View source for RS-17-173, Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

{{Adams
| number = ML17354B196
| issue date = 12/20/2017
| title = Supplement to Dresden Nuclear Power Station, Units 2 and 3 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 = CAC MF9295, CAC MF9296, RS-17-173, TSTF-542
| document type = Letter type:RS, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 11
| project = CAC:MF9295, CAC:MF9296
| stage = Supplement
}}

=Text=
{{#Wiki_filter:4300 Winfield Road Warrenville, IL 60555 IAMIMMIK Amop-   ExeLon G                                                             630 657 2000 Office RS-17-173 10 CFR 50.90 December 20, 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:==
Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

==References:==
(1) Letter from P. R. Simpson (Exelon Generation Company, LLC (EGC)) to NRC, "Application to Revise Technical Specifications to Adopt TSTF-542,
                              'Reactor Pressure Vessel Water Inventory Control,"' dated February 10 2017 (2)   Letter from R. S. Haskell (NRC) to B. C. Hanson (EGC), "Dresden Nuclear Power Station, Units 2 and 3 - Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler-542, Revision 2,
                              'Reactor Pressure Vessel Water Inventory Control' (CAC Nos. MF9295 and MF9296)," dated July 11, 2017 (3)   Letter from P. R. Simpson (EGC) to NRC, "Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"' dated July 13, 2017 In Reference 1, Exelon Generation Company, LLC (EGC) submitted a request for amendments to the Technical Specifications (TS) for Dresden Nuclear Power Station (DNPS), Units 2 and 3.
Specifically, EGC requested that the NRC complete its review and approval of a request to adopt TSTF-542.
In Reference 2, the NRC determined that additional information was required to complete the evaluation of the Reference 1 request. The response to Reference 2 was provided in Reference 3.

December 20, 2017 U.S. Nuclear Regulatory Commission Page 2 EGC recently identified that an issue related to TSTF-542 applies to its request to adopt the TSTF for DNPS, Units 2 and 3. Specifically, in accordance with TSTF-542, TS Table 3.3.5.2-1, Function 1.a (Core Spray System Reactor Steam Dome Pressure  Low (Injection Permissive),
and Function 2.a (Low Pressure Coolant Injection (LPCI) Reactor Steam Dome Pressure  Low (Injection Permissive) are required in Modes 4 and 5. Prior to TSTF-542, the analogous Functions 1.c and 2.c in TS Table 3.3.5.1-1 had a Mode 4 and 5 applicability modified by a footnote specifying that these functions were only required when the associated emergency core cooling system (ECCS) subsystem(s) were required to be operable per limiting condition for operation (LCO) 3.5.2, "ECCS Shutdown." The footnote was inadvertently omitted from Table 3.3.5.2-1 Functions 1.a and 2.a in TSTF-542. Without the footnote, the Reactor Steam Dome Pressure  Low functions would be required to be operable for all low pressure ECCS subsystems, regardless of whether they are credited for meeting LCO 3.5.2. Requiring the functions for all ECCS subsystems is unnecessary. In Modes 4 and 5 with the reactor steam dome at atmospheric pressure, these functions only serve to satisfy permissives for opening low pressure ECCS injection valves for manual actuation. Accordingly, a variation is proposed to affix Footnote (a) (i.e., "Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, `Reactor Pressure Vessel Water Inventory Control"') to the "Required Channels Per Function" column of Functions 1.a and 2.a of TS Table 3.3.5.2-1. The TS markup reflecting this variation and the corresponding revised TS page are included in Attachments 1 and 2, respectively.
Additionally, an issue was identified regarding the markups for TS Pages 3.5.2-1 and 3.5.2-3 pertaining to the use of the word subsystems versus subsystem in LCO 3.5.2 (i.e., TS Page 3.5.2-1), and system versus subsystem for the standby gas treatment system in LCO 3.5.2, Required Action DA (i.e., TS Page 3.5.2-3). The corrected markups and associated revised TS pages have been included in Attachments 1 and 2, respectively.
EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Reference 1.
The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
EGC is notifying the State of Illinois of this supplement to a previous application for a change to the TS by sending a copy of this letter and its attachment to the designated State Official in accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

December 20, 2017 U.S. Nuclear Regulatory Commission Page 3 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.
declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of December 2017.
pectfully, 712N 1
t_
Patrick R. Simpson Manager  Licensing Exelon Generation Company, LLC Attachments:       1. Proposed Technical Specifications Changes (Mark-Up)
: 2. Revised Technical Specifications Pages cc:     NRC Regional Administrator, Region III NRC Senior Resident Inspector  Dresden Nuclear Power Station Illinois Emergency Management Agency  Division of Nuclear Safety

Dresden Nuclear Power Station, Units 2 and 3 Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 1 - PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP) 3.3.5.2-3 3.5.2-1 3.5.2-3

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 SPECIFIED       CHANNELS PER     REQUIRED   SURVEILLANCE        ALLOWABLE FUNCTION            CONDITIONS         FUNCTION      ACTION A.1  REQUIREMENTS           VALUE
: 1. Core Spray System
: a. Reactor Steam Dome      4(a), 5(al           2 (a)           C      SR  3.3.5.2.2    < 341.7 psig PressureLow (Permissive)
: b. Core Spray Pump         4(a), 5(a)           1 per           D      SR  3.3.5.2.2    _> 802 gpm Discharge FlowLow                        pump (a)                                   and (Bypass)                                                                             s992 gpm
: 2. Low Pressure Coolant Injection (LPCI) System
: a. Reactor Steam Dome      4(3), 5(a)          2 (a)           C       SR  3.3.5.2.2    < 341.7 psi PressureLow (Permissive)
: b. Low Pressure Coolant    4(a), 5(a)          1 per           D       SR  3.3.5.2.2    _> 1107 gpm Injection Pump                            loop (a)
Discharge FlowLow (Bypass)
: 3. Shutdown Cooling System (SDC) Isolation
: a. Reactor Vessel Water        (b)         1 per trip           B      SR  3.3.5.2.1    _> 2.65 inches LevelLow                                 system                   SR  3.3.5.2.2
: 4. Reactor Water Cleanup System Isolation
: a. Reactor Vessel Water        (b)         1 per trip          B       SR 3.3.5.2.1     _> 2.65 inches LevelLow                                  system                   SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."
(b) 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.

FM=-'cCrVc!               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   EGGS-S rH tdewTRPV Water Inventory Control LCO 3.5.2            DRAIN TIME of RPV water inventory to the top of active fuel (TA F) shall be >_ 36 hours.
AND TweOne low pressure ECCS injection/spray subsystem= shall be OPERABLE.
APPLICABILITY:       MODES 4 and 5.,
MO DE 5 , exGept w4h the spent -fuel sten-a-gepeel gates remn                                                             n f the ved  and wateT level ~!           32   4 evepthe t op r eaG tep      uTpe v essel l n TT'QT '9n .
ACTIONS CONDITION                        REQUIRED ACTION                           COMPLETION TIME A. gRePRequired ECCS             A.1     Restore required ECCS                   4 hours injection/spray                        injection/spray subsystem inoperable.                  subsystem to OPERABLE status.
B. Required Action and            B.1     Initiate action to                      Immediately associated Completion                  establish a method of Time of Condition A                    water injection not met.                               capable of operating without offsite electrical power.+-cam e p eta-e n-swith      -
peter+; !
                                                                 ~
4 7 i n
                                               ~fTi'TT         t
                                                         , 7'g-'h e    p a G t e p vessel Tl.T (9PPR S (continued)
Dresden 2 and 3                           3.5.2-1                                Amendment No.

RPV Water Inventory ControlGGS - S            ewH 3.5.2 ACTIONS CONDITION                       REQUIRED ACTION                     COMPLETION TIME D. DRAIN TIME < 8                D.1     ------- NOTE --------
hours. Requi ed Ap-tiep C-2           Required ECCS
          ;Ss eG4 a ted r mn,otior4         injection/spray subsystem Time-+mot met.                        or additional method of water injection shall be capable of operating without offsite electrical power.
                                    -D-.4   Initiate action to establish an additional method of water injection          Immediately with water sources capable of maintaining RPV water level > TAF for
                                            >_ 36 hours. pestepe QURAB LE status .
AND D.2     Initiate action to establish secondary                Immediately containment boundary       ^r^ ors stand-by gas treatment subs stem to QPERAS E s tatus.
Immediately AND D.3     Initiate action to Tester^
i cnl 8ti nrii sol ate each Gapabilit 4R eaGh P^^~e4~secondary containment penetration flow path not or verify it can be manually isolated from the control room.                              Immediately AND D.4     Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.
(continued)
Dresden 2 and 3                           3.5.2-3                          Amendment No.

Dresden Nuclear Power Station, Units 2 and 3 Supplement to 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 - REVISED TECHNICAL SPECIFICATIONS PAGES 3.3.5.2-3 3.5.2-1 3.5.2-3

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 SPECIFIED       CHANNELS PER      REQUIRED  SURVEILLANCE       ALLOWABLE FUNCTION              CONDITIONS          FUNCTION     ACTION A.1  REQUIREMENTS         VALUE
: 1. Core Spray System
: a. Reactor Steam Dome       4(a)    5(a)          2 (a)            C     SR 3.3.5.2.2    <_ 341.7 psig PressureLow (Permissive)
: b. Core Spray Pump          4(a), 5(a)            1 per            D     SR 3.3.5.2.2    >_ 802 gpm Discharge FlowLow                           pump (a)                                 and (Bypass)                                                                              <_ 992 gpm
: 2. Low Pressure Coolant Injection (LPCI) System
: a. Reactor Steam Dome        4(a), 5(a)          2 (a)            C      SR 3.3.5.2.2    _< 341.7 psig PressureLow (Permissive)
: b. Low Pressure Coolant     4(a), 5(a)           1 per           D      SR 3.3.5.2.2    >_ 1107 gpm Injection Pump                              loop (a)
Discharge FlowLow (Bypass)
: 3. Shutdown Cooling System (SDC) Isolation
: a. Reactor Vessel Water          (b)          1 per trip           B     SR 3.3.5.2.1    ? 2.65 inches LevelLow                                   system                  SR 3.3.5.2.2
: 4. Reactor Water Cleanup System Isolation
: a. Reactor Vessel Water         (b)          1 per trip          B      SR 3.3.5.2.1    >_ 2.65 inches LevelLow                                    system                  SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water inventory Control."
(b) 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.

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.
AND 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.1      Initiate action to      Immediately associated Completion             establish a method of Time of Condition A               water injection not met.                          capable of operating without offsite 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 D. DRAIN TIME < 8 hours. 1D.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 subsystem is capable of being placed in oppratinn-(continued)
Dresden 2 and 3                 3.5.2-3               Amendment No.}}