . ... B 3 . 6 . 1. 3-1 B 3 . 6.1.4       Drywell Pressure .. . .. . ........ . . . ............. . .... . B 3 . 6 . 1 . 4-1 B 3 . 6.1.5       Drywell Air Temperature . .. . . .. ....... .. .. . .. ..... ... B 3 . 6 . 1 . 5-1 B 3 . 6 . 1.6     Low Set Relief Valves .. ... . . ... . ..... . .. . ... ... ..... B 3 . 6 . 1.6-1 B 3 . 6 . 1.7     Reactor Building-to-Suppression Chamber Vacuum Breakers . .... . . . .. ... .. . . ......................... B 3 . 6 . 1 . 7-1 B 3.6.1.8         Suppression Chamber-to-Drywell Vacuum Breakers . .. .. . B 3.6.1.8-1 B 3. 6. 2. 1      Suppression Pool Average Temperature ... ....... ..... . B 3.6.2.1-1 B 3.6.2 . 2       Suppression Pool Water Level .. . .. . ... . . . . ... . .... . . . B 3.6 . 2.2-1 B 3.6 . 2 . 3     Suppression Pool Cooling .. .. .. . ....... ..... ... ..... . B 3 . 6 . 2.3-1 B 3. 6 . 2 . 4    Suppression Pool Spray . . . ... . .... . ........ . . . .. . . .. . B 3 . 6 . 2.4-1 B 3.6 . 2 . 5     Drywell-to-Suppression Chamber Differential Pressure . ..... . .. .. .... .. .. . . .. ....... . .. .. . .. . ... B 3.6.2 . 5-1 B 3. 6 . 3 . 1    Primary Containment Oxygen Concentration ....... .. .. . 8 3 . 6.3 . 1-1 B 3 . 6.4 . l     Secondary Containment .. ..... . ... ........ .......... . . B 3. 6 . 4 . 1-1 B 3. 6. 4 . 2     Secondary Containment Isolation Valves CSCIVs) . ... . . B 3 . 6 . 4.2-1 B 3 . 6.4 . 3     Standby Gas Treatment (SGT) System ..... .. ...... . . . . . B 3.6.4 . 3-1 B 3.7          PLANT SYSTEMS B 3 . 7. 1        Containment Cooling Service Water (CCSW) System . . .. . B                                           3 . 7 . 1-1 B 3. 7. 2         Diesel Generator Cooling Water ( DGCW) System ........ B                                             3 . 7 . 2-1 B 3 . 7. 3        Ultimate Heat Sink (UHS) .... .. ................ . ..... B                                          3 . 7 . 3-1 B 3. 7.4          Control Room Eme rgency Ventilation CCR EV) System .... B                                            3 . 7.4- 1 (continued)
Dresden 2 and 3                                             ii                                                        Revision

ECCS Instrumentation B 3 . 3 . 5.1 BASES APPLICABLE       Function must have a required number of OPERAB LE channels, SAFETY ANALYSES, with their setpoints within the specified Allowable Values, LCO, and         where appropriate . The actual setpoint is calibrated APPLICABILITY    consistent with applicable setpoint methodology assumptions.
(continued)   The Table 3 . 3.5 . 1-1, footnote~ is added to show that certain ECCS instrumentation Functions are also required to be OPERABLE to perform DG initiation .
Allowable Values are specified for each ECCS Function specified in the Table . Nominal trip setpoints are specified in the setpoint calculations . The nominal setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS.
Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable . A channel is inoperable if its actual trip setpoint is not within its required Allowable Value . Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g . , reactor vessel water level), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e . g.,
trip unit) changes state. The analytic limits are derived from the limiting values of the process parameters obtained from the safety analysis. The trip setpoints are determined from the analytic limits, corrected for defined process, calibration, and instrument errors . The Allowable Values are then determined, based on the trip setpoint values, by accounting for the calibration based errors . These calibration based e rrors are limited to reference accuracy, instrument drift, errors associated with measurement and test equipment, and calibration tolerance of loop components . The trip setpoints and Allowable Values determined in this manner provide adequate protection because instrument uncertainties, process effects, calibration tolerances, instrument drift, and severe environment errors (for channels that must function in harsh environments as defined by 10 CFR 50 . 49) are accounted for and appropriately applied for the instrumentation .
Some Functions (i .e, Functions l.c , l.d, 2 . c, 4 . d, 4 . e , 5.d, and 5 . e) have both an upper and lower analytic limit that must be evaluated . The Allowable Values and trip setpoints (continued)
Dresden 2 and 3                   B 3.3.5.1-10                           Revision

ECCS Instrumentation B 3.3 . 5 . 1 BASES APP LI CABLE     l . a . 2.a. Reactor Vessel Water Level-Low Low     (continued)
SAFETY ANALYSES, LCO, and         The Reactor Vessel Water Level-Low Low Allowable Value is APPLICABILITY    chosen to allow time for the low pressure core flooding systems to activate and provide adequate cooling .
Four channels of CS Reactor Vessel Water Level-Low Low Function are only required to be OPERABLE when the CS or DG(s) are required to be OPERABLE to ensure that no single instrument failure can preclude CS and DG initiation . Also, four channels of the LPCI Reactor Vessel Water Level - Low Low Function are only required to be OP ERABLE when the LPCI System is required to be OPERABLE to ensure no single instrument failure can preclude LPCI initiation.          Refer to LCO 3.5.l and LCO 3.5.2, "EGGS Shb1tdmm," for Applicability Bases for the 10*,1 pressblre EGGS sblbsystems; LCO 3.B.l, "AC Soblrces Operating"; and LCO 3. g. 2, "/\C Soblrces Shbltdo*,m,"
for Applicability Bases for the DGs.
: 1. b. 2 . b. Drywe 11 Pressure-High High pressure in the drywell could indicate a break in the reactor coolant pressure boundary CRCPB). The low pressure ECCS and associated DGs are initiated upon receipt of the Drywell Pressure-High Function in order to minimize the possibility of fuel damage . The Drywell Pressure-High Function, along with the Reactor Water Level-Low Low Function, is directly assumed in the LOCA analysis (Ref. 2).
The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 10 CFR 50 . 46 .
High drywell pressure signals are initiated from four pressure switches that sense drywel 1 pressure . The Allowable Value was selected to be as low as possible and be indicative of a LOCA inside primary containment .
The Drywell Pressure-High Function is required to be OPERABLE when the ECCS or DG is required to be OPERABLE in conjunction with times when the primary containment is required to be OPERABLE . Thus, four channels of the CS Drywell Pressure- High Function are required to be (continued)
Dresden 2 and 3                   B 3.3 . 5 . 1-12                     Revision

ECCS Instrumentation B 3.3 . 5.l BASES APPLICABLE       l . c . 2 . c . Reactor Steam Dome Pressure-Low (Permissive)
SAFETY ANALYSES, (continued)
LCO, and APPLICABILITY    Two channels of Reactor Steam Dome Pressure-Low Function are only required to be OPERABLE when the ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude ECCS initiation . Refer to LGO 3.5.l and LGO 3.5.2 for Applicability gases for the low press~re EGGS s~bsystems .
l.d . 2 . f . Core Spray and Low Pressure Coolant Injection Pump Discharge Flow- Low (Bypass)
The minimum flow instruments are provided to protect the associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not sufficiently open. The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump .
The CS Pump Discharge Flow-Low (Bypass) Function is assumed to be OPERABLE and capable of closing the minimum flow valves to ensure that the CS flow assumed during the transients and accidents analyzed in References 1, 2, and 3 is met . The LPCI Pump Discharge Flow-Low (Bypass) Function is only required to be OPERABLE for opening since the LPCI minimum flow valves are assumed to remain open during the transients and accidents analyzed in References 1, 2, and 3.
The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the lim i ts of 10 CFR 50 . 46 .
One flow transmitter per CS pump and one flow transmitter per LPCI subsystem are used to detect the associated subsystems' flow rates . The logic is arranged such that each transmitter causes its associated minimum flow valve to open when flow is low with the pump running. The logic will close the minimum flow valve once the closure setpoint is exceeded . The Pump Discharge Flow- Low (Bypass) Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump. The Core Spray Discharge Flow-Low ( Bypass) Allowable Value is also low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core . For LPCI, the closure of the minimum flow valves is not credited .
(continued)
Dresden 2 and 3                     B 3 . 3.5 . 1-14                     Revision

ECCS Instrumentation B 3. 3. 5. 1 BASES APPLICABLE       l.d . 2 . f . Core Spray and Low Pressure Coolant Injection SAFETY ANALYSES, Pump Discharge Flow-Low (Bypass) (continued)
LCO, and APPLICABILITY    Each chann e l of Pump Discharge Flow-Low (Bypass) Function (two CS channels and two LPCI channels) is only required to be OPERABLE when the associated ECCS is required to be OPERABLE to ensure that no single instrument failure can preclude the ECCS function . Refer to LGO 3 . 5 . 1 and LGO 3 . 5 . 2 f or Applicabi l ity Bases for the low pressyre EGGS sybsystems .
1 . e . 2 . e . Core Spray and Low Pressure Coolant Injection Pump Start- Time Delay Relay The purpose of this time delay is to stagger the start of CS and LPCI pumps that are in each of Divisions 1 and 2, thus limiting the starting transients on the 4160 V ESS buses .
This Function is only necessary when power is being supplied from the standby power sources (DG). The CS and LPCI Pump Start-Time Delay Relays are assumed to be OPERABLE in the accident and transien t analyses requiring ECCS initiation .
That is, the analyses assume that the pumps will initiate when required and excess loading will not cause failure of the power sources.
There are two CS Pump Start-Time Delay Relays and two LPCI Pump Start-Time Delay Relays, one for each CS pump and one for LPCI pump B and D. While each time delay relay is dedicated to a single pump start logic, a single failure of a LPCI Pump Start-Time Delay Relay could result in the failure of the three low pressure ECCS pumps, powered from the same ESS bus, to perform their intended function (e . g . ,
as in the case where both ECCS pumps on one ESS bus start simultaneously due to an inoperable time delay relay) . This still leaves three of the six low pressure ECCS pumps OPERABLE; thus, the single failure criterion is met (i.e . ,
loss of one instrument does not preclude ECCS initiation) .
The Allowable Values for the CS and LPCI Pump Start-Time Delay Relays are chosen to be short enough so that ECCS operation is not degraded.
Each CS and LPCI Pump Start-Time Delay Relay Function is required to be OPERABL E only when the associated LPCI subsystem is required to be OPERABLE . Refer to LGO 3 . 5 . l and LGO 3 . 5.2 for Applicability Bases for the GS and LPGI sybsystems .
(continued)
Dresden 2 and 3                      B 3 . 3.5 . 1-15                     Revision

ECCS Instrumentation B 3.3.5.1 BASES ACTIONS         B.l. B.2    and B.3  (continued) systems lose initiation capability. (e) two or more Function 2 . d channels are inoperable and untripped such that both trip systems lose initiation capability, or (f) two Function 2.j channels are inoperable and untripped. For low pressure ECCS, since each inoperable channel would have Required Action B.1 applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected portion of the associated system of low pressure ECCS and DGs to be declared inoperable. However, since channels in both associated low pressure ECCS subsystems (e.g . , both CS subsys tem s) are inoperable and untripped, and the Completion Times started concurrently for the channels in both su bsystems , this results in the affected portions in the associated low pressure ECCS and DGs being concurrently declared inoperable. For Required Action B.2, redundant automatic initiation capability (i.e., loss of automatic start capability for Functions 3 . a and 3 .b ) is lost if two Function 3.a or two Function 3.b channels are inoperable and untripped in the same trip sys tem .
In this situation (loss of redundant automatic initiation capability), the 24 hour allowance of Required Action B.3 is not appropriate and the feature(s) associated with the inoperable, untripped channels must be declared inop erab le within 1 hour. As noted (Note 1 to ReqYired Action B.l),
ReqYired Action B.l is only applicable in MODES 1, 2, and 3.
In MODES 4 and 5, the specific initiation time of the 1011 pressYre EGGS is not assYmed and the probability of a LOGA is lower . ThYs, a total loss of initiation capability for 24 hoYrs (as allowed by ReqYired Action B.3) is allowed dYring MODES 4 and 5. There is no similar Note provided for ReqYired Action B.2 since HPCI instrYmentation is not reqYired in MODES 4 and 5; thYs, a Note is not necessary .
Notes A note ~i s also provided ( the Note-- to Required Action B. 1 and the Note to Required Action B.2) to delineate which Required Action is applicable for each Function that requires entry into Condition B if an associated channel is inoperable. This ensures that the proper loss of initiation capability check is performed .
The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal (continued)
Dresden 2 and 3                  B 3.3.5.1-30                         Revision

ECCS Instrumentation B 3.3.5 . l BASES ACTIONS         C.l and C. 2   (continued) channels are inoperable in both trip systems, (c) two Function l.e channels are inoperable, (d) two Function 2.e channels are inoperable, (e) two or more Function 2 . g channels, associated with a recirculation pump are inoperable such that both trip systems lose initiation capability, (f) two or more Function 2.h channels are inoperable such that both trip systems lose initiation capability, (g) two Function 2 . i channels are inoperable, or (h) two Function 2.k channels are inoperable. Since each inoperable channel would have Required Action C.l applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected portion of the associated system to be declared inoperable. However, since channels for both low pressure ECCS subsystems are inoperable (e.g.,
both CS subsystems), and the Completion Times started concurrently for the channels in both subsystems, this results in the affected portions in both subsystems being concurrently declared inoperable . For Functions l.e, and 2 . e, the affected portions are the associated low pressure ECCS pumps . For Functions l.c and 2 . c, the affected portions are the associated ECCS pumps and valves.
For Functions 2 . g, 2.h, 2 . i, and 2.k, the affected portions are the associated LPCI valves.
In this situation (loss of redundant automatic initiation capability), the 24 hour allowance of Required Action C. 2 is not appropriate and the feature(s) associated with the inoperable channels must be declared inoperable within 1 hour. As noted (Note 1), Required Action C.l is only applicable in MODES 1, 2, and 3. In MODES 4 and 5, the specific initiation time of the EGGS is not assumed and the probability of a LOGA is lower. Thus, a total loss of automatic initiation capability for 24 hours (as allowed by Required Action C.2) is allo11ed durin&sect; MODES 4 and 5.
The Note- states that Required Action C.l is only applicable for Functions l . c, l.e, 2.c, 2.e, 2 . g, 2 . h, 2.i, and 2.k. Required Action C.l is not applicable to Function 3.g (which also requires entry into this Condition if a channel in this Function is inoperable), since it is the HPCI Manual Initiation Function which is not assumed in any accident or transient analysis . Thus, a total loss of HPCI Manual (continued)
Dresden 2 and 3                  B 3.3.5.1-32                         Revision

ECCS Instrumentation B 3.3 . 5 . 1 BASES ACTIONS         D.l . D.2.1   and D. 2.2      (continued) desired to perform Required Actions D. 2 .1 and D. 2 . 2 (e . g.,
as in the case where shifting the suction source could drain down the HPCI suction piping), Condition H must be entered and its Required Action taken .
E. l and E. 2 Required Action E.l is intended to ensure that appropriate actions are taken if multiple, inoperable channels within the Core Spray and Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass) Functions result in redundant automatic initiation capability being lost for the feature(s) . For Required Action E.l, the features would be those that are initiated by Functions l.d and 2 . f (i.e . , low pressure ECCS) . Redundant automatic initiation capability is lost if (a) two Function l.d channels are inoperable or (b) two Function 2. f channels are inoperable . Since each inoperable channel would have Required Action E.l applied separately (refer to ACTIONS Note), each inoperable channel would only require the affected low pressure ECCS pump to be declared inoperable . However, since channels for more than one low pressure ECCS pump are inoperable, and the Completion Times started concurrently for the channels of the low pressure ECCS pumps, this results in the affected low pressure ECCS pumps being concurrently declared inoperable .
In this situation (loss of redundant automatic initiation capability), the 7 day allowance of Required Action E. 2 is not appropriate and the subsystem associated with each inoperable channel must be declared inoperable within 1 hour . As noted (Note 1 to ReqYired Action E.1), ReqYired Action E.l is only applicable in MODES 1, 2, and 3. In MODES 4 and 5, the specific initiation time of the EGGS is not assYmed and the probabi 1 i ty of a LOGA is 1o*.1er. ThYs, a total loss of initiation capability for 7 days (as allo*.1ed by ReqYired /\ction E. 2) is allo*.1ed dYrin9 MODES 4 and 5. A A Note is also provided ( the Note~ to Required Action E.l) to delineate that Required Action E.l is only applicable to low pressure ECCS Functions . Required Action E.l is not applicable to HPCI Function 3 . f since the loss of one (continued)
Dresden 2 and 3                  B 3 . 3 . 5.1-35                      Revision

RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3      INSTRUMENTATION B 3 . 3 . 5. 2   Reactor Pressure Vessel (RPVJ Water Inventory Control Instrumentation BASES BACKGROUND             The RPV contains penetrations below the top of the active fuel (TAFJ that have the potential to drain the reactor coolant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures .
Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSSJ for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SLJ is exceeded."
The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded . Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.
The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCD 3 . 3.5.1, "Emergency Core Cooling System (ECCSJ Instrumentation," or LCD 3 . 3.6.1, "Primary Containment Isolation instrumentation".
With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2 . 1 . 1 . 3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur . Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will (continued)
Dresden 2 and 3                        B 3 . 3 . 5 . 2- 1                 Revision

RPV Water Inventory Control Instrumentation B 3.3.5. 2 BASES BACKGROUND (continued) be 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 .
The purpose of the RPV Water Inventory Control Instrumentation is to support the requirements of LCD 3 . 5. 2, "Reactor Pressure Vessel (RPV) Water Inventory Control," and the definition of DRAIN TIME . There are functions that are required for manual operation of the ECCS injection/spray subsystem required to be OPERABLE by LCD 3 . 5 . 2 and other functions that support automatic isolation of Shutdown Cooling (SDCJ and Reactor Water Cleanup (RWCUJ system penetration flow path(s) on low RPV water level .
The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCJ) . The equipment involved with each of these systems is described in the Bases for LCD 3 . 5.2.
APPLICABLE        With the unit in MODE 4 or 5, RPV water inventory control is SAFETY ANALYSES,  not required to mitigate any events or accidents evaluated LCD, and          in the safety analyses. RPV water inventory control is APPLICABILITY     required in MODES 4 and 5 to protect Safety Limit 2 . 1. 1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur .
A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems . Instead, an event is postulated in which a single operator error or initiating event a11ows draining of the RPV water inventory 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 . g. , seismic event, Joss of normal power, single human error) . It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually operated to maintain adequate reactor vessel water level .
(continued)
Dresden 2 and 3                    B 3 . 3 . 5 . 2- 2                   Revision

RPV Water Inventory Control Instrumentation B 3.3 . 5 . 2 BASES APPLICABLE       As discussed in References 1, 2, 3, 4, and 5, operating SAFETY ANALYSES, experience has shown RPV water inventory to be significant LCD, and         to public heal th and safety . Therefore, RPV Water Inventory APPLICABILITY    Control satisfies Criterion 4 of 10 CFR 50.36(c)(2J(ii) .
(continued)
Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.
The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.
Core Sorav and Low Pressure Coolant Infection Systems l.a. 2.a. Reactor Steam Dome Pressure-Low (Permissive)
Low reactor steam dome pressure signals are used as permi ss i ves for the low pressure ECCS subsystems. This ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure-Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS .
The Reactor Steam Dome Pressure-Low (Permissive) signals are initiated from two pressure switches that sense the reactor steam dome pressure.
The Allowable Value is low enough to prevent overpressurizing the equipment in the low pressure ECCS.
Two channels of Reactor Steam Dome Pressure-Low Function are only required to be OPERABLE in MODES 4 and 5 when ECCS is required to be OPERABLE by LCD 3.5.2.
(continued)
Dresden 2 and 3                    B 3 . 3 . 5 . 2-3                  Rev i sion

RPV Water Inventory Control Instrumentation B 3.3. 5. 2 BASES APPLICABLE       1.b. 2.b. Core Sorav and Low Pressure Coolant Iniection SAFETY ANALYSES, Pump Discharge Fl ow-Low CBvpass)
LCO, and APPLICABILITY    The minimum flow instruments are provided to protect the (continued)   associated low pressure ECCS pump from overheating when the pump is operating and the associated injection valve is not sufficiently open.       The minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump.
One fl ow transmitter per CS pump and one fl ow transmitter per LPCI loop are used to detect the associated subsystems' flow rates . The logic is arranged such that each transmitter causes its associated minimum flow valve to open when flow is low with the pump running .       The logic will close the minimum flow valve once the closure setpoint is exceeded . The Pump Discharge Fl ow-Low (Bypass) Allowable Values are high enough to ensure that the pump flow rate is sufficient to protect the pump .       The Core Spray Discharge Flow-Low (Bypass) Allowable Value is also low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core .       For LPCI, the closure of the minimum flow valves is not credited.
Each channel of Pump Discharge Flow-Low (Bypass) Function is only required to be OPERABLE in MODES 4 and 5 when the associated ECCS subsystem is required to be OPERABLE by LCD 3.5.2 to ensure the pumps are capable of injecting into the RPV when manually operated .
(continued)
Dresden 2 and 3                    B 3 . 3 . 5 . 2-4                     Revision

RPV Water Inventory Control Instrumentation B 3 . 3 . 5.2 BASES APPLICABLE       Shutdown Cooling CSDCJ Svstem Isolation SAFETY ANALYSES, LCO , and        3 . a - Reactor Vessel Water Level-Low APPLICABILITY (continued)  The definition of Drain Time allows crediting the closing of penetration flow paths that are 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 . The Reactor Vessel Water Level-Low Function associated with SDC System isolation may be credited for automatic isolation of penetration flow paths associated with the SDC System .
The Reactor Vessel Water Level-Low Function receives input from four reactor vessel water level channels. Each channel inputs into one of four trip strings . Two trip strings make up a trip system and both trip systems must trip to cause an isolation of the SDC suction isolation valves . Any channel will trip the associated trip string . Only one trip string must trip to trip the associated trip system . The trip strings are arranged in a one-out-of-two taken twice logic to initiate isolation . Therefore, one trip string in each trip system is required to provide for automatic SOC system isolation .
The Reactor Vessel Water Level-Low Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level-Low Allowable Value (LCO 3 . 3 . 6. 1), since the capability to cool the fuel may be threatened .
The Reactor Vessel Water Level-Low Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME .
Shutdown Cooling System Isolation Functions isolate some Group 3 valves (SDC isolation valves) .
(continued)
Dresden 2 and 3                     B 3 . 3.5 . 2- 5                    Revision

RPV Water Inventory Control Instrumentation B 3.3. 5. 2 BASES APPLICABLE       Reactor Water Cleanup CRWCU) System Isolation SAFETY ANALYSES, LCD, and         4 . a - Reactor Vessel Water level-Low APPLICABILITY (continued)   The definition of Drain Time allows crediting the closing of penetration flow paths that are 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 .       The Reactor Vessel Water Level-Low Function associated with RWCU System isolation may be credited for automatic isolation of penetration flow paths associated with the RWCU System.
The Reactor Vessel Water Level-Low Isolation Function receives input from four reactor vessel water level channels . Each channel inputs into one of four trip stings.
Two trip strings make up a trip system and both trip sy tems must trip to cause an isolation of the RWCU valves . Any channel will trip the associated trip string . Only one trip string must trip to trip the associated trip system .       The trip strings are arranged in a one-out-of-two taken twice logic to initiate isolation .      Therefore, one trip string in each trip system is required to provide for automatic RWCU system isolation .
The Reactor Vessel Water Level-Low Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level-Low Allowable Value (LCD 3 . 3 . 5.1), since the capability to cool the fuel may be threatened .
The Reactor Vessel Water Level-Low Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.
RWCU Functions isolate some Group 3 valves (RWCU isolation valves) .
(continued)
Dresden 2 and 3                   B 3 . 3 . 5 . 2-6                     Revision

RPV Water Inventory Control Instrumentation B 3 . 3 . 5.2 BASES   (continued)
ACTIONS             A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels .
Section 1. 3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components , or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition .
Section 1. 3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel .
Required Action A. l directs entry into the appropriate Condition referenced in Table 3 . 3 . 5. 2 - 1 . The applicable Condition referenced in the table is Function dependent.
Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition .
8.1 and 8 . 2 Shutdown cooling (SOC) system Isolation, Reactor Vessel Water Level-Low, and Reactor Water Cleanup System, Reactor Vessel Water Level-Low functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating Drain Time . If the instrumentation is inoperable, Required Action 8. 1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation . Required Action 8 . 2 directs calculation of DRAIN TIME . The calculation cannot credit automatic isolation of the affected penetration flow paths .
(continued)
Dresden 2 and 3                      B 3.3.5 . 2- 7                          Revision

RPV Water Inventory Control Instrumentation B 3.3. 5. 2 BASES ACTIONS (continued)
Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions . If a required channel of the permissive is inoperable, manual operation of ECCS may be prohibited. Therefore, the affected channel(s) must be placed in the trip condition within 1 hour . With the affected channel(s) in the trip condition, manual operation may be performed .
The Completion Time of 1 hour is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in the trip condition .
If a CS or LPCI Pump Discharge Fl ow-Low bypass function is inoperable, there is a risk that the associated low pressure ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the system to ensure the pump does not overheat .
The 24 hour Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the minimum flow valves and to manually ensure the pump does not overheat .
With the Required Action and associated Completion Time of Condition C or 0 not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately .
(continued)
Dresden 2 and 3                 B 3.3 . 5 . 2-8                     Revision

RPV Water Inventory Control Instrumentation B 3.3.5 . 2 BASES   (continued SURVEILLANCE       As noted in the beginning of the SRs, the SRs for each RPV REQUIREMENTS       Water Inventory Control instrumentation Function are found in the SRs column of Table 3 . 3 . 5. 2-1 .
SR 3 . 3 . 5. 2. 1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred . A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels . It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value .
Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious . A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST .
Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability . If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit .
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO .
SR    3 . 3.5 . 2 . 2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function . A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay . This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests.
(continued)
Dresden 2 and 3                          B 3.3.5 . 2-9                      Revision

RPV Water Inventory Control Instrumentation B 3. 3. 5. 2 BASES SURVEILLANCE    SR  3 . 3.5.2 . 2 (continued)
REQUIREMENTS Any setpoint adjustment shall be consistent with the assumptions of the current plant-specific setpoint methodology .
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
REFERENCES      1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984 .
: 2. Information Notice 86-74, "Reduction of Reactor Cool ant Inventory Because of Misalignment of RHR Valves," August 1986 .
: 3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), "August 1992.
: 4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"
May 1993.
: 5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1,"
July 1994 .
Dresden 2 and 3                   B 3 . 3.5 . 2-10                  Revision

IC System Instrumentation B 3 . 3.5 . .iJ B 3.3       INSTRUMENTATION B 3 . 3 . 5 . ~3   Isolation Condenser (IC) System I nstrumentation BASES BACKGROUND             The purpose of the IC System instrumentation is to initiate actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser). A more complete discussion of IC System operation is provided in the Bases of LCO 3 . 5 . 3 ,
                       "IC System . "
The IC System may be initiated by either automatic or manual means. Automatic initiation occurs for sustained conditions of reactor vessel pressure high . The variable is monitored by four pressure switches that are connected to four time delay relays . The outputs of the time delay relays are connected in a one-out-of-two logic to a trip relay . The output of the trip relays are connected in a two-out-of-two logic arrangement . Once initiated, the IC logic can be overridden by the operator.
APPLICABLE             The function of the IC System to provide core cooling to SAFETY ANALYSES        the reactor is used to respond to a main steam line isolation event. Although the IC System is an Engineered Safety Feature System, no credit is taken in the accident analyses for IC system operation . Based on its contribution to the reduction of overall plant risk, however, the IC System, and therefore its instrumentation, satisfies Criterion 4 of 10 CFR 50 . 36(c)(2)(ii) .
LCD                    The OPERABILITY of the IC System instrumentation is dependent upon the OPERABILITY of the four channels of the Reactor Vessel Pressure-High Function . Each channel must have its setpoint within the Allowable Value specified in SR 3.3 . 5 . 2.2. The actual setpoint is calibrated consistent with applicable setpoint methodology assumptions.
The Allowable Value for the IC System instrumentation Function is specified in the SR . Nominal trip setpoints are spec i fied i n the setpoint calculat i ons . The nomina l setpoints are selected to ensure that the setpoints do not exceed the Allowable Value between CHANNEL CALIBRATIONS.
(continued)
Dresden 2 and 3                           B 3 . 3.5 . 3-1                     Revision

IC System Instrumentation B 3.3.5. iJ BASES LCO             Operation with a trip setpoint less conservative than the (continued) nominal trip setpoint, but within its Allowable Value, is acceptable . A channel i s inoperable if its actual trip setpoint is not within its required Allowable Value. Trip setpoints are those predetermined values of output at which an action should take place. The setpoints are compared to the actual process parameter (e.g . , reactor vessel pressure), and when the measured output value of the process parameter exceeds the setpoint, the associated device (e.g . ,
relay) changes state . The analytic limits (or design limits) are derived from the limiting values of the process parameters obtained from the safety analysis. The trip setpoints are determined from the analytic limits, corrected for defined process, calibration, and instrument errors.
The Allowable Values are then determined, based on the trip setpoint values, by accounting for the calibration based errors. These calibration based errors are limited to reference accuracy, instrument drift, errors associated with measurement and test equipment, and calibration tolerance of loop components . The trip setpoints and Allowable Values determined in this manner provide adequate protection because instrument uncertainties, process effects, calibration tolerances, instrument drift, and severe environment errors (for channels that must function in harsh environments as defined by 10 CFR 50.49) are accounted for and appropriately applied for the in strumentat ion.
The Reactor Vessel Pressure-High Allowable Value is set high enough to ensure that a potential event is in process.
The time delay is determined by engineering judgement to avoid spurious unnecessary activations of the IC by allowing time for the pressure spike, caused by a main steam isolation valve or stop valve closure, to decay .
Four channels of Reactor Vessel Pressure-High Function are available and are required to be OPERABLE when IC is required to be OPERABLE to ensure that no single instrument failure can preclude IC initiation.
APPLICABILITY   The Function is required to be OPERABLE in MODE 1, and in MODES 2 and 3 with reactor steam dome pressure > 150 psig since this is when IC is required to be OPERABLE. (Refer to LCO 3.5.3 for Applicability Bases for the IC System.)
(continued)
Dresden 2 and 3                 B 3.3.5.3-2                          Revision

IC System Instrumentation B 3 . 3.5 .i J BASES   (continued)
ACTIONS             A Note has been provided to modify the ACTIONS related to IC System instrumentation channels. Section 1 . 3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems , components, or variables
                  . expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition . Section 1 . 3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition . However, the Required Actions for inoperable IC System instrumentation channels provide appropriate compensatory measures for separate inoperable channels . As such, a Note has been provided that allows separate Condition entry for each inoperable IC System instrumentation channel.
A.l and A. 2 Required Action A. l is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels result in a complete loss of automatic initiation capability for the IC System . In this case, automatic initiation capability is lost if two channels associated with the same trip relay are inoperable and untripped . In this situation (loss of automatic initiation capability),
the 24 hour allowance of required Action A.2 is not appropriate, and the IC System must be declared inoperable within 1 hour after discovery of loss of IC initiation capability.
The Comple ti on Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock . "
For Required Action A.1 , the Completion Time only begins upon discovery that the IC System cannot be automatically initiated due to two or more inoperable, untripped Reactor Vessel Pressure-High channels. The 1 hour Completion Time for discovery of loss of initiation capability is acceptable because it minimizes risk while allowing time for restoration or tripping of channels .
(continued)
Dresden 2 and 3                      B 3 . 3.5 . 3-3                    Revision

IC System Instrumentation B 3.3 . 5 . .iJ BASES ACTIONS         A.l and A. 2          (continued)
Because of the redundancy of sensors available to provide initiation signals and the fact that the IC System is not assumed in any accident or transient analysis, an allowable out of service time of 24 hours has been shown to be acceptable (Ref . 1) to permit restoration of any inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Ac t ion A. 2 . Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure, and allow operation to continue.
Alternately, if it is not desired to place the channel in trip (e . g., as in the case where placing the inoperable channel in trip would result in an initiation), Condition B must be entered and its Required Action taken .
With any Required Action and associated Completion Time of Condition A not met, the IC System may be incapable of performing the intended function, and the IC System must be declared inoperable immediately.
SURVEILLANCE    The Surveillances are modified by a Note to indicate that REQUIREMENTS    when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours provided the Reactor Vessel Pressure-High Function maintains initiation capability . Upon completion of the Surveillance, or expiration of the 6 hour allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.
SR  3 . 3 . 5 . .i3 . 1 A CHANN EL FUNCTIONAL TEST is performed on each required channel to ensure that the channel wi 11 perform the intended function . A successful test of the required contact(s) of a channel relay may be performed by the verification of the (continued)
Dresden 2 and 3                         B 3 . 3 . 5.3-4                Revision

IC System Instrumentation B 3 . 3 . 5. iJ BASES SURV EIL LANCE  SR  3 . 3 . 5 . ~3 .l  (continued)
REQUIREMENTS change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay . This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.
Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology .
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR  3 .3.5. iJ .2 and SR       3 . 3. 5. iJ . 3 A CHANN EL CA LIB RATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy . CHANNEL CA LIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology. A Note to SR 3 . 3 .5. 3 .2 states that this SR is not required for the time delay portion of these channels.
This allowance is consistent with the plant specific setpoint methodology . This portion of the channels must be calibrated in accordance with SR 3.3.5 . 3.3.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
(continued)
Dresden 2 and 3                       B 3.3.5 . 3-5                           Revision

IC System Instrumentation B 3.3.5. ~3 BASES SURVEILLANCE    SR   3.3.5. ~3 .4 REQUIREMENTS (continued)  The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3 . 5.3 overlaps this Surveillance to provide complete testing of the safety function.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES      1. GENE-770-06-2-A, "Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-of -Service Times for Selected Instrumentation Technical Specifications," December 1992.
Dresden 2 and 3                   B 3.3.5 . 3-6                    Revision

Primary Containment Isolation Instrumentation B 3 .3.6.1 BASES APPLICABLE       6.b . Reactor Vessel Water Level-Low SAFETY ANALYSES, LCO, and         Low RPV water level indicates that the capability to cool APPLICABILITY    the fuel may be threatened . Should RPV water level decrease (continued)   too far, fuel damage could result. Therefore, isolation of some reactor vessel interfaces occurs to begin isolating the potential sources of a break. The Reactor Vessel Water Level-Low Function associated with Shutdown Cooling System isolation is not directly assumed in safety analyses because a break of the Shutdown Cooling System is bounded by breaks of the recirculation and MSL. The Shutdown Cooling System isolation on low RPV water level su pports actions to ensure that the RPV water level does not drop below the top of the active fuel during a vessel draindown event caused by a leak (e .g., pipe break or inadvertent valve opening) in the Shutdown Cooling System.
Reactor Vessel Water Level - Low signals are initiated from four differential pressure transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. Four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Function are available and are required to be OPERABLE to ensure that no single in strument failure can preclude the isolation function. As noted (footnote (b) to Table 3.3.6.l 1), only one channel per trip system (with an isolation signal available to one shYtdown cooling pYmp sYction isolation valve) of the Reactor Vessel Water Level Low FYnction is re~Yired to be OPERABLE in MODES 4 and 5, provided the ShYtdo11n Cooling System integrity is maintained . System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel throYgh the system.
The Reactor Vessel Water Level-Low Allowable Value was chosen to be the same as the RPS Reactor Vessel Water Level -Low Allowable Value (LCO 3.3.1 .1 ), since the capability to cool the fuel may be threatened.
The Reactor Vessel Water Level-Low Function is only required to be OPERABLE in MODE& 3 , 4, and 5 to prevent this potential flow path from lowering the reactor vessel level to the top of the fuel . In MODES 1 and 2, another isolation (i .e., Recirculation Line Water Temperature-High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this Dresden 2 and 3                  B 3 . 3 .6.1 -19                    Revision

Primary Containment Isolation Instrumentation B 3. 3. 6. 1 BASES APPLICABLE          6. b . React0r Vessel 1Alater Level L0w ( rnnti nbled)
SAFET Y /\NAL YS ES LCO, and            The React0r Vessel 111ater Level L0w Fblncti 0n is 0nly
/\PPLIC/HlILITY     re~blired t0 be OPERABLE in MODES 3, 4, and 5 to prevent this potential fl 01.* path from l o*.ieri ng the reaGtor vessel level to the top of the fblel . In MODES 1 and 2, another i sol ati on (i.e., Recircbllation Line Water Temperatblre ~igh) and administrative controls ensblre that this flo11 path remains isolated to prevent blnexpected loss of inventory via this fl mi path.
This Fbincti on isolates the Group 3 shbltdo .m cooling *1al ves .
1 ACTIONS             A Note has been provided to modify the ACTIONS related to primary containment isolation instrumentation channels .
Section 1 . 3, Completion Times, specifies that once a Condition has been entered, subsequent divi s ions, subsystems, components, or variables expressed in the Condition, di s covered to be inoperable or not within limits, will not result in separate entry into the Condition .
Section 1. 3 also speci f ies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable primary containment isolation instrumentation channel s provide appropriate compen satory measures for separate inoperable channel s . As such, a Note has been provided that allow s separate Condition entry for each inoperable pr imary containment isolation in strumentation channel .
Becau s e of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours or 24 hour s , depending on the Function (12 hour s for those Functions that have channel components common to RPS instrumentation and 24 hours for those Functions that do not have channel components common to RPS instrumentation), has been shown to be acceptable (Refs . 8 and 9) to permit restoration of any inoperable channel to OPERABLE status .
This out of service time is only acceptable provided the associated Function is still maintaining isolation capability (refer to Required Action B. 1 Bases) . If the inoperable channel cannot be restored to OPERABLE s tatus within the al l owab l e out of service time, the channel must be placed in the tripped condition per Required Action A.1 .
Placing the inoperable channel in trip would conservatively Dresden 2 and 3                       B 3 . 3 . 6.1 -21                     Revision

Secondary Containment Isolation Instrumentation B 3.3 . 6.2 BASES APPLICABLE       The specific Applicable Safety Analyses, LCO, and SAFETY ANALYSES, Applicability discussions are listed below on a Function by LCO, and          Function basis.
APPLICABILITY (continued)
: 1. Reactor Vessel Water Level-Low Low reactor pressure vessel (RPV) water level indicates that the capability to cool the fuel may be threatened . Should RPV water l evel decrease too far, fuel damage could result .
An isolation of the secondary containment and actuation of the SGT System are initiated in order to minimize the potential of an offsite dose release . The Reactor Vessel Water Level - Low Function is one of the Functions assumed to be OPERABLE and capable of providing isolation and initiation signals . The isolation and initiation of systems on Reactor Vessel Water Level-Low support actions to ensure that any offsite releases are within the limits calculated in the safety analysis (Ref. 2) .
Reactor Vessel Water Level-Low signals are initiated from differential pressure transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel . Four channels of Reactor Vessel Water Level-Low Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function .
The Reactor Vessel Water Level-Low Allowable Value was chosen to be the same as the Reactor Protection System (RPS)
Reactor Vessel Water Level-Low Allowable Value (LCO 3.3 . 1.1, "Reactor Protection System (RPS)
Instrumentation"), since this could indicate that the capability to cool the fuel is being threatened .
The Reactor Vessel Water Level-Low Function is required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists in the Reactor Coolant System (RCS); thus, there is a probability of pipe breaks resulting in significant releases of radioactive steam and gas . In MODES 4 and 5, the probab i lity and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES; thus, this Function i s not required . In addition, the (continued)
Dresden 2 and 3                    B 3 . 3 . 6 . 2-4                  Revision

Secondary Containment Isolation Instrumentation B 3.3.6 . 2 BASES APPLICABLE        2. Drywell Pres sure-High 1 . Reactor Vessel \..'ater Level L011 (con ti n1:1ed)
SAFETY ANALYSES, LCO, and          High drywell pressure can indicate a break in the reactor F1:1nction is also req1:1ired to be OPERABLE during operations APPLICABILITY     coolant pressure boundary (RCPB) . An isolation of the w-i--t-R a potential for draining the reactor vessel COPDRl/s) to ensure that offsite dose limits are not exceeded if core damage occurs.
(continued)   secondary containment and actuation of the SGT System are initiated in order to minimize the potential of an offsite dose release. The isolation and initiating of the systems on Drywell Pressure-High supports action s to ensure that any offsite releases are within the limits calculated in the safety analysis (Ref. 2) .
High drywell pressure signals are initiated from pressure switches that sense the pressure in the drywel l. Four channels of Drywell Pressure-High Functions are available and are required to be OPERABLE to ensure that no sing le instrument failure can preclude performance of the isolation function.
The Allowable Value was chosen to be the same as the RPS Drywell Pressure-High Function Allowable Value (LCO 3 .3.1.1) since this i s indicative of a loss of coolant accident (LOCA).
The Drywell Pressure-High Function is required to be OPERABLE in MODES 1, 2, and 3 where considerable energy exists in the RCS; thus, there is a probability of pipe break s resulting in significant releases of radioactive steam and gas. This Function is not required in MODES 4 and 5 because the probability and consequences of these events are low due to the RCS pressure and temperature limitations of these MODES.
(continued)
Dresden 2 and 3                      B 3.3 . 6 . 2-5                    Revision

Secondary Containment Isolation Instrumentation B 3.3 . 6 . 2 BASES APPLICABLE       3 . 4 . Reactor Building Exhaust Radiation-High and SAFETY ANALYSES, Refueling Floor Radiation-Hi gh (continued)
LCO , and APPLICABILITY    be OPERABL E during OPDRVs movement of recently irradiated fuel assemblies in the secondary containment, because the capability of detecting radiation releases due to fuel failures (due to f~el ~Rcovery or dropped fuel assemblies) must be provided to ensure that offsite dose limits are not exceeded . Due to radioactive decay, these Functions are only required to isolate secondary containment during fuel handling accidents involving handl i ng recently irradiated fuel Ci . e ., fuel that has occupied part of a critical reactor core within the previous 24 hours) .
ACTIONS          A Note has been provided to modify the ACTIONS related to secondary containment isolation instrumentation channels.
Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems , components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition .
Section 1. 3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable secondary containment isolation instrumentation channels provide appropriate compensatory measures for separate inoperable channels. As such, a Note has been provided that allows separate Condition entry for each inoperable secondary containment isolation instrumentation channel .
Because of the diversity of sensors available to provide isolation signals and the redundancy of the isolation design, an allowable out of service time of 12 hours or 24 hours depending on the Function (12 hours for those Functions that have channel components common to RPS instrumentation and 24 hours for those Functions that do not have chann el components common to RPS instrumentation), has been shown to be acceptable (Refs . 3 and 4) to permit restoration of any inoperable channel to OPERABLE status.
This out of service time is only acceptable provided the associated Function is still maintaining isolation capability (refer to Required Action B.l Bases). If the inoperable channel cannot be restored to OPERABLE status (continued)
Dresden 2 and 3                     B 3 . 3.6 . 2-7                  Revision

CREV System Isolation In strumentation B 3.3.7.1 BASES LCO             CALIBRATIONS. Operation with a trip setpoint less (continued) conservative than the nominal trip setpoint, but within its Allowable Value, is acceptable. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value .
Trip setpoints are those predetermined value s of output at which an action should take place . The setpoints are compared to the actual process parameter (e . g., reactor building ventilation exhaust radiation), and when the measured output value of the process parameter exceeds the setpoint, the as sociated device (e.g. ,trip unit) changes state. The analytic limits are derived from the limiting values of the process parameters obtained from the safety analysis. The trip setpoints are determined from the analytic limits, corrected for defined process, calibration, and instrument error s . The Allowable Values are then determined, ba sed on the trip setpoint values, by accounting for the calibration based errors. These calibration based errors are limited to reference accuracy, instrument drift, errors associated with measurement and test equipment, and calibration tolerance of loop components. The trip setpoints and Allowable Values determined in this manner provide adequate pr otection because instrument uncertainties, proces s effects, calibration tolerances, instrument drift, and severe environment error s (for channel s that must function in harsh environment s a s defined by 10 CFR 50.49) are accounted for and appropriatel y applied for the instrumentation.
APPLICABILITY   The Reactor Building Ventilation System-High High Radiation Alarm Function is required to be OPERABLE in MODES 1, 2, and 3 and during movement of recently irradiated fuel assemblies in the secondary containment aRd operatioRs with a poteRtial for draiRiRg the reactor vessel (QPORVs) , to ensure that control room personnel can be protected during a LOCA, or fuel handling event , or vessel draiRdowR eveRt .
During MODES 4 and 5, when these specified conditions are not in progress (e . g. , OPORVs) , the probability of a LOCA or fuel damage is low; thus, the Functions are not required.
Also due to radioactive decay, these Functions are only required to be OPERABLE during fuel handling accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours).
(continued)
Dresden 2 and 3                 B 3 . 3.7 . 1-3                       Revision

ECCS-Operating B 3.5.l B 3.5     EMERGENCY CORE COOLING SYSTEM& (ECCS) , REACTOR PRESSURE VESSEL (RPVJ WATER INVENTORY CONTROL, AND ----Af>J..Q- ISOLATION CONDENSER (IC) SYSTEM B 3. 5. 1   ECCS-Operating BASES BACKGROUND           The ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a loss of coolant accident (LOCA) . The ECCS uses two independent methods (flooding and spraying) to cool the core during a LOCA . The ECCS network consists of the High Pressure Coolant Injection (HPCI) System, the Core Spray (CS) System, the Low Pressure Coolant Injection (LPCI) System, and the Automatic Depressurization System (ADS) . The suppression pool provides the required source of water for the ECCS.
Although no credit is taken in the safety analyses for the contaminated condensate storage tank (CCST), it is capable of providing a source of water for the HPCI, LPCI and CS systems.
On receipt of an initiation signal, ECCS pumps automatically start; the system aligns and the pumps inject water, taken either from the CCST or suppression pool, into the Reactor Coolant System (RCS) as RCS pressure is overcome by the discharge pressure of the ECCS pumps. Although the system is initiated, ADS action is delayed, allowing the operator to interrupt the timed sequence if the system is not needed.
The HPCI pump discharge pressure almost immediately exceeds that of the RCS, and the pump injects coolant into the vessel to cool the core. If the break is small, the HPCI System will maintain coolant inventory as well as vessel level while the RCS is still pressurized. If HPCI fails, it is backed up by ADS in combination with LPCI and CS . In this event, the ADS timed sequence would be allowed to time out and open the relief valves and safety/relief valve (S/RV) depressurizing the RCS, thus allowing the LPCI and CS to overcome RCS pressure and inject coolant into the vessel.
If the break is large, RCS pressure initially drops rapidly and the LPCI and CS cool the core .
Water from the break returns to the suppression pool where it is used again and again. Water in the suppression pool is circulated through a heat exchanger cooled by the Containment Cooling Service Water System . Depending on the (continued)
Dresden 2 and 3                       B 3 . 5 . 1-1                            Revision

EGGS ShYtdo1<,*nRPV Water Inventory Control B 3.5.2 B 3.5      EMERGENCY CORE COOLING SYSTEMS (ECCS) , REACTOR PRESSURE VESSEL (RPV)
WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM B 3. 5 . 2   EGGS ShYtdo*.mRPV Water Inventory Contra l BASES BACKGROUND             The RPV contains penetrations below the top of the active fuel (TAFJ that have the potential to drain the reactor cool ant inventory to below the TAF. If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1 . 1 . 3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.A description of the Core Spray (GS)
Systeff! and the Lo*,1 Pressyre Coolant Injection (LPG!) Systeffl is provided in the Bases for LGO 3 . 5 . 1, "EGGS Operatin&sect; . "
APPLICABLE             With the unit in MODE 4 or 5, RPV water inventory control is The EGGS perforff!ance is evalblated for the entire spectrblffl of SAFETY ANALYSES        not required to mitigate any events or accidents evaluated in the safety analyses. RPV water inventory contra 7 is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.break sizes for a postbllated loss of coolant accident (LOCA) .
A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulated in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which a single operator error or initiating event allows draining of the RPV water inventory 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.g., seismic event, loss of normal power, single human error) . The long terff! cooling analysis following a design basis LOCA (Ref . 1) deff!onstrates that only one low pressblre EGGS injection/spray Sblbsysteff! is reqYired, post LOCA, to fflaintain adeqYate reactor vessel
                      '.later level in the event of an inadvertent vessel drai ndo*.m.
                      - It is reasonable to assume d , based on engineering judgement, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually operated to maintain adequate reactor vessel water level . To provide redYndancy, a ffli ni lflblffl of t"rn l o*,1 pressblre EGGS Dresden 2 and 3                            B 3. 5. 2-1                              Revision

EGGS ShbAtdownRPV Water Inventory Control B 3 . 5.2 injection/spray sblbsystems are reqblired to be OPERAB LE in MODES 4 and 5.
As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety . Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50 . 36(c)(2)(ii) .
The low pressblre EGGS sblbsystems satisfy Criterion 3 of 10 CFR 50 . 36(c)(2)(ii).
(continued)
Dresden 2 and 3                   B 3 . 5 . 2-2                      Revision

EGGS Sh1,1tdownRPV Water Inventory Control B 3. 5. 2 BASES  (continued)
LCO                 The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1 . 3 .
The Limiting Condition for Operation (LCD) requires the DRAIN TIME of RPV water inventory to the TAF to be
                   ;::: 36 hours . A DRAIN TIME of 36 hours is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause 1ass of RPV water inventory and resu 1t in the RPV water level reaching the TAF in greater than 36 hours does not represent a significant challenge to Safety Limit 2.1 . 1. 3 and can be managed as part of normal plant operation .
                   +w&---One low pressure ECCS injection/spray subsystem~ -a-f'-e--is required to be OPERABLE and capable of being manually operated to provide defense-in-depth should an unexpected draining event occur . ~A low pressure ECCS injection/
spray subsyste ~ consists of .tw.&-either one Core Spray (CS) subsyste ~ ~or one~ Low Pressure Coolant Injection
( LPCI J subsystem&#xa3; . ~A CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the su ppression pool or contaminated condensate storage tan ks ( CCSTs) to the reactor press bl re ves se 1 ( RPV+ . f..a..-A.-A LPCI subsystem consists of one motor driven pump, p1p1ng, and valves to transfer water from the su ppression pool or the CCSTs to the RPV . In MODES 4 and 5, OPERABLE CCSTs can be credited to support the OPERABILITY of the required ECCS subsystem . A single LPCI pump is required per subsystem because of the similar injection capacity in relation to a CS subsystem . In addition, in MOD ES 4 and 5, the LPCI System cross-tie valves are not required to be open .
Management of gas voids is important to ECCS injection/spray subsystem OPERABILITY.
(continued)
Dresden 2 and 3                        B 3.5 . 2-3                           Revision

EGGS ShYtdownRPV Water Inventory Control B 3 . 5.2 BASES   (continYed)
APPLICABILITY       RPV water inventory control is required in MODES 4 and 5.
Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3 . 5, ECCS, RPV Water Inventory Control, and IC System . RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.
OPERABILITY of the low pressYre EGGS injection/spray sYbsystems i s reqYired in MODES 4 and 5 to ensYre adeqYate coolant inventory and syfficient heat removal capability for the irradiated fyel in the core in case of an inadvertent drai ndm:n of the 1essel. ReqYi rements for EGGS OPERABILITY 1
dYring MODES 1, 2, and 3 are discYssed in the Applicability section of the Bases for LCO 3.5.1. EGGS sybsystems are not reqYired to be OPERABLE dYring MODE 5 11ith the spent fyel storage pool gates removed and the 11ater l e 1el maintained at 1
                    > 23 ft above the RPV flange. This provides syfficient coolant inventory to allow operator action to terminate the inventory loss prior to fyel Yncovery in case of an inadvertent draindown.
The AYtomatic DepressYrization System is not reqYired to be OPERABLE dYring MODES 4 and 5 becaYse the RPV pressYre is
                    < 150 psig, and the CS System and the LPCI sYbsystems can provide core cooling 11ith0Yt any depressYrization of the primary system .
The ~igh PressYre Coolant Injection System is not reqYired to be OPERABLE dYring MODES 4 and 5 since the lo"' pressyre EGGS injection/spray SYbsystems can provide syfficient flo',1 to the vessel.
ACTIONS             A.1 and B. 1 If any onethe required low pressure ECCS injection/spray subsystem is inoperable, the inoperable sybsystemit must be restored to OPERABLE status with in 4 hours . In this Condition, the LCD controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost. the remaining OPERABLE sYbsystem can provide syfficient vessel flooding capability to recover from an inadvertent 1essel drai ndo',:n. ~0'11e 11er, 1
overall system reliability is redYced becaYse a single failYre in the remaining OPERABLE sYbsystem concYrrent with Dresden 2 and 3                       B 3.5 . 2-4                        Revision

EGGS Shbltdo*.mRPV Water Inventory Control B 3.5.2 a vessel drai ndo1m cobll d resbll t in the EGGS not being able to perform its intended fblnction . The 4 hour Completion Time for restoring the required low pressure ECCS injection/spray sub system to OPERABLE status is based on engineering judgment that considered considers the LCD controls on DRAIN TIMEthe remaining available sblbsystem and the low probability of an unexpected draining vessel draindown event that would result in loss of RPV water inventory .
(continbled)
Dre s den 2 and 3                   B 3 . 5.2 - 5                        Revision

EGGS Shbltdo*.mRPV Water Inventory Control B 3 . 5.2 ACTIOflJS       A.l and B.l        (continbled)
                .w..i-t-A--If the inoperable ECCS injection/spray subsystem is not restored to OP ERABLE status with in the required Completion Time, action must be initiated immediately initiated to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually operated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for
                ~ 36 hours.        If recirculation of injected water would occur, it may be credited in determining the necessary water volume . sblspend operations Hith a potential for dr aining the reactor vessel (QPDRVs) to minimize the probability of a vessel draindown and the sblbseqblent potential for fission prodblct release. Actions mblst continble blntil OPDRVs are sblspended.
(continued)   I Dresden 2 and 3                        B 3.5.2-6                           Revision

EGGS ShbltcfownRPV Water Inventory Control B 3 .5. 2 BASES ACTIONS             C.1. C.2 and C.3 (continued)C . l, C. 2, D. l, D. 2, and D.3 With the DRAIN TIME less than 36 hours but greater than or equal to 8 hours, compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur . Should a draining event 1ower the reactor cool ant 1eve l to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material . Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment .
The secondary containment provides a controlled volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action C.1 requires verification of the capability to establish the secondary containment boundary in less than the DRAIN TIME . The required verification confirms actions to establish the secondary containment boundary are preplanned and necessary materials are available . The secondary containment boundary is considered established when one Standby Gas Treatment (SGT) subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment . With both of the reqblired EGGS injection/spray sblbsystems inoperable, all coolant inventory makeblp capability may be blnavailable. Therefore, actions mblst immediately be initiated to sblspend OPDRVs to minimize the probability of a vessel draindmrn and the sblbseqblent potential for fission prodblct release . Actions mblst continble blntil OPDRVs are Sblspended . One reqblired EGGS injection/spray Sblbsystem mblst also be restored to OPERABLE statbls within 4 hoblrs. The 4 hoblr Completion Time to restore at least one low pressblre EGGS injection/spray sblbsystem to OPERABLE statbls ensblres that prompt action will be taken to provide the reqblired coolins capacity or to initiate actions to place the plant in a condition that minimizes any potential fission prodblct release to the en~'i ronmen t .
I f at least one reqbl i red 10*.1 pressblre EGGS injection/spray sblbsystem is not restored to OP ERABLE statbls 1.*i thin the 4 hoblr Completion Time, additional actions are reqblired to minimize any potential fission prodblct release to the environment . This inclbldes ensblrins secondary containment is OPERABLE; one standby sas treatment Sblbsystem is OPERABLE; and secondary containment isolation capability is Dresden 2 and 3                        B 3 .5. 2-7                            Revision

EGGS Shbl t do wn RPV Water Inventory Control B 3.5.2 a vailable i n each associated pene t ratio n fl o*..* path not Verification that the secondary containment boundary can be established must be performed within 4 hours . The required verification is an administrative activity and does not require manipulation or testing of equipment . Secondary containment penetration flow paths form a part of the secondary containment boundary . A secondary containment penetration flow path can be considered isolated when one barrier in the flow path is in place . Examples of suitable barriers include, but are not limited to, a closed secondary containment isolation valve (SCIV), a closed manual valve, a blind flange, or another sealing device that sufficiently seals the penetration flow path . Required Action C. 2 requires verification of the capab i lity to isolate each secondary containment penetration flow path in less than the DRAIN TIME. The required verification confirms actions to isolate the secondary containment penetration flow paths are preplanned and necessary materials are available . Power operated valves are not required to receive automatic isolation signals if they can be closed manually within the required time . Verification that the secondary containment penetration flow paths can be isolated must be performed within 4 hours. The required verification is an administrative activity and does not require manipulation or testing of equipment.
(continued)
Dresden 2 and 3                    B 3.5 . 2 -8                            Revision

EGGS ShYtdo11nRPV Water Inventory Control B 3 . 5.2 BASES ACTIONS         C.1. C.2. and C. 3   (continued)
One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases . Required Action C. 3 requires verification of the capability to place one SGT subsystem in operation in less than the DRAIN TIME . The required verification confirms actions to place a SGT subsystem in operation are preplanned and necessary materials are available . Verification that a SGT subsystem can be placed in operation must be performed within 4 hours.
The required verification is an administrative activity and does not require manipulation or testing of equipment .
isolated that is assYmed to be isolated to mitigate radioactivity releases (i . e . , one secondary containment isolation valve and associated instrymentation are OPERABLE or other acceptable administrative controls to assyre isolation capability. The administrative controls may consist of stationing a dedicated operator, who is in continYoYs commYnication with the control room, at the controls of the isolation device. In this way the penetration can be rapidly isolated when a need for (continYed)
Dresden 2 and 3                  B 3 . 5 . 2-9                         Revision

EGG~ ~hbltao'. mRPV Water Inventory Control B 3.5.2
                /\CTI OM~ CD . l ~D . 2   D . +/-3 . ~    and D . ~1(continblea)
With the DRAIN TIME less than 8 hours, mitigating actions are implemented in case an unexpected draining event should occur . Note that if the DRAIN TIME is less than 1 hour, Required Action E. l is also applicable .
Required Action D. l requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCD . The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur . The Note to Required Action D. l states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power . The additional method of water injection may be manually operated and may consist of one or more systems or subsystems . The additional method of wat er injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for~ 36 hours . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume .
(continued)
Dresden 2 and 3                  B 3 . 5.2-10                              Revision

EGGS Shbttcfoi,mRPV Water Inventory Control B 3.5.2 BASES ACTIONS         D.1. D.2. D.3. and D. 4        (continued)
Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material .
Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.
The secondary containment provides a control volume into which fission products can be contained, diluted, and processed prior to release to the environment. Required Action 0 . 2 requires that actions be immediately initiated to establish the secondary containment boundary. With the secondary containment boundary established, one SGT subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment.
The secondary containment penetrations form a part of the secondary containment boundary. Required Action D. 3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be manually isolated from the control room. A secondary containment penetration flow path can be considered isolated when one barrier in the flow path is in place. Examples of suitable barriers include, but are not limited to, a closed secondary containment isolation valve (SCJV), a closed manual valve, a blind flange, or another sealing device that sufficiently seals the penetration flow path.
One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases . Required Action D.4 requires that actions be immediately initiated to verify that at least one SGT subsystem is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.
secondary containffient is indicated) . OPERABILITY ffiay be verified by an adffiinistrative check, or by exaffiining logs or other inforffiation, to deterffiine whether the coffiponents are obit of service for ffiaintenance or other reasons. It is not necessary to perforffi the Sbtrveillances needed to deffionstrate the OPERABILITY of the coffiponents . If, however, any reqbtired coffiponent is inoperable, then it ffibtSt be restored to OPERABLE statbts. In this case, the Sbtrveillance ffiay need Dresden 2 and 3                    B 3 . 5 . 2-11                         Revision

ECG~ ~hbltdm*mRPV Water Inventory Contra 1 B 3. 5. 2 to be performed to restore the component to OPERABLE statbls.
Actions mblst continble blntil all reqblired components are OPERABLE.
Ll If the Required Actions and associated Completion times of Conditions C or D are not met, or if the DRAIN TIME is less than 1 hour, actions must be initiated immediately to restore the DRAIN TIME to ~ 36 hours.      In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF. Note that Required Actions D.l, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour.
(continued)
Dres den 2 and 3                  B 3 . 5. 2-12                        Revision

EGGS Shbltdoi,.rnRPV Water Inventory Control B 3 . 5. 2 BASES   (continued)
SURVEILLANCE        SR   3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF i ~ ~ 36 hours . The period of 36 hours is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation .
The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation .
A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube . If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.
The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths . A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake . Normal or expected leakage from closed systems or past isolation devices is permitted .
Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities .
The exclusion of penetration flow paths from the determination of DRAIN TIME must consider the potential effects of a single operator error or initiating event on (continued)
Dresden 2 and 3                     B 3.5.2-13                             Revision

EGGS Shbitdo*,mRPV Water Inventory Control B 3.5 . 2 BASES SURVEILLANCE    SR      3.5.2.1    (continued)
REQUIREMENTS items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.) . If failure of such items could result and would cause a draining event from a closed system or between the RPV and the isolation device, the penetration flow path may not be excluded from the DRAIN TIME calculation.
Surveillance Requirement 3.0.1 requires SRs to be met between performances . Therefore, any changes in p 1ant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined .
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
SR     3 . 5.2 . 2 The minimum water level of 10 ft 4 inches above the bottom of the suppression chamber required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for
                -tfl.e-a required CS subsystem ~or LPCI subsys tem pump~ .
recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit,
                -a-l-l---the ECCS injection/spray subsystem~ ~is inoperable unless they areit is aligned to OPERABLE CCSTs.
When suppression pool level is< 10 ft 4 inches, the CS oriH+G LPCI subsystem~ ~is considered OPERABLE only if it~ can take suction from the CCSTs, and the CCSTs water volume is sufficient to provide the required NPSH and vortex prevention for the CS pump and LPCI pump. Therefor e , a verification that either the sup pre ssion pool water level is
                ~ 10 ft 4 inches or that the required low pressure ECCS injection/spray subsyste ~ iH'-e-is aligned to take suction from the CCSTs and the CCSTs contain~ 140,000 available gallons of water, equivalent to 23 ft in both CCSTs with the CCSTs crosstied, ensures that the required low pressure ECCS injection /s pray (continued)
Dresden 2 and 3                       B 3 . 5 . 2-14                        Revision

EGGS ShYtdm.,inRPV Water Inventory Control B 3.5 . 2 BASES SURVEILLANCE    SR   3.5.2 . 2  (continued)
REQUJ REMENTS
                - subsyste m-& can supply at least 140,000 gallons of makeup water to the RPV . The CS and LPCI suctions are uncovered at the 90,000 gallon leve l. l=lo i1ever, as noted, only one 1
reqYired lo i1 pressblre EGGS injection/spray sYbsystem may 1
take credit for the GGST option dblring OPDRVs . DYring OPDRVs, the volblme in the GGSTs may not provide adeqYate makeblp if the RPV were (continYed)
Dresden 2 and 3                    B 3.5 . 2-15                         Revision

EGGS Sh1,1ttleHARPV Water Inventory Control B 3 . 5. 2 SURVU LL/\NGE     SR   3.5.2.1     (ceAtiAbled)
REQU I REME~ITS ce mpletel,y tlraiAetl . Therefore, eAly eAe le*.1 press1,1re EGGS i Ajecti eA/spray s1,1bsystem is all e'n*etl te 1,1se the GGSTs . This
* eAsblres the ether req1,1ired EGGS s1,1bsystem has atleq1,1ate makeblp vel1,1me.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
SR   3.5.2 . ~3. SR   3 . 5 . 2 . 4. aAG SR 3 . 5.2.5 The required low pressure ECCS injection/spray flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS injection/spray subsystem and may also prevent water hammer and pump cavitation.
Selection of ECCS injection/spray subsystem locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations . The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions .
Maintaining the pump discharge lines of the required ECCS injection/spray subsystem sufficiently full of water ensures that the ECCS subsystem will perform properly . Acceptance criteria are established for the volume of accumulated gas at susceptible locations . If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met . If it is determined by subsequent evaluation that the ECCS injection/spray subsystem is not rendered inoperable by the accumulated gas (i . e . , the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.
Dresden 2 and 3                        B 3 . 5. 2-16                          Revision

EGGS Shbttdo'llnRPV Water Inventory Control B 3. 5. 2 ECCS injection/spray subsystem location s susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acc eptance criteria for the location . Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of su sceptible locations . Monitoring may not be pra c ti cal for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety . For these locations, alternative methods (e . g. , operating parame ters, remote monitoring) may be used to monitor the susceptible location . Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not cha/ lenge system OPERABILITY . The accuracy of the method used for monitoring the susceptible locations and trending of the results shou l d be sufficient to as sure system OPERA BILITY during the Survei 7 lance interval . The gases pro vided for SR 3.5.1.1, SR 3.5.1 . 5, and SR 3 . 5 .1. 8 are ap pl icable to SR 3 . 5 . 2 . 2, SR 3 . 5 . 2.4, and SR 3 . 5 . 2 . 5 , res pectiv ely .
The Surve i 7 7ance Frequ ency is contra 7 7ed under the Surveillance Frequency Control Program. The Surveillance Fre quency may vary by l ocat i on s us cept i ble to ga s accumulation .
SR    3 . 5 . 2 .J-4 Verifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path ~ prov i des assurance that the proper flow path ~ will exi st be available for ECCS operat i on . This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing . A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time .
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentia l ly being mi spositioned are in the correct position . This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves. The Surveillance Frequency is contro ll ed under the Surveillance Frequency Control Program . The Surveillance is modified by (continued)
Dres den 2 and 3                         B 3 . 5 . 2-17                          Revision

EGGS Sh1:1tdo*,mRPV Water Inventory Control B 3. 5. 2 BASES SURVEILLANCE    SR  3.5 . 2 . 4 (continued)
REQUIREMENTS a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room . This individual will have a method to rapidly close the system vent flow path if directed.
SR  3 . 5.2 . 5 Verifying that the required ECCS injection/spray subsystem can be manually started and operate for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity . The minimum operating time of 10 minutes is based on engineering judgement .
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR  3.5.2 . 6 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. The Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
Operating experience has shown these components usually pass the Surveillance when performed at the selected Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
(continued)
Dresden 2 and 3                    B 3 . 5 . 2-18                         Revision

EGGS Shbltdo*,m RPV Water Inventory Control B 3.5 . 2 BASES SURVEILLANCE    SR  3.5.2.7 REQUIREMENTS (continued)  The required ECCS subsystem shall be capable of being manually operated.       This Surveillance verifies that the required CS or LPCI subsystem (including the associated pump and valve(s)) can be manually operated to provide additional RPV Water Inventory, if needed.
The Surveillance Frequency is controlled under the Survei 11 ance Frequency Contra I Program .
REFERENCES      1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup," November 1984 .
: 2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.
: 3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50 . 54(f), "August 1992.
: 4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs,"
May 1993 .
: 5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1,"
July 1994.
: 6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3141516," February 1983.UFS.A.R, Section 6 . 3 . 3 .4.1.
Dresden 2 and 3                   B 3.5.2-19                             Revision

IC System B 3.5.3 B 3.5     EMERGENCY CORE COOLING SYSTEM& CECCS) , REACTOR PRESSURE VESSEL (RPVJ WATER INVENTORY CONTROL, AND ISOLATION CONDENSER CIC) SYSTEM B 3 . 5.3   IC System BASES BACKGROUND            The IC System is not part of the ECCS; however, the IC System is included with the ECCS section because of their similar functions .
The IC System is designed to operate either automatically or manually following reactor pressure vessel (RPV) isolation to provide adequate core cooling . Under these conditions, the High Pressure Coo l ant Injection (HPCI) and IC systems perform similar functions .
The IC System (Ref.l) is a passive high pressure system comprised of one natural circulation heat exchanger, two AC motor-operated isolation valves, two D. C. motor-operated isolat i on valves, and two tube side high point vent isolation valves to main steam l i ne '' A" . The IC System functions as a heat sink for decay heat removal from the reactor vessel following reactor scram and isolation from the main conden ser . This function prevents overheating of the reactor fuel, controls reactor pressure, and limits the loss of reactor coolant through the relief valves . The IC System is automatically initiated by sustained reactor vessel high pres s ure and, once activated, remains in operation until manually removed from service .
The isolation condenser shell contains two tube bundles .
When the IC System is in operation, both tube bundles are in service .
The IC System is designed to provide core cooling for reactor pressure ~ 150 psig . The shell side of the condenser has a minimum water level of 6 feet which provides an inventory of~ 18,700 gallons. This minimum level provides~ 11,300 gallons (approximately 3 feet) of water above the top of the tube bundles . The shell side water temperature must be~ 210&deg;F . During normal plant operations, when the system is in standby, makeup is from the clean demineralize d water storage tank . Makeup during IC System operation can be provided from the Condensate (continued)
Dresden 2 and 3                          B 3. 5. 3-1                        Revision

I C Syste m B 3.5.3 BASES BACKGROUND      Transfer System . Since during operation of the IC System, (continued) water in the shell will boil, the condenser is vented to the atmosphere via one line .
APPLICABLE      The function of the IC System is to respond to main steam SAFETY ANALYSES line isolation events by providing core cooling to the reactor . The IC System is an Eng i neere d Safety Feature System, an d credit is taken in the loss of feedwater transient analysis for IC System operation (Ref . 3) . Based on its co ntr i but i on to t he reductio n of overal l pl ant r i sk ,
the system satisfies Criterion 4 of 10 CFR 50 . 36(c)( 2)(ii) .
LCO             The OPERABILITY of the IC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation, loss of feedwater, or similar occurrence . The IC System reduces the loss of RPV inventory during such events .
APPLICABILITY   The IC System is required to be OPERABLE during MODE 1, and MODES 2 and 3 with reactor steam dome pressure > 150 psig, since IC is the primary non-ECCS source for core cooling when the reactor is isolated and pressurized . In MODES 2 and 3 with reactor steam dome pressure~ 150 psig, the low pressure ECCS injection/spray subsystems can provide sufficient core cooling . ....oo-+J n MODES 4 and 5 , IC is not required to be OPERABLE since core cooling is assured by LCD 3.5.2, "RPV Water Inventory Control." the 10\\' pressure EGGS injection/spray subsystems can provide sufficient core coolin9'.
ACTIONS         A Note prohibits the application of LCO 3 . 0 . 4 . b to an inoperable IC System . There is an increased risk associated with entering a MODE or other spec i fied condit i on i n the Applicability with an inoperable IC System and the provisions of LCO 3 . 0.4 . b, which allow entry into a MODE or other spec if ied condit i on in the Applicab i lity with the LCO not met af t er performance of a r i sk assessment addressing inoperable systems and components, should not be applied in this circumstance .
(continued)
Dresden 2 and 3                      B 3. 5 . 3-2                        Revision

PC I Vs B 3.6.1.3 BASES LCO             10 CFR 50 Appendix R requirements) to be de-activated and (continued) closed, are considered OPERABLE when the valves are de-activated and closed . These passive isolation valves and devices are those listed in Reference 1.
MSIVs must meet additional leakage rate requirements . Other PCIV leakage rates are addressed by LCO 3.6.1.1, "Primary Containment," as Type B or C testing.
This LCO provides assurance that the PCIVs will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the primary containment boundary during accidents.
APPLICABILITY   In MODES 1, 2, and 3, a OBA could cause a release of radioactive material to primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, !!!&5-t PCIVs are not required to be OPERABLE in MODES 4 and 5. Certain valves, however, are required to be OPERABLE when the to prevent inadvertent reactor vessel drai ndo*,m. These valves are those *..ihose associated instrumentation is required to be OPERABLE per LCO 3 .3. ~5 . ~2 . "Primary Containment IsolationReactor Pressure Vessel (RPV) Water Inventory Control Instrumentation." (This does not include the valves that isolate the associated instrumentation.)
ACTIONS         The ACTIONS are modified by a Note allowing penetration flow path(s) to be unisolated intermittently under administrative controls . These controls consist of stationing a dedicated operator at the controls of the valve, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a need for primary containment isolation is indicated.
A second Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry i s allowed for each penetration flow path . This is acceptable, s ince the Required Actions for each Condition provide appropriate compensatory actions for each inoperable PCIV.
Complying with the Required Actions may allow for continued operation, and subsequent inoperable PCIVs are governed by subsequent Condition entry and application of associated Required Actions.
(continued)
Dresden 2 and 3                     B 3.6.1.3-4                        Revision

PC I Vs B 3 . 6 . 1.3 BASES ACTIONS (continued)
With the MSIV leakage rate CSR 3.6 . 1 . 3 . 10) not within limit, the assumptions of the safety analysis may not be met .
Therefore, the leakage must be restored to within limit within 8 hours . Restoration can be accomplished by isolating the penetration that caused the limit to be exceeded by use of one closed and de-activated automatic valve, closed manual valve, or blind flange . When a penetration is isolated, the leakage rate for the isolated penetration is assumed to be the actual pathway leakage through the isolation device . I f two isolation devices are used to isolate the penetration, the leakage rate is assumed to be the lesser actual pathway leakage of the two devices .
The Completion Time of 8 hours allows a period of time to restore MSIV leakage rate to within limit given the fact that MSIV closure will result in isolation of the main steam line(s) and a potential for plant shutdown .
E.l and E. 2 If any Required Action and associated Completion Time cannot be met in MODE 1, 2, or 3, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .
F. l and F. 2 If any Required Action and associated Completion Time cannot be met for PCIV(s) required OPERABLE in MODE 4 or 5, the unit must be 131 aced in a condition i ri *.ihi ch the LCO does not ap13ly. Action must be immediately initiated to suspend 013erations *.iith a potential for drainin&sect; the reactor vessel COPDRVs) to minimize the probability of a vessel draindmm and subsequent potential for fission product release .
Actions must continue until OPDRVs are sus13ended . If suspendin&sect; an OPDRV *,1ould result in closin&sect; the shutdo1m coolin&sect; isolation valves, an alternative Required Action is provided to immediately initiate action to restore the (continued)
Dresden 2 and 3                    B 3. 6. 1.3-9                         Revision

PCIVs B 3.6 . 1.3 BASES ACTIONS          ~. l  and   ~ . 2  (continued)
                *1al *1e( s) to OPERABU status. This all o*.1s shutdo*.in cooling to remain i n service 11hile actions are being taken to restore the valve .
SURVEILLANCE    SR     3.6 . 1.3.1 REQUIREMENTS This SR ensures that the 18 inch primary containment vent and purge valves are closed as required or, if open, opened for an allowable reason . If a vent or purge valve is opened in violation of this SR, the valve is considered inoperable .
The torus purge valve, 1601-56, is normally open for pressure control, therefore this valve is excluded from this SR. However, this is acceptable s ince this valve is designed to automatically close on LOCA conditions. The SR is modified by a Note stating that the SR is not required to be met when the vent or purge valves are open for the stated reasons . The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the drywell vent and purge valves and their as sociated suppre ss ion chamber vent and purge valves are not open s imultaneously.
The 18 inch vent and purge valves are capable of closing in the environment following a LOCA . Therefore, the se valve s are allowed to be open for limited period s of time. The Surveillance Frequency i s controlled under the Surveillance Frequency Control Program.
SR    3.6 . 1.3 . 2 This SR verifies that each primary containment isolation manual valve and blind flange that is located out s ide primary containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions, i s closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits .
This SR does not require any testing or valve manipulation.
Rather, it involves verification that those PCIVs outside primary containment, and capable of being mispositioned, are in the correct position . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
(continued)
Dresden 2 and 3                       B 3 . 6 . 1.3-10                  Revision

Suppression Pool Water Level B 3.6.2.2 BASES   (continued)
APPLICABLE           Initial su ppression pool water level affects suppression SAFETY ANALYSES     pool temperature response calculations, calculated drywell pressure during vent clearing for a OBA, calculated pool swell loads for a OBA LOCA , and calculated loads due to relief valve discharges . Suppression pool water level must be maintained within the limits specified so that the safety analysis of Reference 1 remains valid.
Suppression pool water level satisfies Criteria 2 and 3 of 10 CFR 50 . 36(c)(2)(ii) .
LCO                 A limit that suppression pool water level be~ 14 ft 6 . 5 inches and ~ 14 ft 10 . 5 inches above the bottom of the suppression chamber is required t o ensure that the primary containment conditions assumed for the safety analyses are met . Either the high or low water level limits were used in the safety analyses, depending upon which is more conservative for a particular calculation .
APPLICABILITY       In MODES 1 , 2, and 3, a OBA would cause significant loads on the primary containment. In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES . The requirements for maintaining suppression pool water level within limits in MODE 4 or 5 is addressed in LCO 3 . 5 . 2,
                    " EGGS ShbltdownRPV Water Inventory Control ."
ACTIONS With suppression pool water level outside the limits, the conditions assumed for the safety analyses are not met . If water level is below the minimum level, the pressure suppression function still exists as long as the downcomers are covered, HPCI turbine exhaust is covered, and relief valve quenchers are covered . If suppression pool water level is above the maximum level, protection against overpressurization still exists due to the margin in the peak containment pressure analysis and the capability of the Suppression Pool Spray System. Therefore, continued operation for a limited time is allowed . The 2 hour Completion Time is sufficient to restore suppression pool water level to within limits . Also, it takes into account the low probability of an event impacting the suppression pool water level occurring during this interval.
(continued)
Dresden 2 and 3                       B 3.6.2.2-2                          Revision

Secondary Containment B 3.6.4.l BASES APPLICABLE      associated leakage rates assumed in the accident analysis SAFETY ANALYSES and that fission products entrapped within the secondary (continued) containment structure will be treated by the SGT System prior to discharge to the environment.
Secondary containment satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO             An OPERABLE secondary containment provides a control volume into which fission products that bypass or leak from primary containment, or are released from the reactor coolant pressure boundary components located in secondary containment, can be diluted and processed prior to release to the environment. For the secondary containment to be considered OPERABLE, it must have adequate leak tightness to ensure that the required vacuum can be established and maintained, the hatches and blowout panels must be closed and sealed, the sealing mechanisms (e.g . , welds, bellows, or 0-rings) associated with each secondary containment penetration must be OPERABLE (such that secondary containment leak tightness can be maintained), and all inner or all outer doors in each secondary containment access opening must be closed.
APPLICABILITY   In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.
In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operatioRs with a poteRtial for draiRiRg the reactor vessel (QPDRVsl or d~riRg movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, secondary containment is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e.,
fuel that has occupied part of a critical reactor core within the previous 24 hours).
(continued)
Dresden 2 and 3                 B 3.6.4 . 1- 2                     Revision

Secondary Containment B 3.6 . 4.1 BASES ACTIONS         C.l anEI C.2 (continued)
Movement of recently i rradiated fuel assemblies in the secondary containment anEI OPDRVs can be postulated to cause significant fission product release to the secondary containment . In s uch cases, the secondary containment is the only barrier to release of fission products to the environment . Therefore, movement of recently irradiated fuel assemblies must be immediately suspended if the secondary containment is inoperab l e .
Suspension of this activity shall not preclude completing an action that involves moving a component to a safe position .
Also, action ffi~st be iffiffieEliately initiateEI to s~spenEI OPDRVs to ffiiniffiize the probability of a vessel ElrainElm1n anEI s~bseq~ent potential for fission proEl~ct release.          Actions ffi~st contin~e ~ntil OPDRVs are s~spenEleEI.
Required Action C. l has been modified by a Note stating that LCO 3 . 0.3 is not applicable . If moving recen tl y irradiated fuel assemblies while in MODE 4 or 5, LCO 3 . 0.3 would not specify any action . If moving recently irradiated fuel as s emblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown .
SURV EILLANCE   SR    3.6 . 4 . 1.1 REQUIREMENTS This SR ensures that the secondary containmen t boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions . The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .
(continued)
Dresden 2 and 3                     B 3 . 6 . 4 . 1-4                     Revision

SCI Vs B 3.6.4.2 BASES APPLICABLE      leakage from the primary containment is processed by the SAFETY ANALYSES Standby Gas Treatment (SGT) System before being released to (continued) the environment.
Maintaining SCIVs OPERABLE with isolation times within limits ensures that fission products will remain trapped inside secondary containment so that they can be treated by the SGT System prior to discharge to the environment.
SCIVs s atisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) .
LCO             SCIVs form a part of the secondary containment boundary .
The SCIV safety function is related to control of offsite radiation releases resulting from DBAs.
The power operated, automatic, i s olation valves are considered OPERABLE when their isolation times are within limits and the valve s actuate on an automatic i solation s ignal . The valves covered by this LCO, along with their associated stroke times, are listed in the Technical Requirements Manual (Ref. 2) .
The normally closed manual SCIVs are considered OPERABLE when the valve s are clo sed and blind flange s are in place, or open under admini s trative control s . The se pa s sive i solation valves or devi ces are listed in Reference 2.
APPLICABILITY   In MODES 1, 2, and 3, a OBA could lead to a fission product release to the primary containment that leaks to the secondary containment. Therefore, the OPERABILITY of SCIVs is required.
In MODES 4 and 5, the probability and consequence s of these event s are reduced due to pressure and temperature limitations in these MODES . Therefore, maintaining SCIVs OPERABLE is not required in MODE 4 or 5, except for other s ituations under which significant radioactive releases can be postulated, such as during e13erati ens iii th a 13etenti al fer draining the reacter vessel (QPQRVs) er d~ring movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, SCIVs are only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previou s 24 hours) .
(continued)
Dresden 2 and 3                  B 3.6 . 4 . 2-2                       Revision

SCI Vs B 3. 6.4. 2 BASES ACTIONS         .B....J. (continued)
The Condition has been modified by a Note stating that Condition B is only applicable to penetration flow paths with two isolation valves. This clarifies that only Condition A is entered if one SCIV is inoperable in each of two penetrations .
C.l and C. 2 If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the LCO does not apply . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .
D.l and Q.2 If any Required Action and associated Completion Time are not met, the plant must be placed in a condition in which the LCO does not apply . If applicable, the movement of recently irradiated fuel assemblies in the secondary containment must be immediately suspended . Suspension of this activity shall not preclude completion of movement of a component to a safe position . Also, if applicable, actions must be immediately initiated to suspend OPQRVs in order to minimize the probability of a vessel draindo*,m and the subsequent potential for fission product release . Actions must continue until OPQRVs are suspended.
Required Action D. l has been modified by a Note stating that LCO 3 . 0 . 3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3 . 0 . 3 would not specify any action. If moving fuel while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations . Therefore, in either case, inability to suspend movement of recently i rradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown .
(continued)
Dresden 2 and 3                      B 3.6 . 4 . 2-5                 Revision

SGT System B 3.6.4.3 BASES APP LI CABILITY In MODES 4 and 5, the probability and consequences of these (continued) events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System in OPERABLE status is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during 013erations *,1ith a 13otential for drainin&sect; the reactor vessel (QPQRVs) or dYrin&sect; movement of recently irradiated fuel assemblies in the secondary containment . Due to radioactive decay, the SGT System is only required to be OPERABL E during fuel handling involving handling recently irradiated fuel Ci . e., fuel that has occupied part of a critical reactor core within the previous 24 hours).
ACTIONS With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status in 7 days. In this condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system reliability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant SGT System and the low probability of a DBA occurring during this period.
If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the overall plant risk is minimized . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours. Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref . 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short . However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state .
(continued)
Dresden 2 and 3                    B 3.6.4.3-3                       Revision

SGT System B 3 . 6 .4. 3 BASES ACTIONS                (continued)
Required Action B.l is modified by a Note that prohibits the application of LCO 3 . 0. 4 . a . This Note clarifies the intent of the Required Action by indicating that it is not permissible under LCO 3 . 0 . 4 . a to enter MODE 3 from MODE 4 with the LCO not met . While remaining in MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordance with LCO 3 . 0 . 4 . a .
However, where al l owed, a risk assessment may be performed in accordance with LCO 3. 0 . 4.b. Consideration of the results of this risk assessment is required to determine the acceptability of entering MOD E 3 from MODE 4 when this LCO is not met. The allowed Completion Time is reasonable ,
based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
C.l .and C.2 .1. and C.2.2 During movement of recently irradiated fuel assemblies, in the secondary containment or d1::1ring OPDRVs , when Required Action A.l cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation . This action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation will occur, and that any other failure would be readily detected .
An alternative to Required Action C. l i s to immediately suspen d activities that represent a potential for releasing a significant amount of radioactive material to the secon dary containment, thus placing the plant in a condition that minimizes risk . If applicable, movement of recently irradiated fuel assemblies must immediately be suspended .
Suspension of this activity must not preclude completion of movement of a component to a safe position. Also, if applicable, actions m1::1st immediately be initiated to s1::1spend OPDRVs in order to minimize the probability of a vessel draindo i1n and s1::1bseq1::1ent potential for fission prod1::1ct 1
release. Actions m1::1st contin1::1e 1::1ntil OPDRVs are s1::1spended.
The Required Actions of Condition C have been modified by a Note stat ing that LCO 3 . 0.3 is not applicable . If moving recently irradiated fuel assemblies while in MODE 4 or 5, (continued)
Dresden 2 and 3                   B 3.6 . 4.3-4                           Revision

SGT System B 3.6.4.3 BASES ACTIONS         C. l . and C.2 . l. and G. 2 . 2   (continued)
LCO 3 . 0.3 would not specify any action . If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
If both SGTS subsystems are inoperable in MODE 1, 2, or 3, the SGT system may not be capable of supporting the required radioactivity release control function . Therefore, one SGT subsystem must be restored to OPERABLE status within 1 hour .
The 1 hour Completion Time provides a period of time to correct the problem that is commensurate with the importance of supporting the required radioactivity release control function in MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring the SGT System) occurring during periods where the required radioactivity release control function may not be maintained is minimal .
Ll If one SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the plant must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref . 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state .
Required Action E. l is modified by a Note that prohibits the application of LCO 3 . 0.4.a . This Note clarifies the intent of the Required Action by indicating that it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remaining in MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordance with LCO 3.0.4.a .
(continued)
Dresden 2 and 3                     B 3 . 6.4 . 3-5                Revision

SGT System B 3.6 . 4 . 3 BASES ACTIONS         l......l  (continued)
However, where allowed, a risk assessment may be performed in accordance with LCO 3.0 . 4 . b. Consideration of the results of this risk assessment is required to determine the acceptability of entering MODE 3 from MODE 4 when this LCO is not met The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems .
F. l . aAd     ~ . 2.
When two SGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of this activity shall not preclude completion of movement of a component to a safe position . Also, if applicable, actioA must immediately be iAitiated to suspend OPDRVs iA order to miAimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.
Required Action F.l has been modified by a Note stating that LCO 3.0 . 3 is not applicable . If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3 . 0 . 3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations . Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
SURVEILLANCE    SR       3. 6.4 . 3. 1 REQUIREMENTS Operating (from the control room using the manual initiation switch) each SGT subsystem for ~ 15 continuous minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly . It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action .
(continued)
Dresden 2 and 3                        B 3.6.4 . 3-6                 Revision

CREV System B 3.7.4 BASES LCO (continued) doors, hatches, floors plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE . This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.
APPLICABILITY   In MODES 1, 2, and 3, the CREV System must be OPERABLE to ensure that the CRE will remain habitable during and following a OBA, since the OBA could lead to a fission product release.
In MODES 4 and 5, the probability and consequences of a OBA are reduced because of the pressure and temperature limitations in these MODES. Therefore, maintaining the CREV System OPERABLE is not required in MODE 4 or 5, except ~
the following sitYations Ynder which significant radioactive releases can ae postylated:
: a. Dd uring movement of recently irradiated fuel assemblies in the secondary containment-;----a-R4.
: a. DYring operations 'n'ith a potential for draining the reactor vessel COPDRVs).
Due to radioactive decay, the CREV System is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e . , fuel that has occupied part of a critical reactor core within the previous 24 hours).
ACTIONS With the CREV System inoperable for reasons other than an inoperable CRE boundary, in MODE 1, 2, or 3, the inoperable CREV System must be restored to OPERABLE status within 7 days. The 7 day Completion Time is based on the low probability of a OBA occurring during this time period .
(continued)
Dresden 2 and 3                   B 3.7.4-7                        Revision

CREV System B 3. 7.4 BASES ACTIONS         E. l. aRd t.2 (continued)
LCO 3 . 0 . 3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel movement can occur in MODE 1, 2, or 3, the Required Actions of Condition E are modified by a Note indicating that LCO 3.0.3 does not apply . If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations . Entering LCO 3.0 . 3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of recently irradiated fuel assemblies . The NOTE to the ACTIONS, "LCO 3 . 0. 3 is not applicable," ensures that the actions for immediate suspension of recently irradiated fuel assembly movement are not postponed due to entry into LCO 3 . 0.3 .
With the CREV System inoperable or with the CREV System inoperable due to an inoperable CRE boundary, during movement of recently irradiated fuel assemblies in the secondary containment or duriRg OPDRVs , action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require the CREV System to be placed in the i solation / pre s surization mode of operation . This places the unit in a condition that minimizes the accident ri s k.
If applicable, movement of recently irradiated fuel a s semblies in the secondary containment must be s uspended immediately. Su s pension of this activity shall not preclude completion of movement of a component to a safe position .
Also, if applicable, actioR ffiust be iRitiated iffiffiediately to suspeRd OPDRVs to ffiiRiffiize the probability of a vessel draindown and the subsequent potential for fission product release. Actions ffiust continue until the OPDRVs are suspended.
(continued)
Dresden 2 and 3                     B 3.7 . 4-10                       Revision

Control Room Emergency Ventilation AC System B 3 . 7. 5 BASES APPLICABILITY    In MODES 4 and 5, the probability and consequences of a (continued) Design Basis Accident are reduced due to the pressure and temperatur e l imitations in these MODES . Therefore, maintaining the Control Room Emergency Ventilation AC System OPERABLE is not required in MODE 4 or 5, except for the foll o*.:i n&sect; si te1ati ens e1neer which si &sect;ni fi cant raei oacti ve releases can 9e poste1latee:
<!1-7~~~~~~~~~d uring         movement of recently irradiated fuel assembl i es in the secondary containment~.
: 9.      Dt1ri n&sect; operati ens 11i th a potential for erai ni n&sect; the reactor vessel ( OPDRl/s).
Due to radioactive decay, the Control Room Emergency Ventilation AC System is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i . e . , fuel that has occupied part of a critical reactor core within the previous 24 hours).
ACTIONS With the Control Room Emergency Ventilation AC System inoperable in MODE 1, 2, or 3 , the system must be restored to OPERABLE status within 30 days . The 30 day Completion Time is based on the low probability of an event occurring requiring control room emergency zone isolation and the availability of alternate nonsafety cooling methods.
In MODE 1, 2, or 3, if the inoperable Control Room Emergency Ventilation AC System cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes overall plant risk . To achieve this status, the unit must be placed in at least MODE 3 within 12 hours . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 2) and because th e time spen t in MODE 3 t o perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.
(continued)
Dresden 2 and 3                          B 3 . 7. 5 -3                         Revision

Control Room Emergency Ventilation AC System B 3 .7.5 BASES ACTIONS         ..B........l (continued)
Required Action B.l is modified by a Note that prohibits the application of LCO 3. 0.4 . a . This Note clarifies the intent of the Required Action by indicating that it is not permissible under LCO 3.0 . 4 . a to enter MODE 3 from MODE 4 with the LCD not met . While remaining in MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordance with LCO 3 . 0 . 4.a .
However, where allowed, a risk assessment may be performed in accordance with LCO 3 . 0.4 . b. Consideration of the results of this risk assessment is required to determine the acceptability of entering MODE 3 from MODE 4 when this LCO is not met . The allowed Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems .
C.l and G.2 LCD 3.0 . 3 i s not applicable while in MODE 4 or 5. However, since recently irradiated fuel movement can occur in MODE 1, 2, or 3, the Required Actions of Condition C are modified by a Note indicating that LCO 3.0.3 does not apply. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3 , the fuel movement is independent of reactor operations. Entering LCD 3 . 0 . 3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of recently irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3 . 0 . 3 is not applicable," ensures that the actions for immediate susp en sion of recently irradiated fuel assembly movement are not po stponed due to entry into LCD 3 .0.3.
With the Control Room Emergency Ventilation AC System inoperable during movement of recently irradiated fuel assemblies in the secondary containment or d~rin9 OPDRVs ,
action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control room . This places the unit in a condition that minimizes risk .
(continued)
Dresden 2 and 3                          B 3.7.5-4                        Revision

Control Room Emergency Ventilation AC System B 3.7.5 BASES ACTIONS         C. l and C.2     (continued)
If applicable, movement of recently irradiated fuel assemblies in the secondary containment must be suspended immediately . Suspension of this activity shall not preclude completion of movement of a component to a safe position.
Also, if applicable, action mYst be initiated immediately to sYspend OPDRVs to minimize the probability of a vessel draindown and sYbseqYent potential for fission prodYct release. Action mYst continYe Yntil the OPDRVs are sYspended .
SURVEILLANCE    SR   3 . 7. 5 .1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room emergency zone heat load assumed in the safety analyses. The SR consists of a combination of testing and calculation . The Survei l la nce Frequency is control l ed under the Surveil l ance Frequency Control Program.
REFERENCES      1. UFSAR, Section 6.4 .
: 2. NEDC-32988-A, Revision 2, Technical Justification to Support Risk - Informed Modification to Selected Required End States for BWR Plants, December 2002 .
Dresden 2 and 3                     B 3 . 7. 5-5                      Revision

AC Sources-Shutdown B 3.8 . 2 B 3.8     ELECTRICAL POWER SYSTEMS B 3 . 8.2   AC Sources- Shutdown BASES BACKGROUND           A description of the AC sources is provided in the Bases for LCD 3 . 8.1, "AC Sources-Operating . "
APPLICABLE           The OPERABILITY of the m1n1mum AC sources during MODES 4 SAFETY ANALYSES      and 5, and during movement of recently irradiated fuel assemblies in the secondary containment ensures that :
: a. The facility can be maintained in the shutdown or refueling condition for extended periods;
: b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
: c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as ;2-A-inadvertent draindo *,m of the vessel or a fuel handling accident involving handling recently irradiated fuel.
Due to radioactive decay, AC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i.e . , fuel that has occupied part of a critical reactor core within the previous 24 hours)
In general, when the unit is shutdown the Technical Specifications 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 (continued)
Dr esden 2 and 3                       B 3.8 . 2-1                        Revision

AC Sources-Shutdown B 3 . 8.2 BASES LCO             Systems-Shutdown," ensures that all required loads are (continued) powered from offsite power. An OPERABLE DG, associated with a Distribution System Essential Service System CESS) bus required OPERABLE by LCO 3 . 8 . 8, ensures that a diverse power so urce is available for providing electrical power support assuming a los s of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of po stulate d events during s hutdown (e.g., fuel handling accidents involving handling recently irradiated fuel -a-fl4 reactor vessel drai ndo11n ).
The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESS bus(es), and of accepting required loads during an accident. Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the unit. The offsite circuit from the 138 kV or 345 kV switchyard consists of the incoming breakers and disconnects to the 22 or 32 reserve auxiliary transformer (RAT) (or 21 or 31 unit auxiliary transformer CUAT) on backfeed), associated 22 or 32 RAT (or 21 or 31 UAT on backfeed), and the respective circuit path including feeder breakers to 4160 VESS buses required by LCO 3.8.8.
Another qualified circuit is provided by the bus tie between the corresponding ESS buses of the two units.
The required DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective 4160 V ESS bus on detection of bus undervoltage, and accepting required load s . This sequence must be accomplished within 13 seconds . Each DG must also be capable of accepting required loads within the assumed loading sequence interval s, and must continue to operate until offsite power can be restored to the 4160 V ESS bu ses . These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot and DG in standby with engine at ambient conditions . Additional DG capabilities must be demonstrated to meet required Surveillances . Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY . The necessary portions of the DG Cooling Water and Ultimate Heat Sink System capable of pr ov iding cooling to the required DG is also required .
(continued)
Dresden 2 and 3                    B 3.8 . 2-3                       Revision

AC Sources-Shutdown B 3.8.2 BASES LCO              It is acceptable for divisions to be cross tied during (continued) shutdown conditions, permitting a single offsite power circuit to supply all required divisions .
APPLICABILITY   The AC sources are required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment to provide assurance that :
: a. Systems providin&sect; adequate coolant inventory makeupthat provide core cooling are available for the irradiated fuel assemblies in the core in case of an inadvertent draindown of the reactor vessel ;
: b. Systems needed to mitigate a fuel handling accident involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 24 hours) are available;
: c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
: d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.
ACTIONS         LCO 3 . 0 . 3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3 . 0 . 3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Entering LCO 3.0.3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of recently irradiated fuel assemblies . The Note to the ACTIONS, "LCO 3 . 0 . 3 is not applicable," ensures that the actions for immediate suspension of recently irradiated fuel assembly movement are not postponed due to entry into LCO 3.0.3.
(continued)
Dresden 2 and 3                      B 3 . 8.2 -4                    Revision

AC Sources-Shutdown B 3.8 . 2 BASES ACTIONS (continued)
An offsite circuit is considered inoperable if it is not available to one required 4160 V ESS bus. If two or more 4160 V ESS buses are required per LCO 3 . 8.8, one division with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS-,--- and movement of recently irradiated~
movement, and operations with a potential for draining the reactor vessel . By the allowance of the option to declare required features inoperable that are not powered from offsite power, appropriate restrictions can be implemented in accordance with the required feature(s) LCOs' ACTIONS.
Required features remaining powered from a qualified offsite circuit, even if that circuit is considered inoperable because it is not powering other required features, are not declared inoperable by this Required Action. For example, if both Division 1 and 2 ESS buses are required OPERABLE by LCO 3.8.8, and only the Division 1 ESS buses are not capable of being powered from offsite power, then only the required features powered from Division 1 ESS buses are required to be declared inoperable.
A. 2. 1 , A.2 . 2 . A.2.3 . A 2 4 B. 1 . B.2. and B. 3 and B 4 With the required offsite circuit not available to all required divisions, the option still exists to declare all required features inoperable per Required Action A. 1. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made.
With the required DG inoperable, the minimum required diversity of AC power sources is not available . It is, therefore, required to suspend CORE ALTERATIONS~, and movement of recently irradiated fuel assemblies in the secondary containment , and activities that coYld resYlt in inadvertent drainin9 of the reactor vessel .
Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition .
These actions minimize the probability of the occurrence of postulated events . It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the plant safety systems .
(continued)
Dresden 2 and 3                       B 3.8.2-5                          Revision

AC Sources-Shutdown B 3.8 . 2 BASES ACTIONS         A.2.1 . A. 2.2 . A. 2.3 . A. 2.4 . B.l B.2  and B.3 . aAd B.4 (continued)
The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the plant safety syst em s may be without sufficient power .
Pursuant to LCO 3 . 0. 6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESS bus, ACTIONS for LCO 3.8.8 must be immediately entered . Thi s Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a division is de-energized . LCO 3.8 . 8 provides the appropriate restrictions for the situation involving a de-energized division.
SURVEILLANCE    SR  3.8.2.1 REQUIREMENTS SR 3.8 . 2 . 1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3 to be applicable . SR 3.8 . 1.9 is not required to be met since only one offsite circuit is required to be OPERABLE . SR 3 . 8 . 1 . 20 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE . SR 3.8 . 1.21 is not required to be met because the opposite unit's DG is not required to be OPERABLE in MODES 4 and 5, and during movement of recently irradiated fuel assemblies in secondary containment . Refer to the corresponding Bases for LCD 3.8.1 for a di scussion of each SR.
This SR is modified by two Notes. The reason for Note 1 is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESS bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event (continued)
Dresden 2 and 3                      B 3.8 . 2-6                        Revision

AC Sources-Shutdown B 3.8 . 2 BASES SURVEILLANCE    SR   3 . 8.2.1 (continued)
REQUIREMENTS could compromise both the required circuit and the DG . It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit are required to be OPERABLE .
Note 2 sta t es that SRs 3 .8 . 1 . 13 and 3 . 8.1 . 19 are not required to be met when its associated ECCS subsystem(s) are not required to be OPERABLE . These SRs demonstrate the DG response t o an ECCS initiation signal (either alone or in conjunction with a loss of offsite power signal) . This is consistent with the ECCS instrumentation requirements that do not require the ECCS initiation signals when the associated ECCS subsystem is not required to be OPERABLE .
per LGO 3.5 . 2, "EGGS Sh1:1tdo*,,*n."
REFERENCES      None .
Dresden 2 and 3                    B 3. 8 . 2-7                              Revision

DC Sources-Shutdown B 3.8 . 5 B 3. 8   ELECTRICAL POWER SYSTEMS B 3. 8.5   DC Sources-Shutdown BASES BACKGROUND          A description of the DC sources is provided in the Bases for LCO 3 . 8 . 4, "DC Sources-Operating . "
APPLICABLE          The initial conditions of Design Basis Accident and SAFETY ANALYSES     transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature systems are OPERABLE . The DC electrical power system provides normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation and during movement of recently irradiated fuel assemblies in the secondary containment.
The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY .
The OPERABILITY of the minimum DC electrical power sources during MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment ensures that :
: a. The facility can be maintained in the shutdown or refueling condition for extended periods;
: b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
: c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as e-A-inadvertent draindo*.m of the vessel or a fuel handling accident involving handling recently irradiated fuel .
Due to rad i oactive decay, DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i . e . , fuel that has occupied part of a critical reactor core within the previous 24 hours) .
(continued)
Dresden 2 and 3                         B 3.8.5-1                         Revision

DC Sources- Shutdown B 3.8.5 BASES LCO             bus; and b) the required 125 VDC subsystem consisting of one (continued) battery, one battery charger , and the corresponding control equipment and interconnecting cabling supplying power to the associated bus - are required to be OPERABLE to support some of the required DC distribution su bsystems required OPERABLE by LCO 3 . 8 . 8, "Distribution Systems-Shutdown . " This requirement ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e . g., fuel handling accidents involving handling r ecently irradiate d fuel and inadvertent reactor vessel draindo*.m ). The associated alternate 125 VDC electrical power subsystem may be used to satisfy the requirements of the 125 voe subsystems .
APPLICABILITY   The DC electrical power sources required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel ass emblies in the secondary containment provide assurance that :
: a. Required features to provide adequate coolant inventory make~p    core cooling are available for the irradiated f~el assemblies in the core in case of an inadvertent draindown of the reactor vessel ;
: b. Required features needed to mitigate a fuel handling accident involving handling recently irradiated fuel are available;
: c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
: d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition .
Due to radioactive decay, DC electrical power is only required to mitigate fuel handling accidents involving handling recently irra diated fuel (i . e . , fuel that has occupied part of a critical reactor core within the previous 24 hours).
The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8 . 4.
(continued)
Dresden 2 and 3                     B 3.8 . 5-3                       Revision

DC Sources- Shutdown B 3 . 8.5 BASES (continued)
ACTIONS           LCO 3.0.3 is not applicable while in MODE 4 or 5 . However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3.0 . 3 is not applicable . If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action . If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations .
Entering LCO 3 . 0.3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of recently irradiated fuel assemblies . The Note to the ACTIONS, "LCO 3.0 . 3 is not applicable," ensures that the actions for immediate suspension of recently irradiated fuel assembly movement are not postponed due to entry into LCO 3.0.3 .
A. l . A.2.1 . A.2.2. and A.2.3 aRd A 2 4 By allowance of the option to declare required features inoperable with associated DC electrical power subsystem(s) inoperable, appropriate restrictions are implemented in accordance with the affected system LCOs' ACTIONS . However, in many instances, this option may involve undesired administrative efforts . Therefore, the allowance for sufficiently conservative actions is made (i . e . , to suspend CORE ALTERATIONS, movement of recently irradiated fuel assemblies in the secondary containment , aRd aRy activities that co~ld res~lt iR iRadverteRt draiRiRg of the reactor vessel ).
Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.
These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety systems .
The Completion Time of immediately is consistent with the required times for actions requiring prompt attention . The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power .
(continued)
Dresden 2 and 3                      B 3.8.5 -4                        Revision

Distribution Systems-Shutdown B 3.8 . 8 BASES APP LI CABLE    The OPERABILITY of the m1n1mum AC and DC electrical power SAFETY ANALYSES sources and associated power distribution subsystems during (continued) MODES 4 and 5, and during movement of recently irradiated fuel assemblies in the secondary containment ensures that:
: a. The facility can be maintained in the shutdown or refueling condition for extended periods;
: b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and
: c. Adequate power is provided to mitigate events postulated during shutdown, such as an inadvertent drai ndo1m of the vessel or a fuel handling accident involving handling recently irradiated fuel .
Due to radioactive decay, AC and DC electrical power is only required to mitigate fuel handling accidents involving handling recently irradiated fuel (i . e., fuel that has occupied part of a critical reactor core within the previous 24 hours) .
The AC and DC electrical power distribution systems satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO             Various combinations of subsystems, equipment, and components are required OPERABLE by other LCOs, depending on the specific plant condition . Implicit in those requirements is the required OPERABILITY of necessary support features. This LCO explicitly requires energization of the portions of the electrical distribution system, including the opposite unit Division 2 electrical distribution subsystem, necessary to support OPERABILITY of Technical Specifications required systems, equipment, and components - both specifically addressed by their own LCO, and implicitly required by the definition of OPERABILITY .
Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the plant in a safe manner to mitigate the consequences of postulated events during shutdown (e . g. ,
fuel handling accidents involving handling recently irradiated fuel and inadvertent reactor vessel drai ndmm ) .
(continued)
Dresden 2 and 3                   B 3. 8.8-2                       Revision

Distribution Systems-Shutdown B 3 .8. 8 BASES (continued)
APPLICABILITY     The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 4 and 5 and during movement of recently irradiated fuel assemblies in the secondary containment provide assurance that :
: a. Systems to provide adeqyate coolant inventory makeYpthat provide core cooling are available for the irradiated fyel in the core in case of an inadvertent draindown of the reactor vessel ;
: b. Systems needed to mitigate a fuel handling accident involving handling recently irradiated fuel (i . e., fuel that has occupied part of a critical reactor core within the previous 24 hours) are available;
: c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
: d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.
The AC and DC electrical power distribution subsystem requirements for MODES 1, 2, and 3 are covered in LCO 3.8 . 7.
ACTIONS           LCO 3 . 0 . 3 is not applicable while in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, the ACTIONS have been modified by a Note stating that LCO 3 . 0.3 is not applicable . If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Entering LCO 3 . 0.3 while in MODE 1, 2, or 3 would require the unit to be shutdown, but would not require immediate suspension of movement of recently irradiated fuel assemblies. The Note to the ACTIONS, "LCO 3 . 0.3 is not applicable," ensures that the actions for immediate suspension of recently irradiated fuel assembly movement are not postponed due to entry into LCO 3 . 0 . 3.
(continued)
Dresden 2 and 3                        B 3.8 . 8-3                     Revision

Di stribution Systems-Shutdown B 3.8 . 8 BASES ACTIONS         A. l . A. 2.1 . A. 2. 2 . A. 2 . 3 . and A. 2 . 4 and A.2.5 (continued)
Although redundant required features may require redundant divisions of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem division may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS,---- and the movement of recently irradiated fuel movement, and operations with a potential for draining the reactor vessel . By allowing the option to declare required features associa t ed with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions . In many instances this option may involve undesired administrative efforts . Therefore , the allowance for sufficiently conservative actions is made, Ci . e . , to suspend CORE ALTERATIONS, movement of recently irradiated fuel assemblies in the secondary containment , and any activities that co~ld result in inadvertent draining of the reactor vessel ) .
Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition .
These actions minimize the probability of the occurrence of postulated events . It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the plant safety systems .
Notwithstanding performance of the above conservative Required Actions, a required shutdown cooling (SOC) subsystem may be inoperable . In this case, Required Actions A. 2 . 1 through A. 2 .4-3 do not adequately address the concerns relating to coolant circulation and heat removal . Pursuant to LCO 3 . 0 . 6, the SOC ACTIONS would not be entered .
Therefore, Required Action A . 2. ~ is provided to direct declaring SOC inoperable, which results in taking the appropriate SOC ACTIONS.
The Completion Time of immediately is consistent with the required t i mes for act i ons requiring prompt attention . The restoration of the requ i red di stribution subsystems should be completed as quickly as possible in order to minimize the time the plant safety systems may be without power .
(continued)
Dresden 2 and 3                       B 3.8 . 8-4                            Revision}}