RS-09-003, Additional Information Supporting Requests for License Amendments to Adopt TSTF-423, Technical Specifications End States, NEDC-32988-A: Difference between revisions

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Exelon Generation                  www.exeloncorp.com                                      Nuclear 4300 Winfield Road Warrenville, IL60555 RS-09-003 January 30, 2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
 
==Subject:==
Additional Information Supporting Requests for License Amendments to Adopt TSTF-423, "Technical Specifications End States, NEDC-32988-A"
 
==References:==
: 1.      Letter from D. M. Benyak (AmerGen Energy Company, LLC) to U. S.
NRC, "Application for Technical Specification Change TSTF-423, Risk Informed Modification to Selected Required Action End States for BWR Plants, Using the Consolidated Line Item Improvement Process," dated June 21, 2007
: 2.      Letter from D. M. Benyak (Exelon Generation Company, LLC) to U. S.
NRC, "Application for Technical Specification Change TSTF-423, Risk Informed Modification to Selected Required Action End States for BWR Plants, Using the Consolidated Line Item Improvement Process (RS                              118)," dated October 9, 2007
: 3.      Letter from D. M. Benyak (Exelon Generation Company, LLC) to U. S.
NRC, "Application for Technical Specification Change TSTF-423, Risk Informed Modification to Selected Required Action End States for BWR Plants, Using the Consolidated Line Item Improvement Process (RS                              117)," dated October 9, 2007
 
January 30, 2009 U. S. Nuclear Regulatory Commission Page 2
: 4. E-mail from S. Sands (U. S. NRC) to T. A. Byam (Exelon Generation Company, LLC), "TSTF-423 - RAIs," dated January 8, 2009
: 5. TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 0,
                      'Technical Specifications End States, NEDC-32988-A,"' Revision 1, March 2007
: 6. Volume 71, Federal Register, Page 14726 (71 FRN14726), "Notice of Availability of Model Application Concerning Technical Specifications for Boiling Water Reactor Plants to Risk-Inform Requirements Regarding Selected Required Action End States Using the Consolidated Line Item Improvement Process," dated March 23, 2006 In References 1 through 3, AmerGen Energy Company, LLC (AmerGen) and Exelon Generation Company, LLC (EGC) requested amendments to Facility Operating License No. NPF-62, Renewed Facility Operating License Nos. DPR-19 and DPR-25, and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Clinton Power Station (CPS), Unit 1; Dresden Nuclear Power Station (DNPS), Units 2 and 3; and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2; respectively. The proposed changes request adoption of Technical Specification Task Force (TSTF)-423 into station Technical Specifications (TS).
In Reference 4, the NRC requested additional information to complete its review. In response to Reference 4, EGC is providing information as discussed in Attachment 1 and supported by Attachments 2 through 8.
Attachments 2, 4, and 6 provide revised proposed TS pages for CPS, DNPS, and QCNPS, respectively. Attachments 3, 5, and 7 provide revised proposed TS Bases pages for CPS, DNPS, and QCNPS, respectively, and are provided for information only and do not require NRC approval. Because some of the TS have been amended since References 1 through 3 were submitted, EGC is providing markups on the current versions of these TS and has identified these recently amended TS with an asterisk (*).
In support of the proposed changes in References 1 through 3, AmerGen and EGC made two commitments. Subsequently, EGC has determined that a commitment made in these submittals should be updated to align with the supplemental information provided in this letter.
This updated commitment takes exception to the portion of the TSTF implementation guide (Reference 5) that no longer applies.
EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of References 1 through 3. The information provided in this submittal does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration. This evaluation continues to demonstrate that the information published in the FederalRegister notice in Reference 6 supports the conclusion that the proposed license amendment does not involve a significant hazards consideration.
 
January 30, 2009 U. S. Nuclear Regulatory Commission Page 3 Revised regulatory commitments contained in this letter are listed in Attachment 8. The supporting information provided in this submittal has been reviewed and approved by the CPS, DNPS, and QCNPS Plant Operations Review Committees and the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. Should you have any questions concerning this letter, please contact Michelle Yun at (630) 657-2818.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of January 2009.
Je          a~nsen Ma a er- Licensing cc:    NRC Senior Resident Inspector NRC Regional Administrator, Region III : Response to Request for Additional Information : Markup of Revised Proposed CPS Technical Specifications Pages : Markup of Revised Proposed CPS Technical Specifications Bases Pages : Markup of Revised Proposed DNPS Technical Specifications Pages : Markup of Revised Proposed DNPS Technical Specifications Bases Pages : Markup of Revised Proposed QCNPS Technical Specifications Pages : Markup of Revised Proposed QCNPS Technical Specifications Bases Pages : List of Regulatory Commitments
 
ATTACHMENT I Response to Request for Additional Information NRC Request I Please explain how the licensee would prevent LCO 3.0.4(a) from being inappropriately invoked during startup to facilitate going up in mode with inoperable systems or equipment.
 
===Response===
To prevent LCO 3.0.4(a) from being inappropriately invoked during startup to facilitate going up in mode with inoperable systems or equipment, EGC proposes the insertion of a Note into those Required Actions that are affected by TSTF-423. The Note will appear as follows:
                    ---------------- NOTE --------------------------------
LCO 3.0.4.a is        not applicable when entering MODE 3.
This Note has been added to the TS markups previously submitted for CPS, DNPS, and QCNPS. Some of the previously submitted TS have been amended since EGG's requests to adopt TSTF-423 at CPS, DNPS, and QCNPS. Accordingly, currently implemented versions of TS have been marked up to include the original TSTF-423 adoption markups and the above shown Note. These TS have been designated by an asterisk (*).
NRC Request 2 Please demonstrate how the licensee would maintain an equivalent level of protection while operating in Mode 3 with an inoperable primary containment.
 
===Response===
EGC has evaluated its requests to amend station TS for primary containment and has determined to withdraw requests to amend this TS. This is reflected in the absence of primary containment TS in the attached marked up TS and TS Bases. Because Mode 3 is no longer the requested end state for primary containment, EGC has determined that it is necessary to revise its original commitment to follow guidance established in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 0, 'Technical Specifications End States, NEDC-32988-A,"'
Revision 1, to indicate that the following statement on Page 2 no longer applies:
"If Primary Containment is not operable, Secondary Containment and Standby Gas Treatment must be verified operable in order to remain in Mode 3."
 
ATTACHMENT 2 Markup of Revised Proposed CPS Technical Specifications Pages TS Note Insert:
------------------------------- NOTE--------------------------------
LCO 3.0.4.a is not applicable when entering MODE 3.
Revised Proposed CPS TS Pages 3.3  -81 3.5  -2 3.5  -3 3.6  -22 3.6  -24 3.6  -27a 3.6  -32 3.6  -43 3.6  -51 3.6  -52 3.6  -69 3.7  -1 3.7  -2 3.7  -4*
3.7  -5*
3.7  -6*
3.7  -8 3.7  -11 3.8  -3 3.8  -24 3.8  -34 3.8  -35 3.8  -40
* Denotes TS pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS version Page 1 of 1
 
RPS Electric    Power Monitoring 3.3.8.2 3.3  INSTRUMENTATION 3.3.8.2  Reactor Protection System (RPS)      Electric Power Monitoring LCO  3.3.8.2      One RPS electric power monitoring assembly shall be OPERABLE for each inservice RPS special solenoid power supply or alternate power supply.
APPLICABILITY:      MODES 1, 2, and 3, MODES 4 and 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One or both inservice      A.1    Remove associated              1 hour power supplies with              inservice power the electric power                supply(s) from monitoring assembly              service.
inoperable.
                                                  <  TS Note Inserti B. Required Action and        B.1    Be in MODE 3.                  12 hours associated Completion Time of Condition A      4AD-not met in MODE 1, 2, or 3.                      A.2    Be in MODE 4                  3 C. Required Action and        C.1    Initiate action to            Immediately associated Completion              fully insert all Time of Condition A                insertable control rods not met in MODE 4 or 5            in core cells with any control rod              containing one or more withdrawn from a core              fuel assemblies.
cell containing one or more fuel assemblies.
CLINTON                              3.3-81                      Amendment No. 9S, 102
 
ECCS -Operating 3.5.1 ACTIONS  (continued)
CONDITION                  REQUIRED ACTION              COMPLETION TIME C. Two ECCS injection    C.1      Restore one ECCS          72 hours subsystems inoperable.          injection/spray subsystem to OPERABLE OR                              status.
One ECCS injection and one ECCS spray subsystem inoperable.
ITS Note Inser D. Required Action and    D.1      Be in  MODE 3.            12 hours associated Completion Time of Condition A,  pdiB B, or C not met.
5.2  Be +/-' MOED 4.                6htr E. One ADS valve          E.1      Restore ADS valve to      14 days inoperable.                    OPERABLE status.
F. One ADS valve          F.1      Restore ADS valve to      72 hours inoperable.                    OPERABLE status.
AND                    OR One low pressure ECCS  F.2      Restore low pressure      72 hours injection/spray                  ECCS injection/spray subsystem inoperable,            subsystem to OPERABLE status.
(continued)
CLINTON                              3.5-2                        Amendment No.          95
 
ECCS -Operating 3.5.1 ACTIONS    (continued)
CONDITION            REQUIRED ACTION              COMPLETION TIME
                                            *TS  Note Insert G. Two or more ADS valves G.l  Be in MODE 3.              12 hours inoperable.
OR Required Action and        dmc- pressure te associated Completion        _5O VZig.
Time of Condition E or F not met.
H. HPCS and Low Pressure  H.1  Enter LCO 3.0.3.          Immediately Core Spray (LPCS)
Systems inoperable.
OR Three or more ECCS injection/spray subsystems inoperable.
OR HPCS System and one or more ADS valves inoperable.
OR Two or more ECCS injection/spray subsystems and one or more ADS valves inoperable.
CL INTON                          3 .5-3                      Amendment No. 95
 
LLS Valves 3.6.1.6 3.6  CONTAINMENT SYSTEMS 3.6.1.6  Low-Low Set (LLS)  Valves LCO  3.6.1.6      The LLS function of five safety/relief valves shall be OPERABLE.
APPLICABILITY:    MODES 1, 2,  and 3.
ACTIONS CONDITION                      REQUIRED ACTION        COMPLETION TIME A. One LLS valve            A.1    Restore LLS valve to      14 days inoperable.                      OPERABLE status.
B. Required Action and        B.1    Be in MODE 3.TS NoteInser 12 hours associated Completion Time of Condition A        ___
not met.
B.2    Be in M    3. iODE        1  hours Two or more LLS valves    C.1    Be inMODE 3.              12 hours inoperable.
AND 0.2    Be in MODE 4              36 hours CLINTON                              3.6-22                        Amendment No. 95
 
RHR Containment Spray System 3.6.1.7 3.6  CONTAINMENT SYSTEMS 3.6.1.7  Residual Heat Removal    (RHR)  Containment Spray System LCO  3.6.1.7      Two RHR containment spray subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION                COMPLETION TIME A. One RHR containment      A.1    Restore RHR                    7 days spray subsystem                containment spray inoperable,                    subsystem to OPERABLE status.
B. Two RHR containment      B.1    Restore one RHR                8 hours spray subsystems                containment spray inoperable,                    subsystem to OPERABLE status.
ITS Note Inserti C. Required Action and      C.1    Be in MODE 3.                  12 hours associated Completion Time not met.          -AN-e.2    Be in  IODE 4.                  36 hour CLINTON                              3.6-24                            Amendment No. 95
 
FWLCS 3.6.1.9 3.6  CONTAINMENT SYSTEMS 3.6.1.9  Feedwater Leakage Control System (FWLCS)
LCO  3.6.1.9      Two FWLCS subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2,  and 3.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One FWLCS subsystem      A.1    Restore FWLCS                30 days inoperable,                    subsystem to OPERABLE status.
B. Two FWLCS subsystems      B.1    Restore one FWLCS            7 days inoperable,                    subsystem to OPERABLE status.
                                              <    iTS Note Insert C. Required Action and      C.1    Be in MODE 3.                12 hours associated Completion Time not met.
e.2    Bein MODBE 4.                3  er SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUENCY SR  3.6.1.9.1      Perform a system functional test of each          24 months FWLCS subsystem.
CLINTON                            3.6-27a                          Amendment No. 169
 
RHR Suppression Pool  Cooling 3.6.2.3 3.6  CONTAINMENT SYSTEMS 3.6.2.3  Residual Heat Removal    (RHR)  Suppression Pool Cooling LCO  3.6.2.3      Two RHR suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION            COMPLETION TIME A. One RHR suppression      A.1      Restore RHR              7 days pool cooling subsystem              suppression pool inoperable,                          cooling subsystem to OPERABLE status.
B. Required Action and      B.1      Be in MODE 3.            12 hours associated Completion Time of Condition A      ___
not met.
B.2      Be i+/- MODE 4.              36-iete C  Two RHR suppression      C.A        Be in MODE 3.            12 hours pool cooling subsystems inoperable. ADQ C.2        Be in MODE 4.            36 hours CLINTON                              3.6-32                        Amendment No. 95
 
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 primary or secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).
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      B.1      Be in MODE 3.          12 hours associated Completion Time of Condition A      PdH-not met.
5.2    Be. in .. e. t.ott 4-(continued)
CLINTON                              3.6-43                    Amendment No. 147
 
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 primary or secondary containment, During operations with a potential for draining the reactor I
vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION          COMPLETION TIME A. One SGT subsystem        A.1    Restore SGT subsystem      7 days inoperable,                      to OPERABLE status.
B. Required Action and        B.1    Be in MODE    T Note Inser 12 hours associated Completion Time of Condition A      AND not met in MODE 1, 2, or 3.                      B.. BeiNGDE-(continued)
CLINTON                              3.6-51                        Amendment No. 147
 
SGT System 3.6.4.3 ACTIONS    (continued)
CONDITION                  REQUIRED ACTION        COMPLETION TIME 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.
primary or secondary                                                        l containment, or during  OR OPDRVs.
C.2.1    Suspend movement of    Immediately recently irradiated fuel assemblies in the primary and secondary containment.
AND C.2.2    Initiate action to suspend OPDRVs.
Immediately I
D. Two SGT subsystems    D.1      Enter LC33.0.3.3      Imm.diately inoperable in MODE 1,            eiMODE'I                hours 2, or 3.Not (continued)
CLINTON                          3.6-52                      Amendment No. 147
 
Drywell Post-LOCA Vacuum Relief System 3.6.5.6 ACTIONS    (continued)
CONDITION                        REQUIRED ACTION                COMPLETION TIME C. Two or more drywell            C.l    Restore drywell post-        72 hours post-LOCA vacuum                        LOCA vacuum relief relief subsystems                      subsystems to inoperable for reasons                  OPERABLE status.
other than Condition A.
D. Required Action and            D.1    Be in MODE 3.                12 hours associated Completion Time of Condition-*-r,[        AND
        , r- C no9t mt D.2    Be in MODE 4.                36 hours E. Required Action and associated  E.1      Be in MODE 3                12 hours Completion Time of Condition B or C not met.                  ITS                        Note Insert CLINTON                                  3.6-69                            Amendment No. 95
 
Division 1 and 2 SX Subsystems and UHS 3.7.1 3.7  PLANT SYSTEMS 3.7.1    Division 1 and 2 Shutdown Service Water              (SX)  Subsystems and Ultimate Heat Sink (UHS)
LCO  3.7.1            Division 1 and 2 SX subsystems and the UHS shall be OPERABLE.
APPLICABILITY:          MODES 1, 2,  and 3.
ACTIONS CONDITION                        REQUIRED ACTION                  COMPLETION TIME A. UHS water volume not          A.1      Restore UHS water              90 days within limit,                            volume to within limit.
B. Division 1 or 2 SX              ------------ NOTES------------
subsystem inoperable.          1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources--Operating, '
for diesel generator made inoperable by SX.
: 2. Enter applicable Conditions and Required Actions of LCO 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown, "
for RHR shutdown cooling subsystem made inoperable by SX.
B.1        Restore SX subsystem          72 hours to OPERABLE status.
(continued)
C. Required Action and associated CN        Be in MODE 3.                  1e ours not met.                                                  &#xfd;TS]Note Inser CLINTON                                      3.7-1                            Amendment No. 95
 
Division 1 and 2 SX Subsystems and.UHS 3.7.1 Actions  (continued)
CONDITION                    REQUIRED ACTION        I COMPLETION TIME
[    . Required Action and      ED]      Be in MODE 3.          12 hours associated Completion Time of Condition A      AND
      -em-4.-not met.
Be in MODE 4.          36 hours OR Division 1 and 2 SX subsystems inoperable.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR  3.7.1.1    Verify UHS water volume is &#x17d; 593 acre-ft.        In accordance with UHS Erosion, Sediment Monitoring, and Dredging Program SR  3.7.1.2    Verify each required SX subsystem manual,        31 days power operated, and automatic valve in the flow path servicing safety related systems or components, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR  3.7.1.3    Verify each SX subsystem actuates on an actual or simulated initiation signal.
24 months I
CLINTON                                3.7-2                    Amendment No. 169
 
Control Room Ventilation System 3.7.3 3.7    PLANT SYSTEM 3.7.3    Control Room Ventilation System LCO    3.7.3            Two Control Room Ventilation subsystems shall be OPERABLE.
                                                ------------ NOTE----------------------------
The control room envelope (CRE) boundary may be opened intermittently under administrative control.
APPLICABILITY:          MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the primary or secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                              REQUIRED ACTION            COMPLETION TIME A. One Control Room                    A.1        Restore Control Room      7 days Ventilation subsystem                          Ventilation subsystem inoperable for reasons                          to OPERABLE status.
other than Condition r%/. One or more Control                            Initiate  action to      Immediately Room Ventilation                                implement mitigating subsystems inoperable                          actions.
due to inoperable CRE boundary in MODE 1,                  AND 2, or 3.
Verify mitigating        24 hours WI          actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
AND 90 days
                                            /.3        Restore CRE boundary to OPERABLE status.
(continued)
B. Hequired Action and associated        B1        Be in MODE 3.7-"          12 hours Completion Time of Condition A not met in MODE 1, 2, or 3.            1 CL NT N".74"m                                                                      nd en    N . 7 CLINTON                                              3.7-4                      Amendment No. 178
 
Control    Room Ventilation      System 3.7.3 ACTIONS      (continued)
CONDITION                          REQUIRED ACTION                      COMPLETION      TIME
  *. Required Action and                          Be in      MODE  3.              12 hours Associated Completion Time of Condition--A---
M-B5 not met in MODE 1,          AND 2,  or 3.
Be in      MODE  4.              36 hours 1-                                                1
[qlK. Required Action and associated      Completion
                                      ------------- NOTE-------------
LCO 3.0.3        is  not applicable.
Time of Condition A not met during movement of irradiated        A71            Place OPERABLE                    Immediately fuel assemblies in the primary or secondary          19            Control Room Ventilation          subsystem containment, during                          in high radiation CORE ALTERATIONS, or                        mode.
during OPDRVs.
OR
                                          .-2 .1    Suspend movement of                Immediately irradiated        fuel assemblies in the primary and secondary containment.
19      AND
                                      /.2.2        Suspend CORE                      Immediately ALTERATIONS.
AND Initiate      action to          Immediately suspend OPDRVs.
: 5. Two Control Room              /.1            Ete      iLCM E 3. e..
Ventilation      subsystems inoperable in MODE 1,          19                                                F12h-urs-2,  or 3 for reasons                                        ITS Note Insert other than Condition (continued)
CLINTON                                          3.7-5                              Amendment      No. 178
 
Control Room Ventilation System 3.7.3 ACTIONS    (continued)
CONDITION                  E  REQUIRED ACTION            COMPLETION TIME Two Control Room          /.i1    Suspend movement of      Immediately Ventilation subsystems              irradiated fuel inoperable during                  assemblies in the movement of irradiated              primary and secondary fuel assemblies in the              containment.
primary or secondary containment, during        AND CORE ALTERATIONS, or during OPDRVs.                      Suspend CORE            Immediately
                                /A2 ALTERATIONS.
OR AND One or more Control Room Ventilation          /-3      Initiate  action to      Immediately subsystems inoperable              suspend OPDRVs.
due to inoperable CRE boundary during movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR  3.7.3.1      Operate each Control Room Ventilation            31 days subsystem with flow through the makeup filter  for &#x17d; 10 continuous hours with the heaters operating.
SR  3.7.3.2      Operate each Control Room Ventilation            31 days subsystem with flow through the recirculation filter  for &#x17d; 15 minutes.
(continued)
CLINTON                                  3.7-6                    Amendment No. 178
 
Control Room AC System 3.7.4 3.7  PLANT SYSTEMS 3.7.4    Control Room Air Conditioning    (AC)  System LCO  3.7.4        Two control room AC subsystems shall be OPERABLE.
APPLICABILITY:      MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the primary or secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION            COMPLETION TIME A. One control room AC      A.1        Restore control room    30 days subsystem inoperable.                AC subsystem to OPERABLE status.
B. Two control room AC      B.1        Verify control room      Once per 4 hours subsystems inoperable,              area temperature
* 86 OF.
AND B.2        Restore one control      7 days room AC subsystem to OPERABLE status.
C. Required Action and      C.1        Be in MODE 3.            12 hours Associated Completion Time of Condition A or    lTSNOtelnsert B not met in MODE 1, 2, or 3.                  e.2        Be i  M..... 4+        .. .......
(continued)
CLINTON                                  3 .7-8                    Amendment No. 95
 
Main Condenser  Offgas 3.7.5 3.7  PLANT SYSTEMS 3.7.5    Main Condenser Offgas LCO  3. 7.5        The radioactivity rate of the noble gases measured at the offgas recombiner effluent shall be
* 289 mCi/second after decay of 30 minutes.
APPLICABILITY:      MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.
ACTIONS CONDITION                    REQUIRED ACTION                COMPLETION TIME A. Radioactivity rate of      A.1      Restore radioactivity        72 hours the noble gases not                  rate of the noble within limit,                        gases to within limit.
B. Required Action and        B.1      Isolate all main              12 hours associated Completion                steam lines.
Time not met.
OR B.2      Isolate SJAE.                12 hours OR B.3X      Be in MODE 3.                12 hours ADTS                Note Insert B.3.2    DBe in HOD 4.                36 hours CLINTON                                3.7-11                            Amendment No. 95
 
AC Sources--Operating 3.8.1 ACTIONS  (continued)
CONDITION              REQUIRED ACTION              COMPLETION TIME C. Two offsite circuits    C.1  Declare required          12 hours from inoperable,                  feature(s) inoperable      discovery of when the redundant        Condition C required feature(s)        concurrent with are inoperable.            inoperability of redundant required feature(s)
AND C.2  Restore one offsite        24 hours circuit to OPERABLE status.
D. One offsite circuit    D.1  Restore offsite            12 hours inoperable,                  circuit to OPERABLE status.
AND OR One required DG inoperable.            D.2  Restore required DG        12 hours to OPERABLE status.
E. Two required DGs        E.1  Restore one required      2 hours inoperable.                  DG to OPERABLE status.                    OR 24 hours if Division 3 DG is inoperable F. Required Action and    F.1  Be in MODE 3.              12 hours Associated Completion Time of Condition A,  -Aa--              TS Note Insert B, C, D, or E not met.
F.2  De in MODS 4.
(continued)
CLINTON                              3.8-3                    Amendment No. 95
 
DC Sources--Operating 3.8.4 3.8    ELECTRICAL POWER SYSTEMS 3.8.4      DC Sources--Operating LCO    3.8.4            The Division 1, Division 2, Division 3, and Division 4 DC electrical power subsystems shall be OPERABLE.
APPLICABILITY:          MODES 1, 2,    and 3.
ACTIONS CONDITION                          REQUIRED ACTION              COMPLETION TIME A. One battery charger on            A.1        Restore battery          2 hours Division 1 or 2                            terminal voltage to inoperable,                                greater than or equal to the minimum established float voltage.
AND A.2        Verify battery float current < 2 amps.        Once per 12 hours AND A.3        Restore battery          7 days charger to OPERABLE status.
B. One battery on                  B.1        Restore battery to        2 hours Division 1 or 2                            OPERABLE status.
inoperable.
2 hours C. Division 1 or 2 DC                C.1        Restore Division 1 electrical power                            and 2 DC electrical subsystem inoperable                      power subsystems to for reasons other                        OPERABLE status.
than Condition A or B.
,. Division 3 or 4 DC                E).      Declare High Pressure      Immediately electrical power                            Core Spray System subsystem inoperable,                      inoperable.
/.      Required Action and                FF      Be in MODE 3.              12 hours associated Completion Time not met.                    AND Io C  n itinE Condition E                  -Ffor F.2  Be in MODE 4.              36 hours
: 0. Required Action and associated  D1          Be in MODE 3.Sote Inse  12 hours Completion Time for Condition A, B, or C not met.
CL I NTON CLINTON3.84Amnmn                                  3.8-24                                No Amendment No. 12 142
 
Inverters-Operating 3.8.7 3.8              ELECTRICAL POWER SYSTEMS 3.8.7                    Inverters--Operating LCO              3. 8.7                                      The Division 1, 2, 3, and 4 inverters, and A and B RPS solenoid bus inverters shall be OPERABLE.
APPLICABILITY:                                                MODES 1, 2,      and 3.
ACTIONS
-------------------------------------NOTE--------------------------------------
Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems--Operating," with any uninterruptible AC bus de-energized.
CONDITION                                                                              REQUIRED ACTION                COMPLETION TIME A.            Division 1 or 2                                                A.1        Restore Division 1            7 days inverter inoperable,                                                    and 2 inverters to OPERABLE status.
,..              One or more Division 3                                        -B-I-      Declare High Pressure        Immediately or 4 inverters                                                *-j        Core Spray System
'.J              inoperable.                                                              inoperable.
/.              One RPS solenoid bus                                          e.-4.-1    Transfer RPS bus to          1 hour inverter inoperable.                                          E          alternate power source.
AND
                                                                              -~i.2      Verify RPS bus supply          Once per 8 hours 57 Hz.
_frequency      thereafter OR 1 hour
                                                                              -e-i-      De-energize RPS bus.
(continued)
B.            Required Action and associated                                  B.1      Be in MODE 3.                  12 hours Completion Time of Condition A not met.                                                                                TS Note Insert CLINTON                                                                                  3.8-34                          Amendment No. 174
 
Inverters-Operating 3.8.7 ACTIONS    (continued)
CONDITION                      REQUIRED ACTION        COMPLETION TIME Id. Both RPS solenoid bus        -B-+/-      De-energize one RPS    1 hour inverters inoperable.        F7      solenoid bus.
7I.
,. Required Action and                    Be in MODE 3.          12 hours F  associated Completion Tim not met.                  AND Be in MODE 4.          36 hours Ifor Condition C, D, or E      F2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR  3.8.7.1        Verify correct inverter voltage, frequency,    7 days and alignment to required uninterruptible AC buses and RPS solenoid buses.
CLINTON                                    3.8-3S                    Amendment No. 95
 
Distribution Systems--Operating 3.8.9 ACTIONS  (continued)
CONDITION                REQUIRED ACTION          COMPLETION TIME C. One or more Division 1 C.1      Restore Division 1      2 hours or 2 DC electrical              and 2 DC electrical power distribution              power distribution      AND subsystems inoperable,          subsystems to OPERABLE status.        16 hours from discovery of failure to meet LCO D. Required Action and    D.1      Be in MODE 3.          12 hours associated Completion Time of Condition A,  MiTSBNoteInsert B, or C not met.
E. One or more Division 3 E.1      Declare High Pressure  Immediately or 4 AC, DC, or                Core Spray System uninterruptible AC bus          inoperable.
electrical power distribution subsystems inoperable.
F. Two or more divisions  F.1      Enter LCO 3.0.3.        Immediately with inoperable distribution subsystems that result in a loss of function.
CLINTON                          3.8-40                      Amendment No. 95
 
ATTACHMENT 3 Markup of Revised Proposed CPS Technical Specifications Bases Pages Revised Proposed CPS TS Bases Pages B 3.3 -233 to B 3.3 -236 B 3.5 -7 B 3.5 -8 B 3.5 -10 to B 3.5 -14a B 3.6 -36 to B 3.6 -38 B 3.6 -41 B 3.6 -43 B 3.6 -47c B 3.6 -58 B 3.6 -59 B 3.6 -86* to B 3.6 -88a B 3.6 -98 to B 3.6 -101a B 3.6 -130 to B 3.6 -132 B 3.7 -4 to B 3.6 -6 B 3.7 -13* to B 3.7 -16c*
B 3.7 -19 B 3.7 -21 B 3.7 -23 to B 3.7 -24a B 3.8 -12 to B 3.8 -16 B 3.8 -18 B 3.8 -22 B 3.8 -24 B 3.8 -29 B 3.8 -31 B 3.8 -32a B 3.8 -55 B 3.8 -58 B 3.8 -71b*
B 3.8 -72*
B 3.8 -73*
B 3.8 -85 to B 3.8 -87
* Denotes TS Bases pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS Bases page version Page 1 of 1
 
RPS Electric Power Monitoring B 3.3.8.2 BASES APPLICABILITY    in MODES 1, 2, and 3, and MODES 4 and 5 with any control rod (continued)  withdrawn from a core cell containing one or more fuel assemblies.
ACTIONS          A.1 If the power monitoring assembly for an inservice power supply (UPS or alternate) is inoperable, or the power monitoring assembly in each inservice power supply is inoperable, the system protective function is lost.                    In this condition, 1 hour is allowed to restore the assembly to OPERABLE status for each inservice power supply.                If the inoperable assembly for each inservice power supply cannot be restored to OPERABLE status, the associated power supplies must be removed from service within 1 hour (Required Action A.1).        An alternate power supply with OPERABLE assemblies may then be used to power one RPS bus.
The 1 hour Completion Time is sufficient for the plant operations personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration or removal from service of the electric power monitoring assemblies.
Alternately, if it is not desired to remove the power supply(s) from service (e.g., as in the case where removing the power supply(s) from service would result in a scram or isolation), Condition B or C, as applicable, must be entered and its Required Actions taken.
In addition to the actions identified in Condition A, if the frequency of the supply to the RPS solenoid bus is
* 57 Hz, the OPERABILITY of all Class 1E equipment which could have been subjected to the abnormal frequency on the associated RPS solenoid bus must be demonstrated by the performance of a CHANNEL FUNCTIONAL TEST or CHANNEL CALIBRATION, as required.      These tests should be performed within 24 hours of discovering the underfrequency condition.
B. 1 -arrd---.2-the plant must be        If any Required Action and associated Compiletion Time of broughtoverall which          plant! in to a MODE      Condition must  be yerfor,,ed. Thisin place.
A is not met      MODE 1,th~e2, plant  a aplant or 3 +/-r,          shutdct.t conditlon        .
risk is minimized.      Where    i    a  e            o    d thT1.~gh tht    i1opFelabi        RPS (continued)
CLINTON                            B 3.3-233                              Revision No.        1-1
 
RPS Electric Power Monitoring B 3.3.8.2 BASES ACTIONS      B.1Iand-B.2 (continued) olo~~.i pv......it.in      &--ascn'ly(s)] f requiredad eleetrie pe-,c ..... ...                    ilce r-e,      ....
ensresth.at the safety f.t......    .f  .
t.. P. (e.g., -        a,    f Gontrol _49s) is met .              The plant shutdown is accomplished by placing the plant in MODE 3 within 12 hours with+/-- 36.........."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.1 If any Required Action and associated Completion Time of Condition A is not met in MODE 4 or 5, with any control rod withdrawn from a core cell containing one or more fuel assemblies, the operator must immediately initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies (Required Action C.1) . This Required Action results in the least reactive condition for the reactor core and ensures that the safety function of the RPS (e.g., scram of control rods) is not required.
SURVEILLANCE SR  3.3.8.2.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each overvoltage, undervoltage, and underfrequency 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 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.
As noted in the Surveillance, the CHANNEL FUNCTIONAL TEST is only required to be performed while the plant is in a condition in which the loss of the RPS bus will not jeopardize steady state power operation (the design of the system is such that the power source must be removed from service to conduct the Surveillance).      The 24 hours is intended to indicate an outage of sufficient duration to allow for scheduling and proper performance of the (continued)
CLINTON                    B 3.3-234                            Revision No. 5-5
 
RPS Electric Power Monitoring B 3.3.8.2 BASES SURVEILLANCE SR  3.3.8.2.1  (continued)
REQUIREMENTS Surveillance. The 184 day Frequency and the Note in the Surveillance are 1psed on guidance provided in Generic Letter 91-09 (Ref.2."
SR  3.3.8.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies that the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.
The Frequency is based upon the assumption of a 24 month calibration interval in the determination of the magnitude of equipment drift in the setpoint analysis.
SR  3.3.8.2.3 Performance of a system functional test demonstrates a required system actuation (simulated or actual) signal.        The logic of the system will automatically trip open the associated power monitoring assembly circuit breaker.      Only one signal per power monitoring assembly is required to be tested. This Surveillance overlaps with the CHANNEL CALIBRATION to provide complete testing of the safety function. The system functional test of the Class 1E circuit breakers is included as part of this test to provide complete testing of the safety function. If the breakers are incapable of operating, the associated electric power monitoring assembly would be inoperable.
The 24 month 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 (continued)
CLINTON                    B 3.3-235                      Revision No. 10-7
 
RPS Electric Power Monitoring B 3.3.8.2 BASES SURVEILLANCE SR  3.3.8.2.3  (continued)
REQUIREMENTS Surveillance were performed with the reactor at power.
Operating experience has shown that these components usually pass the Surveillance.
REFERENCES  1. USAR, Section 8.3.1.1.3.1.
NRC Generic Letter 91-09, "Modification of Surveillance Interval for the Electric Protective Assemblies in Power Supplies for the Reactor Protection System."
CLINTON                    B 3.3-236                    Revision No. 10-7
 
ECCS-Operating B 3.5.1 BASES ACTIONS              C.'
(continued)
With two ECCS injection subsystems inoperable or one ECCS injection and one ECCS spray subsystem inoperable, at least one ECCS injection/spray subsystem must be restored to OPERABLE status within 72 hours.            In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA.      However, overall ECCS reliability is reduced in this Condition because a single failure in one of the remaining OPERABLE subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function.            Since the ECCS availability is reduced relative to Condition A, a more restrictive Completion Time is imposed.            The 72 hour Completion Time is based on a reliability study, as provided in Reference 12.
D.1 -ad -.- 2 If any Required Action and associated Completion Time of overall plant risk Condition A, B, or C            not met, the plant must be brought is minimized.      to a MODE in which theLQO does nolt apply.            To achieve this status, the plant must be brought to at east MODE 3 within 12 hours ata        M MOD4      ........
h.n 36-      . The allowed ECompletion            Time,---e&m/reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
E.1 4  The LCO requires seven ADS valves to be OPERABLE to provide the ADS function.      Reference'kicontains the results of an analysis that evaluated the effect of one ADS valve being out of service.      Per this analysis, operation of only six ADS valves will provide the required depressurization.
However, overall reliability of the ADS is reduced because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability.            Therefore, operation is only allowed for a limited time.            The 14 day Completion Time is based on a reliability study (Ref. 12) and has been found to be acceptable through operating experience.
(continued)
CLINTON                                    B 3.5-7                            Revision No. 0
 
ECCS---Operating B3.5.1 BASES ACTIONS        F.1 and F.2 (continued)
If any one low pressure ECCS injection/spray subsystem is inoperable in addition to one inoperable ADS valve, adequate core cooling is ensured by the OPERABILITY of HPCS and the remaining low pressure ECCS injection/spray subsystems.
However, the overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available.      Since both a portion of a high pressure (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours is required to restore either the low pressure ECCS injection/spray subsystem or the ADS valve to OPERABLE status. This Completion Time is based on a reliability study (Ref. 12) and has been found to be acceptable through operating experience.
If any Required Action and associated Completion Time of Condition E or F are not met or if two or more\*DS valves are inop rble,    the plant must be brought to a mndltion in Overall plant risk    wIcth~rb r
theniCe dpb    nout apply. To achieve this status, the isminimized          plant must be brought to at least MODE 3 within 12 hours and-reacter steam dome presutr      reduted to ! i 4r Ae*ij  .thin
                        -hoserts& The allowed Completion Time,                            sreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
H.1 When multiple ECCS subsystems are inoperable, as stated in Condition H, the plant is in a degraded condition not specifically justified for continued operation, and may be in a condition outside of the accident analyses.        Therefore, LCO 3.0.3 must be entered immediately.
(continued)
CL INTON                            B 3.5-8                        Revision No. 0
 
ECCS--<Operating B 3.5.1 BASES SURVEILLANCE SR  3.5.1.2  (continued)
REQUIREMENTS LPCI mode and not otherwise inoperable.      This allows operation in the RHR shutdown cooling mode during MODE 3 if necessary.
SR 3.5.1.3 Verification every 31 days that ADS accumulator supply pressure is &#x17d; 140 psig assures adequate air pressure for reliable ADS operation.      The accumulator on each ADS valve provides pneumatic pressure for valve actuation.        The designed pneumatic supply pressure requirements for the accumulator are such that, following a failure of the pneumatic supply to the accumulator, at least two valve actuations capioccur with the drywell at 70% of design pressure (Ref.'Y.,,I. The ECCS safety analysis assumes only one actuation to achieve the depressurization required for operation of the low pressure ECCS.      This minimum required pressure of 140 psig is provided by the Instrument Air System. The 31 day Frequency takes into consideration administrative control over operation of the Instrument Air System and alarms for low air pressure.
With regard to ADS accumulator supply pressure values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.
This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Ref. ;.
SR 3.5.1.4 The performance requirements of the ECCS pumps are determined through application of the 10 CFR 50, Appendix K, criteria (Ref. 8).      This periodic Surveillance is performed (in accordance with the ASME Code, Section XI, requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses.
The ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of 10 CFR 50.46 (Ref. 10).
(continued)
CLINTON                          B 3.5-10                    Revision No. 4-6
 
ECCS--Operating B 3.5.1 BASES SURVEILLANCE SR  3.5.1.4  (continued)
REQUIREMENTS The pump flow rates are verified with a pump differential pressure that is sufficient to overcome the RPV pressure expected during a LOCA. The pump outlet pressure is adequate to overcome the elevation head pressure between the pump suction and the vessel discharge, the piping friction losses, and RPV pressure present during LOCAs.      These values may be established during pre-operational testing.      The Frequency for this Surveillance is in accordance with the Inservice Testing Program requirements.
With regard to pump flow rates and differential pressures values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Refs. 17, +/-8, 19).
SR  3.5.1.5 The ECCS subsystems are required to actuate automatically to perform their design functions. This Surveillance test verifies that, with a required system initiation signal (actual or simulated), the automatic initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as designed, including actuation of the system throughout its emergency operating sequence, automatic pump startup, and actuation of all automatic valves to their required positions. This Surveillance also ensures that the HPCS System will automatically restart on an RPV low water level (Level 2) signal received subsequent to an RPV high water level (Level 8) trip and that the suction is automatically transferred from the RCIC storage tank to the suppression pool. The LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," overlaps this Surveillance to provide complete testing of the assumed safety function.
The 24 month 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 that these components usually pass the SR, which is based on the refueling cycle.
Therefore, the Frequency (continued)
CLINTON                        B 3.5-11                  Revision No. 10-7
 
ECCS---Operating B 3.5.1 BASES SURVEILLANCE SR  3.5.1.5    (continued)
REQUIREMENTS was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
SR 3.5.1.6 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals.
A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,
solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components.      SR 3.5.1.7 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.
The 24 month 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 that these components usually pass the SR, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents an RPV pressure blowdown.
SR  3.5.1.7 A manual actuation of each required ADS valve (those valves removed and replaced to satisfy SR 3.4.4.1) is performed to verify that the valve is functioning properly.      This SR can be demonstrated by one of two methods. If performed by Method 1, plant startup is allowed prior to performing this test because valve OPERABILITY and the setpoints for over.ressure protection are verified, per ASME requirements
[-    (Ref. 1 2'), prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours after reactor steam pressure and flow are adequate to perform the test.      The 12 hours allowed for manual actuation after the required pressure is reached is sufficient to achieve stable (continued)
CLINTON                          B 3.5-12                  Revision No. 10-7
 
ECCS--Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.7    (continued)
REQUIREMENTS Conditions for testing and provides a reasonable time to complete the SR.      If performed by Method 2, valve OPERABILITY has been demonstrated for all installed ADS valves based upon the successful operations of a test sample of S/RVs.
: 1. Manual actuation of the ADS valve, with verification of the response of the turbine control valves or bypass valves, by a change in the measured steam flow, or any other method suitable to verify steam flow (e.g.,
tailpipe temperature or acoustic monitoring).      Adequate reactor steam pressure must be available to perform this test to avoid damaging the valve.      Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the ADS valves divert steam flow upon opening. Sufficient time is therefore allowed after the required pressure and flow are achieved to perform this test. Adequate pressure at which this test is to be performed is consistent with the pressure recommended by the valve manufacturer.
: 2. The sample population of S/RVs tested to satisfy SR 3.4.4.1 will also be stroked in the relief mode during "as-found" testing to verify proper operation of the S/RV. The successful performance of the test sample of S/RVs provides reasonable assurance that all ADS valves will perform in a similar fashion. After the S/RVs are replaced, the relief-mode actuator of the newly-installed S/RVs will be uncoupled from the S/RV stem, and cycled to ensure that no damage has occurred to the S/RV during transportation and installation.      Following cycling, the relief-mode actuator is recoupled and the proper positioning of the stem nut is independently verified. This verifies that each replaced S/RV will properly perform its intended function.
SR 3.5.1.6 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.      The STAGGERED TEST BASIS Frequency ensures that both solenoids for each ADS valve relief-mode actuator are alternately tested.      The Frequency of the required relief-mode actuator testinq is based on the tests required by ASME OM, Part 1, (Ref.VI'y)      as implemented by the Inservice Testing Program of Specification 5.5.6.      The testing Frequency required by the Inservice Testing Program is based on operating experience and valve performance.      Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
CLINTON                          B 3.5-13                    Revision No. 7-2
 
ECCS--Operating B 3.5.1 BASES SURVEILLANCE  SR 3.5.1.8 REQUIREMENTS (continued)
This SR ensures that the ECCS RESPONSE TIMES are within limits for each of the ECCS injection and spray subsystems.
The response time limits (i.e.,  <42 seconds for the LPCI subsystems, <41 seconds for the LPCS subsystem, and <27 seconds for the HPCS system) are specified in applicable surveillance test procedures. This SR is modified by a Note which identifies that the associated ECCS actuation instrumentation is not required to be response time tested.
This is supported by Reference T9 Response time testing of the remaining subsystem components is required. However, of the remaining subsystem components, the time for each ECCS pump to reach rated speed is not directly measured in the response time tests. The time(s) for the ECCS pumps to reach rated speed is bounded, in all cases, by the time(s) for the ECCS injection valve(s) to reach the full-open position. Plant-specific calculations show that all ECCS motor start times at rated voltage are less than two seconds. In addition, these calculations show that under degraded voltage conditions, the time to rated speed is less than five seconds.
ECCS RESPONSE TIME tests are conducted every 24 months.      The 24 month 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 that these components usually pass the SR, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
With regard to ECCS RESPONSE TIME values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. ).1j (continued)
CLINTON                          B 3.5-14                  Revision No. 10-7
 
ECCS--Operating B 3.5.1 BASES REFERENCES                  1. USAR,  Section 6.3.2.2.3.
: 2. USAR,  Section 6.3.2.2.4.
: 3. USAR,  Section 6.3.2.2.1.
: 4. USAR,  Section 6.3.2.2.2.
: 5. USAR,  Section 15.2.8.
: 6. USAR,  Section 15.6.4.
: 7. USAR,  Section 15.6.5.
: 8. 10 CFR 50,  Appendix K.
: 9. USAR,  Section 6.3.3.
: 10. 10 CFR 50.46.
: 11. USAR,  Section 6.3.3.3.
Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
R-ns-e-T-3            (NRC),  "Recommended Interim Revisions to LCO's for ECCS Components," December 1, 1975.
1l4-.I .r    USAR,  Table 6.3-8.
USAR,  Section 7.3.1.1.1.4.
NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing Requirements," January 1994.
Calculation IP-0-0044.
EF-5]        Calculations    01HP09/10/II, IP-C-0042.
Calculations    01LP08/II/14, IP-C-0043.
Calculations 01RH19/20/23/24,    IP-C-0041.
Calculation IP-0-0024.
ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 1.
CLINTON                                      B 3.5-14a                  Revision No. 7-2
 
LLS Valves B 3.6.1.6 BASES APPLICABLE      LLS S/RVs are specified,      all five LLS S/RVs do not operate SAFETY ANALYSES in any DBA analysis.
(continued)
LLS valves satisfy Criterion 3 of the NRC Policy Statement.
LCO            Five LLS valves are required to be OPERABLE to satisfy the assumptions of the safety analysis (Ref. 1) . The requirements of this LCO are applicable to the mechanical and electrical/pneumatic capability of the LLS valves to function for controlling the opening and closing of the S/RVs.
APPLICABILITY  In MODES 1, 2, and 3, an event could cause pressurization of the reactor and opening of S/RVs.        In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.
Therefore, maintaining the LLS valves OPERABLE is not required in MODE 4 or 5.
ACTIONS        A. I With one LLS valve inoperable, the remaining OPERABLE LLS valves are adequate to perform the designed function.
However, the overall reliability is reduced.        The 14 day Completion Time takes into account the redundant capability afforded by the remaining LLS S/RVs and the low probability of an event in which the remaining LLS S/RV capability would be inadequate.
B.      11 if two...      LL ---v.al....      ineperable . r . the          overall inoperable LLS valve cannot be restored to OPERABLE status plantriskis within the required CompletionkTime, the plant must be            minimized.
brought to a MODE in which the LCO does not aply.          To achieve this status, the plant must be brought to at\1/2east MODE 3 within 12 hours and tME)B 4 -ih+/-i 36 hoa.'F The allowed Completion Time$-a-r-' reasonable, based on operating experience, to reach the required plant conditions from full (continued)
CLINTON                              B 3.6-36                      Revision No. 0
 
LLS Valves B 3.6.1.6 BASES ACTIONS      B.1 and B.2      (continued) power conditions in an orderly manner and without
            >achallenging plant systems.
SURVEILLANCE  SR    3.6.1.6.1 REQUIREMENTS A manual actuation of each required LLS valve (those valves removed and replaced to satisfy SR 3.4.4.1) is performed to verify that the valve is functioning properly.      This SR can be demonstrated by one of two methods.      If performed by Method 1, plant startup is allowed prior to performing this test because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements (e.),      prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours after reactor steam pressure and flow are adequate to perform the test.      The 12 hours allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions for testing and provides a reasonable time to complete the SR.      If performed by Method 2, valve OPERABILITY has been demonstrated for all installed LLS valves based upon the successful operation of a test sample of S/RVs.
: 1. Manual actuation of the LLS valve, with verification of the response of the turbine control valves or bypass valves, by a change in the measured steam flow, or any other method suitable to verify steam flow (e.g.,
tailpipe temperature or acoustic monitoring).      Adequate reactor steam pressure must be available to perform this test to avoid damaging the valve. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the LLS valves divert steam flow upon opening.
Sufficient time is therefore allowed after the required pressure and flow are achieved to perform this test.
Adequate pressure at which this test is to be performed is consistent with the pressure recommended by the valve manufacturer.
: 2. The sample population of S/RVs tested to satisfy SR 3.4.4.1 will also be stroked in the relief mode during "as-found" testing to verify proper operation of the S/RV. The successful performance of the test sample of S/RVs provides reasonable assurance that all LLS valves will perform in similar fashion.      After the S/RVs are replaced, the relief-mode actuator of the newly-installed S/RVs will be uncoupled from the S/RV stem, and cycled to ensure that no damage has occurred to the S/RV during transportation and installation.      Following cycling, the relief-mode actuator is recoupled and the (continued)
CLINTON                              B 3.6-37                Revision No. 7-2
 
LLS Valves B 3.6.1.6 BASES SURVEILLANCE      SR  3.6.1.6.1  (continued)
REQUIREMENTS proper positioning of the stem nut is independently verified. This verifies that each replaced S/RV will properly perform its intended function.
The Frequency of the required relief-mode actuator teping is based on the tests required by ASME OM Part 1 (RefYTT),
as implemented by the Inservice Testing Program of Specification 5.5.6. The testing Frequency required by the Inservice Testing Program is based on operating experience and valve performance.      Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.6.1.6.2 The LLS designed S/RVs are required to actuate automatically upon receipt of specific initiation signals.      A system functional test is performed to verify that the mechanical portions (i.e.,    solenoids) of the automatic LLS function operate as designed when initiated either by an actual or simulated automatic initiation signal.      The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.5.4 overlaps this SR to provide complete testing of the safety function.
The 24 month 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. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents a reactor pressure vessel pressure blowdown.
REFERENCES        1. USAR,  Section 5.2.2.2.3.
r__1        ASME/ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 1.
CLINTON                                  B 3.6-38                Revision No. 10-7
 
RHR Containment Spray System B 3.6.1.7 BASES ACTIONS        B.I (continued)
With two RHR containment spray subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours. In this Condition, there is a substantial loss of the drywell bypass leakage mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available.
C. IanC.
If the inoperable RHR containment spray subsystem cannot be overall plant      restored to OPERABLE status within the required Completion risk is            Time, the plaq must be brought to a MODE in which the-bee-minimized          dccs net cpply'    To achieve this status, the plant must be brought to at le.t    MODE 3 within 12 hours and t M8D9    -4
                    *ithin -se hrur-.tThe allowed Completion Timeae reasonable, based on operating. experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE    SR    3.6.1.7.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR containment spray mode flow path provides assurance that the proper flow paths will exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing.      This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The 31 day Frequency of this SR is justified because the valves are operated under procedural control and because improper valve position would affect only a single subsystem. This Frequency has been shown to be acceptable based on operating experience.
(continued)
CLINTON                                B 3.6-41                Revision No. 1-1
 
RHR Containment Spray System B 3.6.1.7 BASES SURVEILLANCE    SR  3.6.1.7.3  (continued)
REQUIREMENTS Therefore, the Frequency was concluded to be acceptable    from a reliability standpoint.
SR  3.6.1.7.4 This Surveillance is performed following activites that could result in nozzle blockage to verify that the spray nozzles are not obstructed and that flow will be provided when required. Such activities may include a loss of foreign material control (of if it cannot be assured),
following a major configuration change, or following an inadvertent actuation of containment spray. This Surveillance is normally performed by an air or smoke flow test. The Frequency is adequate due to the passive nozzle design and its normally dry state and has been shown to be acceptable through operating experience.
REFERENCES      1. USAR,  Section 6.2.1.1.5.
ASME,  Boiler and Pressure Vessel Code, Section XI.
I...3      USAR,  Section 5.4.7 CLINTON                                B 3.6-43              Revision No. 10-7
 
FWLCS B 3.6.1.9 BASES ACTIONS        C. 1an4  C.
(continued)
If the inoperable FWLCS subsystem cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the L-e dees n, overailplantrisk        . To achieve this status, the plant must be brought to is minimized      at least MODE 3 within 12 hours -a- 0* r C    4 Within 36-
                  -d.      The allowed Completion Time-a*evreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE  SR  3.6.1.9.1 REQUIREMENTS A system functional test of each FWLCS subsystem is performed to ensure that each FWLCS subsystem will operate through its operating sequence. This includes verifying automatic positioning of valves and operation of each interlock, and that the necessary check valves open.
Adequacy of the associated RHR pumps to deliver FWLCS flow rates required to meet the assumptions made in the supporting analyses concurrent with other modes was demonstrated during acceptance testing of the system after installation. Periodic verification of the capabilities of the RHR pumps is performed under SR 3.5.1.4.
The 24 month 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.
REFERENCES    1. USAR,  Section 15.6.5.
CLINTON                              B 3.6-47c                Revision No. 10-7
 
RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS        B.1 -ftf4-B-n2                                          F&#xfd;yerall
                                                                        -plant    (isk is minimized (continued)
If the Required Action and required Completion Time of Condition A cannot be met or if t-w RiA siupprersion pool eooling subsystems a7    inpI        the plant must be brought to a MODE in which tht                            To achieve this status, the plant must be brought to at.east        MODE 3 within 12 hours andtJ 0- ?fRP 4 withi-n .;4,Aho      "The allowed C-&#xfd;-4ompletion Time$ aae--reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE  SR    3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves, in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation.      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 being locked, sealed, or secured.
A valve is also allowed to be in the nonaccident position, provided it can be aligned to the accident position within the time assumed in the accident analysis.        This is acceptable, since the RHR suppression pool cooling mode is manually initiated.      This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.      This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the subsystem is a manually initiated system.        This Frequency has been shown to be acceptable, based on operating experience.
(continued)
CLINTON                                B 3.6-58                    Revision No. 0
 
RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE      SR    3.6.2.3.2 REQUIREMENTS (contin ied)    Verifying each RHR pump develops a flow rate &#x17d; 4550 gpm, with flow through the associated heat exchanger to the suppression pool, ensures that pump performance has not degraded during the cycle.      Flow is a normal test of centi fugal pump performance required by ASME Section XI (Ref. Y). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance.        The Frequency of this SR is in accordance with the Inservice Testing Program.
With regard to RHR pump flow rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value with respect to instrument uncertainties.      This requires additional margin to be added to the limit to compensate for instrument uncertainties for implementation in the          rF associated plant procedures.      (RefT      4)C.          M REFERENCES        1.      USAR,  Section 6.2.
ASME,  Boiler and Pressure Vessel Code,    Section XI.
                    *Z-  USAR, Section 5.4.7.
9Il.      Calculations 01RH20/25 and IP-C-0041.
CLINTON                                  B 3.6-S9                  Revision No. 6-4
 
Secondary Containment B 3.6.4.1 BASES ACTIONS A.1  (continued) containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.              overall plant risk is minimized.
B. 1 aen.-B --
If the secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plantmust be brought to a MODE in which the            does nut apply..COTo achieve MODE    this status, 3 within 12 hourstheaq4plant must 4 be#o4!t-h4:n
                                      #R MOS          brought    to at least 35hur.Thfe---          -s-ti allowed Completion Time&-ar-- 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.1 and C.2 Movement of recently irradiated fuel assemblies in the primary or secondary containment and OPDRVs can be postulated to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environment. Movement of recently irradiated fuel assemblies must be immediately suspended if the secondary containment is inoperable.
Suspension of these activities    shall not preclude completing an action that involves moving a component to a safe position. Also, action must be immediately initiated            to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.
Required Action C.1 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 (continued)
CLINTON                      B 3.6-86                        Revision No. 11-4
 
Secondary Containment B 3.6.4.1 BASES ACTIONS      C.1 and C.2    (continued) movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
SURVEILLANCE SR  3.6.4.1.1 REQUIREMENTS This SR ensures that the secondary containment boundary is sufficiently leak tight to preclude exfiltration under expected wind conditions. The 24 hour Frequency of this SR was developed based on operating experience related to secondary containment vacuum variations during the applicable MODES and the low probability of a DBA occurring between surveillances.
Furthermore, the 24 hour Frequency is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal secondary containment vacuum condition.
With regard to secondary containment vacuum values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require conpensation for instrument indication uncertainties (Ref. A).
a SR  3.6.4.1.2 and SR    3.6.4.1.3 Verifying that secondary containment equipment hatches and access doors are closed ensures that the infiltration of outside air of such a magnitude as to prevent maintaining the desired negative pressure does not occur. Verifying that all such openings are closed provides adequate assurance that exfiltration from the secondary containment will not occur. In this application the term "sealed" has no connotation of leak tightness. Maintaining secondary containment OPERABILITY requires verifying one door in the access opening is closed, except when the access opening is being used for entry and exit. The 31 day Frequency for these SRs has been shown to be adequate based on operating experience, and is considered adequate in view of the other controls on secondary containment access openings.
(continued)
CLINTON                            B 3.6-87              Revision No. 7-3
 
Secondary Containment B 3.6.4.1 BASES SURVEILLANCE        SR  3.6.4.1.4 and SR    3.6.4.1.5 REQUIREMENTS (continued)        The SGT System exhausts the secondary containment atmosphere to the environment through appropriate treatment equipment.
Each SGT subsystem is designed to draw down pressure in the secondary containment to > 0.25 inches vacuum water gauge within the time required and maintain pressure in the secondary containment at > 0.25 inches of vacuum water gauge for 1 hour at a flow rate of < 4400 cfm.      To ensure that all fission products released to the secondary containment are treated, SR 3.6.4.1.4 and SR 3.6.4.1.5 verify that a pressure in the secondary containment that is less than the lowest postulated pressure external to the secondary containment boundary can rapidly be established and maintained. When the SGT System is operating as designed, the establishment and maintenance of secondary containment pressure cannot be accomplished if the secondary containment boundary is not intact. Establishment of this pressure is confirmed by SR 3.6.4.1.4, which demonstrates that secondary containment can be drawn down to > 0.25 inches of vacuum water gauge in the required time using one SGT subsystem.
Specifically, the required drawdown time limit is based on ensuring that the SGT system will draw down the secondary containment pressure to &#x17d; 0.25 inches of vacuum water gauge within 12 minutes (i.e.,    10 minutes from start  of gap release which occurs 2 minutes after LOCA initiation)      under LOCA conditions. Typically, however, the conditions under which drawdown testing is performed pursuant to SR 3.6.4.1.4 are different than those assumed for LOCA conditions.        For this reason, and because test results are dependent on or influenced by certain plant and/or atmospheric conditions that may be in effect at the time testing is performed, it is necessary to adjust the test acceptance criteria      (i.e.,
the required drawdown time) to account for such test conditions. Conditions or factors that may impact the test results include wind speed, whether the turbine building ventilation system is running, and whether the containment equipment hatch is open (when the test is performed during plant shutdown/outage conditions). The acceptance criteria for the drawdown test    are thus based on a computer model
[ReTFT.TY/K),            verified by actual performance of drawdown tests, in which the drawdown time determined for accident conditions is adjusted to account for performance of the test during normal but certain plant conditions.        The test acceptance criteria  are specified in the applicable plant test procedure(s). Since the drawdown time is dependent upon secondary containment integrity, the drawdown requirement cannot be met if the secondary containment boundary is not intact.
SR 3.6.4.1.5 demonstrates that the pressure in the secondary containment can be maintained > 0.25 inches of vacuum water gauge for 1 hour using one SGT subsystem at a flow rate of
                    < 4400 cfm. The 1 hour test period allows secondary containment to be in thermal equilibrium at steady state (continued)
CLINTON                                    B 3.6-88                Revision No. 11-4
 
Secondary Containment B 3.6.4.1 BASES SURVEILLANCE  SR    3.6.4.1.4 and SR    3.6.4.1.5 (continued)
REQUIREMENTS conditions. The primary purpose of these SRs is to ensure secondary containment boundary integrity.      The secondary purpose of these SRs is to ensure that the SGT subsystem being tested functions as designed.      There is a separate LCO with Surveillance Requirements which serves the primary purpose for ensuring OPERABILITY of the SGT System.      These SRs need not be performed with each SGT subsystem.      The SGT subsystem used for these Surveillances is staggered to ensure that in addition to the requirements of LCO 3.6.4.3, either SGT subsystem will perform this test.      The inoperability of the SGT System does not necessarily constitute a failure of these Surveillances relative to the secondary containment OPERABILITY.      Operating experience has shown these components usually pass the Surveillance.
Therefore, the Frequency was concluded to be acceptable from a reliability    standpoint.
With regard to drawdown time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Refs. -4,5).
REFERENCES    1. USAR,  Section 15.6.5.
: 2. USAR,  Section 15.7.4.
Calculation IP-0-0082.
Calculation IP-0-0083.
2-T.. Calculation IP-0-0084.
MX*. Calculation 3C10-1079-001.
CLINTON                              B 3.6-88a                Revision No. 11-4
 
SGT System B 3.6.4.3 BASES APPLICABILITY  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 OPERABLE 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 operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies (i.e.,    fuel that has occupied part of a critical reactor core within the previous 24 hours) in the primary or secondary containment.
ACTIONS        A.1 With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 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 subsystem and the low probability of a DBA occurring during this period.
B. 1and    B.2 If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the overall plant plant must be brought to a MODE in which the Lee --        et riskis        a--p-ly-. To achieve this status, the plant must be brought to minimized. at least ODE 3 within 12 hours and t- M5E 4 %itkin allowed Completion Time-      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.1,    C.2.1 and C.2.2 During movement of recently irradiated fuel assemblies in the primary or secondary containment or during OPDRVs, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should be immediately placed in operation. This Required Action ensures that the remaining subsystem is OPERABLE, (continued)
CLINTON                                B 3.6-98                Revision No. 7-3
 
SGT System B 3.6.4.3 BASES ACTIONS C.1,    C.2.1 and C.2.2  (continued) that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.
An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the unit in a Condition that minimizes risk. If applicable, movement of recently irradiated fuel assemblies must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. This action should be chosen if the OPDRVs could be impacted by a loss of offsite power. Action must continue until OPDRVs are suspended.
The Required Actions of Condition C have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving 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.
D..
If.both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT System may not be capable of supporting the required radioactivity release control function. Thercfcrc, LCO S.0. 3  RI-tp be en e e      LI~.....l.LaL.-ly
                                  .LL~
                                    ..                7 E.1 and E.2 When two SGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in the primary and secondary containment must be immediately suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe (continued)
CLINTON                          B 3.6-99                Revision No. 7-3
 
SGT System B3.6.4.3 BASES ACTIONS      E.1 and E.2    (continued) position. Also, if applicable, actions must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until OPDRVs are suspended.
SURVEILLANCE SR  3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem from the main control room for
            > 10 continuous hours 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. Operation with the heaters on (automatic heater cycling to maintain temperature) for &#x17d; 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.
With regard to operating time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref./3.
SR  3.6.4.3.2 This SR verifies that the required SGT filter    testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing HEPA filter performance, charcoal adsorber bypass leakage and efficiency, minimum system flow rate, combined HEPA filter and charcoal adsorber pressure drop, and heater dissipation.
The frequencies for performing the SGT System filter      tests are in accordance with Regulatory Guide 1.52 (Ref. 4) and include testing initially,    after 720 hours of system operation, once per 24 months, and following painting, fire, or chemical release in any ventilation zone communicating with the system. The laboratory test results will be (continued)
CLINTON                            B 3.6-100              Revision No. 10-7
 
SGT System B 3.6.4.3 BASES SURVEILLANCE SR  3.6.4.3.2  (continued)
REQUIREMENTS verified to be within limits within 31 days of removal of the sample from the system. Additional information is discussed in detail in the VFTP.
With regard to filter    testing values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref.    ).
SR  3.6.4.3.3 This SR requires verification that each SGT subsystem automatically starts upon receipt of an actual or simulated initiation signal.
The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.2.5 overlaps this SR to provide complete testing of the safety function.
While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.6.4.3.4 This SR requires verification that the SGT filter    cooling bypass damper can be opened and the fan started.      This ensures that the ventilation mode of SGT System operation is available. While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
CLINTON                            B 3.6-101              Revision No. 10-7
 
SGT System B 3.6.4.3 BASES REFERENCES 1. 10 CFR 50, Appendix A,  GDC 41.
: 2. USAR, Section  6.2.3.
: 3. USAR, Section  15.6.5.
: 4. Regulatory Guide 1.52.
: 5. USAR, Section  6.5.1.
: 6. USAR, Section    15.6.4.
: 7. USAR Appendix A.
B. ASME/ANSI N510-1980.
Calculation IP-0-0086.
Calculation 12-0-0087.
CLINTON                    B 3.6-101a        Revision No. 4-6
 
Drywell Post-LOCA Vacuum Relief System B 3.6.5.6 BASES ACTIONS A.1 (continued)
A Note has been added to provide clarification that separate Condition entry is allowed for each vacuum relief subsystem not closed.
B.1 With one drywell post-LOCA vacuum relief subsystem inoperable for reasons other than Condition A, the inoperable subsystem must be restored to OPERABLE status within 30 days. In these Conditions, the remaining OPERABLE vacuum relief subsystems are adequate to perform the depressurization mitigation function since three 10-inch lines remain available. The 30 day Completion Time takes into account the redundant capability afforded by the remaining subsystems, a reasonable time for repairs, and the low probability of an event requiring the vacuum relief subsystems to function occurring during this period.
C.1 With two or more drywell post-LOCA vacuum relief subsystems inoperable for reasons other than Condition A, the inoperable subsystems must be restored to OPERABLE status within 72 hours. The 72 hour Completion Time takes into account a reasonable time for repairs, and the low probability of an event requiring the vacuum relief subsystems to function occurring during this period.
D.1 and D.2 If  the inoperable drywell post-LOCA vacuum relief subsystem(s)  cannot be closed or rested to      EPRABLE sLtaus within the required Completion Time, 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 (continued)
CLINTON                      B 3.6-130                Revision No. 7-5
 
Drywell Post-LOCA Vacuum Relief System B 3.6.5.6 BASES ACTIONS      D.l and D.2 (continued) experience, to reach the required plant conditions from full power conditions in an orderly manner and without
            ,challenging plant systems.
SURVEILLANCE  SR  3.6.5.6.1 REQUIREMENTS Each drywell post-LOCA vacuum relief valve is verified to be closed (except when being tested in accordance with SR 3.6.5.6.2 and SR 3.6.5.6.3 or when the drywell post-LOCA vacuum relief valves are performing their intended design function) to ensure that this potential large drywell bypass leakage path is not present. This Surveillance is normally performed by observing the drywell post-LOCA vacuum relief valve position indication. The 7 day Frequency is based on engineering judgment, is considered adequate in view of other indications of drywell post-LOCA vacuum relief valve status available to the plant personnel, and has been shown to be acceptable through operating experience.
Two Notes are added to this SR. The first  Note allows drywell post-LOCA vacuum relief valves opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening drywell post-LOCA vacuum relief valves are controlled by plant procedures and do not represent inoperable drywell post-LOCA vacuum relief valves. A second Note is included to clarify that valves open due to an actual differential pressure, are not considered as failing this SR.
SR 3.6.5.6.2 Each drywell post-LOCA vacuum relief valve must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position. This provides assurance that the safety analysis assumptions are valid. A 31 day Frequency was chosen to provide additional assurance that the drywell post-LOCA vacuum relief valves are OPERABLE.
(continued)
CLINTON                          B 3.6-131                Revision No. 1-1
 
Drywell Post-LOCA Vacuum Relief System B 3.6.5.6 BASES SURVEILLANCE  SR  3.6.5.6.3 REQUIREMENTS (continued) Verification of the drywell post-LOCA vacuum relief valve opening differential pressure is necessary to ensure that the safety analysis assumptions of < 0.2 psid for drywell vacuum relief are valid. The safety analysis assumes that the drywell post-LOCA vacuum relief valves will start opening when the dry well pressure is approximately 0.2 psid less than the containment and will be fully open when this differential pressure is 0.5 psid. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for violating the drywell boundary. Operating experience has shown these components usually pass the Surveillance, which is based on the refueling cycle.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES    1. USAR,  Section 6.2.      F CLINTON                            B 3.6-132                Revision No. 10-7
 
Division 1 and 2 SX Subsystems and UHS B 3.7.1 BASES  (continued)
ACTIONS            A.1 If the UHS is inoperable (i.e., the UHS water volume is not within the limit), action must be taken to restore the inoperable UHS to OPERABLE status within 90 days. The 90 day Completion Time is reasonable considering the time required to restore the required UHS volume, the margin contained in the available heat removal capacity, and the low probability of a DBA occurring during this period.
B.1 If the Division 1 or 2 SX subsystem is inoperable, it must be restored to OPERABLE status within 72 hours. With the unit in this condition, the remaining OPERABLE Division 1 or 2 SX subsystem is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE Division 1 or 2 SX subsystem could result in loss of the SX function. The 72 hour Completion Time was developed taking into account the redundant capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
The Required Action is modified by two Notes indicating that the applicable Conditions of LCO 3.8.1, "AC Sources-Operating," and LCO 3.4.9, "Residual Heat Removal (RHR)
Shutdown Cooling System-Hot Shutdown," be entered and the Required Actions taken if the inoperable SX subsystem results in an inoperable DG or RHR shutdown cooling subsystem, respectively. This is in accordance with LCO 3.0.6 and ensures the proper actions are taken for these components.
Z. 1 and Z. 2 If the Required Action and associated Completion Time of Condition A or B are not met, or both Division 1 and 2 SX subsystems are inoperable, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours (continued)
CLINTON                                B 3.7-4                      Revision No. 0
 
Division 1 and 2 SX Subsystems and UHS B 3.7.1 BASES ACTIONS              o        .  (continued)
A andD.2 and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE        SR  3.7.1.1 REQUIREMENTS This SR verifies UHS water volume is &#x17d; 593 acre-feet (excluding sediment). The Surveillance Frequency is in accordance with UHS Erosion, Sediment Monitoring and Dredging Program.
With regard to UHS water volume values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. A).
SR  3.7.1.2 Verifying the correct alignment for each manual, power operated, and automatic valve in each Division 1 and 2 SX subsystem flow path provides assurance that the proper flow paths will exist for Division 1 and 2 SX subsystem operation. 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 is also allowed to be in the nonaccident position and yet considered in the correct position, provided it can be automatically realigned to its accident position within the required time.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be
                  .inadvertently misaligned, such as check valves.
(continued)
CLINTON                                B 3.7-S                    Revision No. 4-6
 
Division 1 and 2 SX Subsystems and UHS B 3.7.1 BASES SURVEILLANCE  SR  3.7.1.2    (continued)
REQUIREMENTS Isolation of the SX subsystem to components or systems does not necessarily affect the OPERABILITY of the associated SX subsystem. As such, when all SX pumps, valves, and piping are OPERABLE, but a branch connection off the main header is isolated, the associated SX subsystem needs to be evaluated to determine if it is still  OPERABLE. Alternatively, it is acceptable and conservative to declare an SX subsystem inoperable when a branch connection is isolated or a supported ventilation system is inoperable.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR  3.7.1.3 This SR verifies that the automatic isolation valves of the Division 1 and 2 SX subsystems will automatically switch to the safety or emergency position to provide cooling water exclusively to the safety related equipment during an accident event. This is demonstrated by use of an actual or simulated initiation signal and is performed with the plant shut down. This SR also verifies the automatic start capability of the SX pump in each subsystem.
Operating experience has shown that these components usually pass the SR. Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.
REFERENCES    1. Regulatory Guide 1.27,  Revision 2,  January 1976.
: 2. USAR,  Section 9.2.1.2.
: 3. USAR,  Table 9.2-3.
: 4. USAR,  Section 6.2.1.1.3.3.
: 5. USAR,  Chapter 15.
: 6. USAR,  Section 6.2.2.3.
: 7. USAR,  Table 6.2-2.
MCI . Calculation IP-0-0095.
CLINTON                          B 3.7-6                    Revision No. 10-7
 
Control Room Ventilation System B 3.7.3 BASES  (continued)
APPLICABILITY      In MODES 1, 2, and 3, the Control Room Ventilation System must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA, since the DBA could lead to a fission product release.
In MODES 4 and 5, the probability and consequences of a DBA are reduced due to the pressure and temperature limitations in these MODES.      Therefore, maintaining the Control Room Ventilation System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
: a.      During operations with a potential for draining the reactor vessel (OPDRVs);
: b.      During CORE ALTERATIONS;  and
: c.      During movement of irradiated fuel assemblies in    the primary or secondary containment.
ACTIONS            A.1 With one Control Room Ventilation subsystem inoperable for reasons other than an inoperable CRE boundary,        the inoperable Control Room Ventilation subsystem must be restored to OPERABLE status within 7 days.        With the unit in this condition, the remaining OPERABLE Control Room Ventilation subsystem is adequate to perform the CRE occupant protection function.        However, the overall reliability    is reduced because a failure in the OPERABLE subsystem could result in loss of Control Room Ventilation System function.      The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.
S.1,    B.2, FH6  3  ICAC.2, andC~j If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals and smoke, the CRE boundary is inoperable.      Actions must be taken to restore an OPERABLE CRE boundary within 90 days.
During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating (continued)
CLINTON                                  B 3.7-13                    Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES 0C.1, C.2, and C.3 ACTIONS B.1, B.2, and 9.3            (continued) actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke.              Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke.                These mitigating actions (i.e,            actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.
The 24 hour Completion Time is reasonable based on the low probability of a DBA during this time period, and the use of mitigating actions.              The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability the CRE occupants will have to implement protective measures that may adversely affect their ability              to control the reactor and maintain it in a safe shutdown condition in the event of a DBA.        In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test      most problems with the CRE boundary.
0D.1 and D.2I In    MODE 1, 2,      or 3,  if  the +/-oJe!a b    C.. 'oLol.ooU Ve1tLil.ti~o        subs y stcm or CRE boundary cannot be restored      to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk.
To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours.                The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
CLINTON                            B 3.7-14                      Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES JE.1, E.2.1, E.2.2, and E.2.3 ACTIONS    L.  ,-  JJ.L.i,  D.:*      and D.2.3 (continued)
The Required Actions of Condition X are modified by a Note indicating that LCO 3.0.3 does not apply.              If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.
Therefore, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.
During movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable Control Room Ventilation subsystem cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE Control Room Ventilation subsystem may be placed in the high radiation mode.              This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.
An alternative to Required Action              .l is to immediately suspend activities            that present a potential for releasing radioactivity that might require the Control Room Ventilation subsystem to be in the high radiation mode of operation.        This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the primary and secondary containment must be suspended immediately.            Suspension of these activities        shall not preclude completion of movement of a component to a safe position.            Also, if applicable, actions must be initiated          immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.              Actions must continue until the OPDRVs are suspended.
(continued)
CLINTON                              B 3.7-15                    Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES ACTIONS          .
(continued)
If both Control Room Ventilation subsystems are inoperable in MODE 1, 2, or 3 for r( sons other than an inoperable CRE boundary (i.e.,        Condition %), the Control Room Ventilation System may not be capable of performing the intended function and the unit is in a condition outside of the accident analyses.          T    fo  ee, L    3C 2.0.3  s b. entre JG.1, G.2, and G.3 12.1,    12.2, and F2.3 During movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two Control Room Ventilation subsystems inoperable or with one or more Control Room Ventilation subsystems inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities            that present a potential for releasing radioactivity that might require treatment of the control room air.            This places the unit in a condition that minimizes the accident risk.
If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in the primary and secondary containment must be suspended immediately.            Suspension of these activities        shall not preclude completion of movement of a component to a safe position.          If applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.          Actions must continue until the OPDRVs are suspended.
SURVEILLANCE  SR    3.7.3.1 and SR      3.7.3.2 REQUIREMENTS This SR verifies that a subsystem in a standby mode starts on demand and continues to operate.            Standby systems should be checked periodically to ensure that they start            and function properly.          As the environmental and normal operating conditions of this system are not severe, testing each subsystem once every month provides an adequate check on this system.          Monthly heater operation dries out any moisture accumulated in the charcoal from humidity in the ambient air.          The Makeup Filter System must be operated from the main control room for &#x17d; 10 continuous hours with the heaters energized.          The Recirculation Filter  System (without heaters) need only be operated for &#x17d; 15 minutes to demonstrate the function of the system.            Furthermore, the 31 day Frequency is based on the known reliability            of the equipment and the two subsystem redundancy available.
(continued)
CLINTON                                B 3.7-16                    Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES SURVEILLANCE SR    3.7.3.1 and SR      3.7.3.2  (continued)
REQUIREMENTS With regard to subsystem operation time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref.-9---8-.
8,9-SR    3.7.3.3 This SR verifies that the required Control Room Ventilation System testing is performed in accordance with the Ventilation Filter Testing Program (VFTP) . The VFTP includes testing HEPA filter        performance, charcoal adsorber bypass leakage and efficiency, minimum system flow rate (scfm), combined HEPA filter      and charcoal adsorber pressure drop, and heatedissipation          in accordance with Regulatory Guide 1.52 (ref.1&#xfd;4).        The Frequencies for performing the Control Room Ventilation System filter        tests are also in accordance with Regulatory Guide 1.52 (RefY7).          Specific      [ii test  frequencies and additional information are discussed in detail in the VFTP.
SR    3.7.3.4 This SR verifies that each Control Room Ventilation subsystem starts      and operates on an actual or simulated high radiation initiation        signal. While this Surveillance can be performed with the reactor at power, operating experience has shown these components usually pass the Surveillance, which is based on the refueling cycle.          Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
(continued)
CLINTON                          B 3.7-16a                    Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES SURVEILLANCE            SR  3.7.3.5 REQUIREMENTS (continued)          This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air    inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room envelope Habitability Program.
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.
This SR verifies that the unfiltered air    inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.      When unfiltered air ,ipleakage is greater than the assumqd flow rate, Conditionv, must be entered.      Reguired Action          I.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the ioccupants                    following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref.
                        &#xfd;4) which endorses, with exceptions, NEI 99-03, Section 8.4 1121 and Appendix F (Ref .      ) . These compensatory measures may also Igeused as mitigating actions as required by Required M      Action V.2. Temporary analytical methods may also bVsed as compensatory measures to restore OPERABILITY (Ref. -T).
Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test      may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
(continued)
CLINTON                                    B 3.7-16b                  Revision No. 12-1
 
Control Room Ventilation System B 3.7.3 BASES  (continued)
REFERENCES        1. USAR,  Section 6.5.1.
: 2. USAR,  Section 9.4.1.
: 3. USAR,  Chapter 6.
: 4. USAR,  Chapter 15.
: 5. USAR,  Section 6.4.
: 6. USAR, Section 9.5.
Calculation IP-O-0096.
Calculation IP-O-0097.
Guide 1.52, Revision 2,  March 1978.
L---- -
          --          "r Regulatory Regulatory Guide 1.196.
Esh-*
NEI 99-03,  "Control Room Habitability Assessment,"
June 2001.
Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 10, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."    (ADAMS Accession No. ML040300694).
CLINTON                              B 3.7-16c                  Revision No. 12-1
 
Control Room AC System B 3.7.4 BASES  (continued)
ACTIONS            A.1 With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE control room AC subsystem is adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring Control Room Ventilation System operation in the high radiation mode, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate cooling methods.
B.l and B.2 If both control room AC subsystems are inoperable, the Control Room AC System may not be capable of performing its intended function. Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected.      With the control room temperature being maintained within the temperature limit, 7 days is allowed to restore a control room AC subsystem to OPERABLE status.      This Completion Time is reasonable considering that the control room temperature is being maintained within limits, the low probability of an event occurring requiring control room isolation, and the availability of alternate cooling methods.
C. 1 -Ca.4-4---
In MODE 1, 2, or 3, if the control room area temperature      loverall plani cannot be maintained
* 86 0 F or if the inoperable control room AC subsystem cannot be restored to OPERABLE status within the associated CompletionTime, the unit must be placed in a MODE that minimizes'risk.      To achieve this status the unit must be placed in at lEapt MODE 3 within 12 hours and. in M8-R*-      n -36 hours.' The allowed Completion TimeX-ere- reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
CLINTON                                B 3.7-19                      Revision No. 0
 
Control Room AC System B 3.7.4 BASES ACTIONS        E.l,  E.2,  and E.3    (continued)
During movement of irradiated fuel assemblies in the primary or secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the Required Action and associated Completion Time of Condition B is not met, action must be taken to immediately suspend activities that present a potential for releasing radioactivity that might require operation of the Control Room Ventilation System in the high radiation mode.
This places the unit in a condition that minimizes risk.
If applicable, CORE ALTERATIONS and handling of irradiated fuel in the primary and secondary containment must be suspended immediately.        Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
SURVEILLANCE  SR  3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analysis.        The SR consists of a combination of testing and calculation.        The 24 month Frequency is appropriate since significant degradation of the Control Room AC System is not expected over this time period.
With regard to heat removal capability values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref.;).
REFERENCES    1. USAR,  Section 6.4.
: 2. USAR,  Section 9.4.1.
M]/. Calculation IP-O-0102.
CLINTON                            B 3 .7-21                    Revision No. 10-7
 
Main Condenser Offgas B 3.7.5 BASES  (continued)
APPLICABILITY      The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System. This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation. In MODES 4 and 5, steam is not being exhausted to the main condenser and the requirements are not applicable.
ACTIONS            A.1 If the offgas radioactivity rate limit is exceeded, 72 hours is allowed to restore the gross gamma activity rate to within the limit. The 72 hour Completion Time is reasonable, based on engineering judgment considering the time required to complete the Required Action, the large margins associated with permissible dose and exposure limits, and the low probability of a Main Condenser Offgas System rupture occurring.
B.1, B.2,  B. .1,  nd  .3.2 If the radioactivity rate is not restored to within the limits within the associated Completion Time, all main steam lines or the SJAE must be isolated. This isolates the Main Condenser Offgas System from the source of the radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed, and at least one main steam line drain valve in each drain line is closed. The 12 hour Completion Time is reasonable, based on operating experience, to perform the actions from full power conditions in an orderly manner and without challenging unit systems.                      overaiiplant risk lis minimized. I An alternative to Required Actions B.. and B.2 is t place the unit in a MODE in which the L-O da    +/-u  dwply.-To (continued)
CLINTON                              B 3.7-23                      Revision No.      0
 
Main Condenser Offgas B 3.7.5 BASES ACTIONS      B.1,  B.2, B.3.1,  and B.3.2  (continued) achieve this status, the unit must be placed in at 1 aet MODE 3 within 12 hours -      i PIDE 4 within 36 hours.      The allowed Completion Timet-afe- reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE SR  3.7.5.1 and SR  3.7.5.2 REQUIREMENTS SR 3.7.5.2, on a 31 day Frequency, requires an isotopic analysis of an offgas sample to ensure that the required limits are satisfied. The noble gases to be sampled arE--
Xe-133, Xe-135, Xe-138, Kr-85m, Kr-87, and Kr-88 (Ref. A).
If the measured release rate of radioactivity increases significantly (by &#x17d; 50% after correcting for expected increases due to changes in THERMAL POWER), an isotopic analysis is also performed within 4 hours after the increase is noted, as required by SR 3.7.5.1, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The required isotopic analysis is intended to support determination of the cause for the increase in offgas radiation release rates, such as the onset of leakage from a fuel pin(s).      However, there are certain evolutions (e.g., swapping of the steam jet air ejectors and regeneration of the offgas system desiccant dryers) which are known to result in a predictable and temporary increase in the indicated offgas radioactivity release rate. These indicated increases in offgas radioactivity release rates can be caused solely by increases in offgas flow. Since these increases are due to an evolution(s) known to cause such an increase and not due to an actual increase in the "nominal steady state fission gas release rate," isotopic analysis of an offgas sample is not required for these evolutions.      In any of these cases, it is prudent to ensure that the offgas radiation level (radioactivity release rate) returns to previous or expected levels within four hours or as soon as possible following the evolution. This will confirm that there are no other causes for the increase in the radioactivity release rate indication. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas, and is acceptable based on operating experience.
(continued)
CLINTON                        B 3.7-24                      Revision No. 1-1
 
Main Condenser Offgas B 3.7.5 BASES SURVEILLANCE    SR  3.7.5.1 and SR  3.7.5.2 (continued)
REQUIREMENTS SR 3.7.5.2 is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.
Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.
With regard to radioactivity rate values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref., .Z REFERENCES      1. USAR, Section 15.7.1.
: 2. NUREG-0800.
: 3. 10 CFR 100.
FDA'. NEDE-24810,  "Station Nuclear Engineering,"  Volume 1A.
j],0. Calculation IP-0-0103.
CLINTON                          B 3.7-24a                    Revision No. 4-6
 
AC Sources--Operating B 3.8.1 BASES ACTIONS E.1    (continued)
According to Regulatory Guide 1.93 (Ref. 6), with both DGs inoperable, operation may continue for a period that should not exceed 2 hours.      This Completion Time assumes complete loss of onsite (DG) AC capability to power the minimum loads needed to respond to analyzed events.        In the event Division 3 DG in conjunction with Division I or 2 DG is inoperable, with Division 1 or 2 remaining, a significant spectrum of breaks would be capable of being responded to with onsite power.      Even the worst case event would be mitigated to some extent-an extent greater than a typical two division design in which this condition represents complete loss of onsite power function.        Given the remaining function, a 24 hour Completion Time is appropriate.          At the end of this 24 hour period, Division 3 systems could be declared inoperable (see Applicability Note) and this Condition could be exited with only one required DG remaining inoperable.      However, with a Division 1 or 2 DG remaining inoperable and the HPCS declared inoperable, a redundant required feature failure exists, according to Required Action B.2.
F. 1 .      .-                                            overall plant risk is minimized.
If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the -teE-does not apply.      To achieve this status, the unit must be brought t&#xfd;sMODE 3 within 12 hours and te MODE 4 within
        -- T    m. The allowed Completion Timeg-a-e-'4teasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
G.1 Condition G corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function.      Therefore, no additional time is justified for continued operation.      The unit is required by LCO 3.0.3 to commence a controlled shutdown.
(continued)
CLINTON                      B 3.8-12                      Revision No.      0
 
AC Sources--Operating B 3.8.1 BASES    (continued)
SURVEIL LANCE        The AC sources are designed to permit inspection and REQUIRE MENTS        testing of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, GDC 18 (Ref. /) . Periodic component tests are supplemented by extensive functional tests during refueling outages under simulated accident conditions. The SRs for demonstrating the OPERABILITY of the DGs are in accordance 1    wit the recommendations of Regulatoy Guide 1.9 (Refs. 3 an      , Regulaty Guide 1.108 (Ref.,), and Regulatory            []
lGuide              1.137 (Ref.kl:&#xfd;) .
Where the SRs discussed herein specify voltage and frequency tolerances, the minimum and maximum steady state output voltages of 4084 V and 4580 V respectively, are equal to
                    - 2% and + 10% of the nominal 4160 V output voltage.      The specified minimum and maximum frequencies of the DG is 58.8 Hz and 61.2 Hz, respectively, are equal to +/- 2% of the 60 Hz nominal frequency. The specified steady state voltage and frequency ranges are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3). However, the minimum voltage was increased to ensure adequate voltage to 15 operate all safety-related loads during a DBA (Ref.
In general, surveillances performed for each of the required DGs are similar, with one notable difference due to the fact that the Division 3 DG utilizes a mechanical governor, while the Division 1 and 2 DGs utilize an electronic governor.        As such, the Division 1 and 2 DGs are capable of operating in both an isochronous mode as well as a "droop" mode for when the DGs are paralleled to the offsite source during testing.
The Division 3 DG, on the other hand, is capable of operating only in the droop mode (through a droop setting of zero can be utilized). This difference may affect the Division 3 DGs capability to achieve rated frequency following automatic switchover from the test mode to ready-to-load operation upon receipt of a LOCA initiation signal (as verified per SR 3.8.1.17).
(continued)
CLINTON                                B 3.8-13                    Revision No. 4-3
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.2 and SR 3.8.1.7      (continued)
REQUIREMENTS The normal 31 day Frequency for SR 3.8.1.2 (see Table 3.8.1-1, "Diesel Generator Test Schedule") is consisten  with the industry guidelines for assessment of diesel generator performance (Ref.'521.      The 184 day Frequency for SR 3.8.1.7 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7).        These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
With regard to required voltage and frequency values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.
This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Refs. +/-6, 17, 18, 21, 117,18,19, 22, 23 SR 3.8.1.3 This Surveillance demonstrates that the DGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads.          However, consistent with tJe recommendations of Regulatory Guide 1.9, Revision 3 (Ref.'.l-5"), this surveillance is performed with a DG load equal to or greater than 90 percent of its continuous rating.      A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is an operational limitation to ensure circulating currents are minimized.
The normal 31 day Frequency for this Surveillance (see Table 3.8.1-1) is consistent with the industry guidelines for assessment of diesel generator performance (Ref.Ti-.2).
(continued)
CLINTON                          B 3.8-14                    Revision No.      4-6
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR 3.8.1.3  (continued)
REQUIREMENTS Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.
Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test.
Note 3 indicates that this Surveillance shall be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.
Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DO start must precede this test to credit satisfactory performance.
With regard to DG loading values obtained'pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require copensation for instrument indication uncertainties (Ref.ll    .
SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank is at or above the low level alarm setpoint.
The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour of DG operation at maximum expected post LOCA loads.
The 31 day Frequency is adequate to assure that a sufficient supply of fuel oil is available, since low level alarms are provided and facility operators would be aware of any large uses of fuel oil during this period.
With regard to fuel oil level values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require coqpensation for instrument indication uncertainties (Ref.                r).V (continued)
CLINTON                        B 3.8-1S                  Revision No. 7-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE    SR 3.8.1.5 REQUIREMENTS (conLtinued) Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day tanks once every 31 days eliminates the necessary environment for bacterial survival. This is an effective means of controlling microbiological fouling.      In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, contaminated fuel oil, and breakdown of the fuel oil by bacteria.
Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance SFrequ ecy is established by Regulatory Guide 1.137 (Ref.1>T) . This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.
SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank.      It is required to support the continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.
The design of fuel transfer systems is such that pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks during or following DG testing. Therefore, a 31 day Frequency is specified to correspond to the maximum interval for DG testing.
SR 3.8.1.7 See SR 3.8.1.2.
(continued)
CLINTON                            B 3.8-16                  Revision No. 4-6
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.9  (continued)
REQUIREMENTS The referenced load for DG 1A is the low pressure core spray pump; for DG 1B, the residual heat removal (RHR) pump; and for DG 1C the HPCS pump. The Shutdown Service Water (SX) pump values are not used as the largest load since the SX supplies cooling to the associated DG. If this load were to trip, it would result in the loss of the DG. The use of larger loads for reference purposes is acceptable.      This Surveillance may be accomplished by:
: 1)    Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest load while paralleled to offsite power, or while supplying the bus, or
: 2)    Tripping its associated single largest load with the DG supplying the bus.
As required by IEEE-308 (Ref..'!4), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above synchronous speed, whichever is lower.
The 24 month Frequency is consistent with the refuel cycle recommendations of Regulatory Guide 1.9 (Ref."      ."
This SR has been modified by two Notes. The intent of Note 1 is to indicate that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and (continued)
CLINTON                        B 3.8-18                    Revision No. 10-7
 
AC Sources -Operating B 3.8.1 BASES SURVEILLANCE  SR  3.8.1.9  (continued)
REQUIREMENTS (continued) 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, Note 2 requires that, if synchronized to offsite power, testing be performed using a power factor 5 0.9.
This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.
Testing performed for this SR is normally conducted with the DG being tested (and .the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related (and non-safety related) distribution systems are aligned to the other offsite source (or unit auxiliary transformers).      This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
With regard to diesel speed values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties    (Ref.V 7) .-                  r24 SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load, i.e.,    maximum expected accident load, without overspeed tripping or exceeding the predetermined voltage limits. However, consistent with the recommendations of              161 Regulatory Guide 1.9, Revision 3 (Ref. A), this                        L J surveillance is performed with a DG load equal to or greater than 90 percent of its continuous rating.
The DG full load rejection may occur because of a system fault or inadvertent breaker tripping.        This Surveillance ensures proper engine generator load response under the simulated test conditions.
This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load.
These acceptance criteria provide DG damage protection.
(continued)
CLINTON                            B 3.8-19                      Revision No. 5-9
 
AC Sources-  Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.10    (continued)
REQUIREMENTS While the DG is not expected to experience this transient during an event and continue to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, testing must be performed using a power factor
* 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience.
The 24 month Frequency is consistent with the refuel cycle        1 recommendation of Regulatory Guide 1.9 (Ref.&#xfd;5an          is intended to be consistent with expected fuel cycle lengths.
This SR has been modified by a Note. The intent of the Note is to indicate that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)  Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related (and non-safety related) distribution systems are aligned to the other offsite source (or unit auxiliary transformers). This minimizes the possibility of common cause failure resulting from offsite/grid voltage perturbations.
This Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite of grid perturbations.
With regard to DG load and voltage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref.2-3).
LJ                  (continued)
CLINTON                        B 3.8-19a                  Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS SR  3.8.1.11                                  IT As required by Regulatory Guide 1.108 (Ref./),
paragraph 2.a. (1),  this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source.      This test verifies all actions encountered from the loss of offsite power, including shedding of the Division 1 and 2 nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
With regard to required voltage and frequency values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.
This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Refs.                ).
The DG auto-start time of 12    seconds is derived from requirements of the accident    analysis to respond to a design basis large break LOCA.      The Surveillance should be continued for a minimum of 5    minutes in order to demonstrate that all starting transients    have decayed and stability has been achieved.
With regard to DG auto-start time values obtained pursuant to this SR, as read from plant i\ndication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.      This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Ref. ..T).
F221 The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.      For instance, ECCS injection valves are not desired to be stroked open, systems are not capable of being operated at (continued)
CLINTON                          B 3.8-20                    Revision No. 4-6
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.11    (continued)
REQUIREMENTS full flow, or RHR systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.      This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months is consistent with the reuel cycle recommendations of Regulatory Guide 1.9 (Ref.13),
takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by two Notes.      The reason. for Note 1 is to minimize wear and tear on the DGs during testing.      For the purpose of this testing, the DGs must be started from standby conditions.      Standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation. This allowance is not intended to impose a maximum limit on engine temperatures.      The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge plant safety systems.
Credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
(continued)
CLINTON                          B 3.8-21                  Revision No. 10-7
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE  SR    3.8.1.12 REQUIREMENTS (continued) This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (12 seconds) from the design basis actuation signal (LOCA signal) and operates for &#x17d; 5 minutes.
The 5 minute period provides sufficient time to demonstrate stability.
With regard to DG start time, required voltage and frequency values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.      This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Refs. .2.k, 17., 8,21,    22) 1119.22,23 of 24 months takes into consideration plant conditions required to perform      the Surveillance and is intended to be consistent with      the expected fuel cycle lengths. Operating experience  has shown that these components usually pass the SR.        Therefore, the Frequency was concluded to be acceptable      from a reliability standpoint.
This SR is modified by two Notes.        The reason for Note 1 is to minimize wear and tear on the DGs during testing.            For the purpose of this testing, the DGs must be started from standby conditions.      Standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor. Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation.      This allowance is not intended to impose a maximum limit on engine temperatures.        The reason for Note 2 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems.      Credit may be taken for unplanned events that satisfy this SR.      Examples of unplanned events may include:
(continued)
CLINTON                            B 3.8-22                      Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.13  (continued)
REQUIREMENTS
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
SR  3.8.1.14                            *)
Regulatory Guide 1.9, Revision 3 (Ref. A? requires demonstration once per 24 months that the DGs can start and run continuously at or near full-load capability for an interval of not less than 24 hours. The DGs are to be loaded equal to or greater than 105 percent of the continuous rating for at least 2 hours and equal to or greater than 90 percent of the continuous rating tcr the 22 hours) (Ref."51). The remaining hours of the test (i.e.,
DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed using a power factor
* 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG could experience.
The 24 month Frequency is consistent with the refuel cycle recommendations of Regulatory Guide 1.9, Revision 3 (Ref.<        *H
            **); takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This Surveillance is modified by two Notes.      Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test.        The intent of Note 2 is to indicate that credit may be taken for unplanned events that satisfy this SR.      Examples of unplanned events may include:
(continued)
CLINTON                        B 3.8-24                    Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE            SR  3.8.1.14  (continued)
REQUIREMENTS
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related (and non-safety related) distribution systems are aligned to the other offsite source (or unit auxiliary transformers). This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
With regard to DG loading capability values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. ),4)
SR  3.8.1.15 This Surveillance is consisknt with the recommendations of R    _ Regulatory Guide 1.108 (Ref."',.8,  paragraph 2.a.(5), and demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 12 seconds. The 12 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA.
With regard to DG loading values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compens&#xfd;;ion for instrument indication Li_  uncertainties
                            ;              (Ref. ;9.
With regard to DG start time, frequency and voltage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.      This requires additional margin to be added to the limit to 117, 18, 19, 22, 23        compensate for instrument uncertaintie,      for implementation in the associated plant procedures (Refs. 16, 17+/-, 1, 21, 22).
The 24 month Frequency is consistent with the refuel cyc recommendations of Regulatory Guide 1.9, Revision 3 (Ref.'        7 (continued)
CLINTON                                    B 3.8-25                    Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.15    (continued)
REQUIREMENTS This SR has been modified by two Notes.        Note 1 ensures that the test is performed with the diesel sufficiently hot.        The requirement that the diesel has operated for at least 2 hours at full load conditions (i.e., equal to or greater than 90 percent of the continuous rating) prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.        Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
SR  3.8.1.16                                    F_
As required by Regulatory Guide 1.108 (Ref. s),
paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and load transfer from the DG to each offsite power source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the undervoltage logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs.      The DG is considered to be in ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the load sequence timers are reset.
Portions of the synchronization circuit are associated with the DG and portions with the offsite circuit.        If a failure in the synchronization requirement of the Surveillance occurs, depending on the specific affected portion of the synchronization circuit, either the DG or the associated offsite circuit is declared inoperable.
The Frequency of 24 months is consistent with the N~fuel            I cycle recommendations of Regulatory Guide 1.9 (Ref.'5A,        and takes into consideration plant conditions required to perform the Surveillance.
(continued)
CLINTON                          B 3 .8-26                  Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE  SR  3.8.1.16    (continued)
REQUIREMENTS This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.        Credit may be taken for unplanned events that satisfy this SR.
Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
SR  3.8.1.17 Demonstration of the test mode override is consist t with the recommendations of Regulatory Guide 1.108 (Ref.          ,      P-I paragraph 2.a.(8)and ensures that the DG availability under accident conditions is not compromised as the result of testing. Except as clarified below for the Division 3 DG, interlocks to the LOCA sensing circuits cause the DG to automatically reset to ready-to-load operation if an ECCS initiation signal is received during operation in        the test mode. Ready-to-load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.
These provisiocns for automatic switchover are required by 4 IEEE-308 (Ref. 'I.-r,  paragraph 6.2.6(2), as further amplified by IEEE 387, sections 5.6.1 and 5.6.2. (Clarification regarding conformance of the Division 3 DG design to these standards is provided in the USAR, Chapter 8 (Reference 2).)
Automatic switchover from the test mode to ready-to-load operation for the division 3 DG is also demonstrated, as described above, by ensuring that DG control logic automatically resets in response to a LOCA signal during the test mode and confirming that ready-to-load operation is attained (as evidenced by the DG running with the output breaker open). However, with the DG governor initially operating in a "droop" condition during the test mode, operator action may be required to reset the governor for (continued)
CLINTON                            B 3.8-27                  Revision No. 10-7
 
AC Sources -Operating B 3.8.1 BASES SURVEILLANCE SR  3.8.1.17  (continued)
REQUIREMENTS ready-to-load operation in order to complete the surveillance for the Division 3 DG. Resetting the governor ensures that the DG will supply the Division 3 bus at the required frequency in the event. of a LOCA and a loss of offsite power while the DG is in a droop condition during the test mode.
The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading is not affected by the DG operation in test mode.      In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.
This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The 24 month Frequency is consistent with the \efuel      cycle  F16&#xfd; recommendations of Regulatory Guide 1.9 (Ref. y5); takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This SR has been modified by a Note. The intent of this note is to indicate that credit may be taken for unplanned events that satisfy this SR. Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
Testing performed for this SR is normally conducted with the DG being tested (and the associated safety-related distribution subsystem) connected to one offsite source, while the remaining safety-related (and non-safety related) distribution systems are aligned to the other offsite source (or unit auxiliary transformers). This minimizes the possibility of common cause failures resulting from offsite/grid voltage perturbations.
(continued)
CLINTON                        B 3.8-28                  Revision No. 10-7
 
AC Sources-  Operating B 3.8.1 BASES SURVEILLAI HCE  SR  3.8.1.18 REQUIREMENITS (continuied) Under accident conditions with a loss of offsite power, loads are sequentially connected to the bus by the load sequencing logic (except for Division 3 which has no load sequence timers). The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents.
The 10% load sequence time tolerance ensures that sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding ESF equipment time delays are not violated and is consistent      ith the recommendations of 5J  Regulatory Guide  1.108  (Ref. 2),      paragraph 2.a.(2).
Reference 2 provides a summary of the automatic loading of ESF buses.
The Frequency of 24 months is consistent with the refuel cycle recommendations of Regulatory Guide 1.9 (Ref.5i; takes into consideration plant conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note.        The reason for the Note is that performing the Surveillance during these MODES may perturb the electrical distribution system, and challenge plant safety systems. Credit may be taken for unplanned events that satisfy this SR.        Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
With regard to sequence time values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. X*).
L--                  (continued)
CLINTON                            B 3.8-29                        Revision No. 10-7
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE    SR    3.8.1.19  (continued)
REQUIREMENTS
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
With regard to DG start time, required voltage and frequency values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties. This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Refs.
1:7, 413, 21:).
17,18,19, 221 SR  3.8.1.20 This Surveillance is performed with the plant shut down and demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.
0  The 10 year Frequency is consiq~ent with the recommendations
            .J  of Regulatory Guide 1.108 (Ref.v/).
This SR is modified by a Note.      The reason for the Note is to minimize wear on the DG during testing.      For the purpose of this testing, the DGs must be started from standby conditions. Standby conditions mean that the lube oil is heated by the jacket water and continuously circulated through a portion of the system as recommended by the vendor.      Engine jacket water is heated by an immersion heater and circulates through the system by natural circulation. This allowance is not intended to impose a maximum limit on engine temperatures.
With regard to required voltage and frequency values obtained pursuant to this SR,    as read from plant indication (continued)
CLINTON                              B 3.8-31                    Revision No. 5-3
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE  SR      3.8.1.20    (continued)
REQUIREMENTS instrumentation, the specified limit is not considered to be a nominal value with respect to instrument uncertainties.
This requires additional margin to be added to the limit to compensate for instrument uncertainties, for implementation in the associated plant procedures (Refs. 16, 17, 18, 21, 117,18,19, 22, 23 Diesel Generator Test Schedule The DG test schedule (Table 3.8.1-1) implements the industry
          *-, guide' nes for assessment of diesel generator performance Ref.u    2). The purpose of this test schedule is to provide timely test data to establish a confidence level associated with the goal to maintain DG reliability at > 0.95 per test.
According to the industry guidelines (Ref.,tl-21, each DG unit should be tested at least once every 31 days.          Whenever a DG has experienced 4 or more valid failures in the last 25 valid tests, the maximum time between tests is reduced to 7 days.        Four failures in 25 valid tests is a failure rate of 0.16, or the threshold of acceptable DG performance, and hence may be an early indication of the degradation of DG reliability.        When considered in the light of a long history of tests, however, 4 failures in the last 25 valid tests may only be a statistically probable distribution of random events.        Increasing the test Frequency allows a more timely accumulation of additional test data upon which to base judgment of the reliability of the DG.        The increased test Frequency must be maintained until seven consecutive failure free tests have been performed.
The Frequency for accelerated testing is 7 days, but no less than 24 hours.        Tests conducted at intervals of less than 24 hours may be credited for compliance with Required Actions.        However, for the purpose of re-establishing the normal 31-day Frequency, a successful test at an interval of less than 24 hours should be considered an invalid test and not count towards the seven consecutive failure free starts, and the consecutive test count is not reset.
A test interval in excess of 7 days (or 31 days, as appropriate) constitutes a failure to meet SRs and results in the associated DG being declared inoperable.            It does not, however, constitute a valid test or failure of the DG, and any consecutive test count is not reset.
(continued)
CLINTON                                B 3.8-32                    Revision No.      5-3
 
AC Sources -Operating B 3.8.1 BASES REFERENCES      1. 10 CFR 50, Appendix A, GDC 17.
: 2. USAR, Chapter 8.
: 3. Regulatory Guide 1.9,  Revision 2.
: 4. USAR, Chapter 6.
: 5. USAR, Chapter 15.
: 6. Regulatory Guide 1.93.
: 7. Generic Letter 84-15,  July 2,  1984.
10 CFR 50,  Appendix A,  GDC 18.
Regulatory Guide 1.108.
Regulatory Guide 1.137.
103.1~
6__J~-  ANSI C84.1,  1982.
NUMARC 87-00,  Revision 1, August 1991.
IEEE Standard 308.
EN-      IP Calculation 19-AN-19.
Regulatory Guide 1.9,  Revision 3.
Calculation IP-C-0050.
F15.1~  Calculation IP-C-0051.
Calculation IP-C-0054.
[761h.,- Calculation  IP-0-0114.
I17 .1e Calculation  IP-C-0111.
Calculation IP-0-0106.
Calculation IP-0-0143.
Calculation IP-0-0110.
Calculation IP-0-0116.
CLINTON                          B 3.8-32a                    Revision No. 7-7
 
DC Sources -Operating B 3.8.4 BASES ACTIONS>
(continued)      e    E7 With one or more Division 3 or 4 DC electrical power subsystems inoperable, the HPCS System may be incapable of Isr1performing              its intended functions and must be immediately declared inoperable.      This declaration also requires entry into applicable Conditions and Required Actions of LCO 3.5.1, "ECCS-Operating."
E 3 ANrd Z .2-dF.1 nJF1 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit 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.        The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).
SURVEILLANCE      SR  3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge-helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function.      Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery (or battery cell) and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem.      On float charge, battery cells will receive adequate current to continually charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer (2.20 Vpc or 127.6 V at the battery terminals).
This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years).      The 7 day Frequency is consistent with manufacturer's recommendations and IEEE-450 (Ref.        ).
With regard to battery terminal voltage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. --21.
(continued)
CLINTON                              B 3.8-55                    Revision No. 6-5
 
DC Sources -Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) SR  3.8.4.2 This SR verifies the design capacity of the batteryt chargers. According to Regulatory Guide 1.32 (Ref. y), the L-J battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensure that these requirements can be satisfied.      This SR provides two options. One option requires that each battery charger be capable of supplying 300 amps for Divisions 1 and 2 (100 amps for Divisions 3 and 4) at the minimum established float voltage for 4 hours. The ampere requirements are based on the output rating of the chargers.
The voltage requirements are, based on the charger voltage level after a response to a loss of AC power.      The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least 2 hours.
The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective or the status of the plant during which these demands occur).
This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current.
The battery is recharged when the measured charging current is  < 2 amps.
The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
With regard to minimum required amperes and duration values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require co for instrument indication uncertainties (Ref.4.                  [L (continued)
CLINTON                          B 3.8-56                  Revision No. 10-7
 
DC Sources--Operating B 3.8.4 BASES SURVEILLANCE SR  3.8.4.3 REQUIREMENTS (continued)
A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system.      The discharge rate and test length are established with a dummy load that corresponds to the design duty cycle requirements as specified in Reference 4.
The Surveillance Frequency of 24 months is an exception to the recommendations of Regulaory Guide 1.32 (Ref.        and Regulatory Guide 1.129 (Ref.    ), which state that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 18 months.
This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test SR 3.8.6.6 in lieu of SR 3.8.4.3. This substitution is acceptable because SR 3.8.6.6 represents an equivalent test of battery capability as SR 3.8.4.3. The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance. Examples of unplanned events may include:
: 1)    Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and
: 2)    Post maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.
With regard to battery capacity values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. 1).
(continued)
CLINTON                        B 3 .8-57                Revision No. 10-7
 
DC Sources--Operating B 3.8.4 BASES REFERENCES          1. 10 CFR 50, Appendix A,  GDC 17.
: 2. Regulatory Guide 1.6,  March 10, 1971.
: 3. IEEE Standard 308,  1978.
: 4. USAR, Section 8.3.2.
: 5. USAR, Chapter 6.
: 6. USAR, Chapter 15.
: 7. Regulatory Guide 1.93,  December 1974.
IEEE Standard 450,  1995.
Fl- ~~2T    Regulatory Guide 1.32,  February 1977.
Regulatory Guide 1.129,  December 1974.
Calculation IP-0-0123.
CLINTON                            B 3.8-58                    Revision No. 6-5
 
Inverters -Operating B 3.8.7 BASES ACTIONS A.1    (continued)
In addition to the above, the following evaluations will be performed as part of the CPS risk management program whenever inverter maintenance is required.
: 1. Evaluate simultaneous        switchyard maintenance and reliability.
: 2. Evaluate concurrent maintenance or inoperable status of any of the remaining three instrument bus inverters for the unit.
: 3. Evaluate simultaneous EDG maintenance.
With one or more Division 3 or 4 inverters inoperable, the associated Division 3 ECCS subsystem may be incapable of performing intended function and must be immediately declared inoperable.          This also requires entry into applicable Conditions and Required Actions for LCO 3.5.1, "ECCS--Operating.
ID.1.1, D.. ,      .
e.I+/-.+/-,    e.1. 2 .... d e. 2 With one RPS solenoid bus inverter inoperable it may be incapable of providing voltage and frequency regulated power sufficient to protect the loads connected to the bus.              In this condition, the source of power must be transferred or removed from service.          If the RPS bus power is transferred to its    alternate source, an additional ACTION is required to periodically monitor the frequency on the bus.            This frequency is designed to be limited by the in-line RPS electric power monitoring assembly (required by LCO 3.3.8.2, "RPS Electric Power Monitoring"), however, in the event of a single failure, frequency protection would not be available.
Should frequency be discovered < 57 Hz, additional ACTIONS are required in LCO 3.3.8.2 due to the inoperable RPS electric power monitoring assembly.
The 1 hour Completion Time is sufficient for plant personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration, transfer or removal of the RPS bus power supply from service.
(continued)
CLINTON                          B 3.8-71b                  Revision No. 12-3
 
Inverters  -  Shutdown i      B 3.8.8 BASES ACTIONS (continued)
With both RPS solenoid bus inverters inoperable both RPS buses may be incapable of providing voltage and frequency regulated power sufficient to protect the loads connected to the buses. In this condition, the source of power must be transferred or removed from service, however,'only one RPS bus is allowed to be powered from an alternate source at any one time. Therefore, at least one RPS solenoid bus must be de-energized. The remaining affected bus will be de-energized or powered from its    alternate sourc6 in accordance with Condition. 4 The 1 hour Completion Time is sufficient for plant personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration or removal of the RPS bus power supply from service.
1F.1 and F.2 F2.1 &R1 1B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the associated Completion Time, 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, tolreach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
(continued)
CLINTON                        B 3.8-72                    Revision No. 12-3
 
Invert ers -Operating B 3.8.7 BASES SURVEILLANCE    SR    3.8.7.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all    required circuit breakers closed and uninterruptible AC buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation connected to the uninterruptible AC buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.
With regard to voltage and frequency values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref        ff.ij REFERENCES      1.      USAR, Chapter 8.
: 2.      USAR, Chapter 6.
: 3.      USAR, Chapter 15.
2          4inser2
[]/        Calculation IP-0-0131.
CLINTON                              B 3.8-73                  Revision No. 12-3
 
Distribution Systems--Operating B 3.8.9 BASES ACTIONS                C.1    (continued)
: b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; and
: c. The potential for an event in conjunction with a single failure of a redundant component.
The 2 hour Completion Time for DC buses is        consistent with Regulatory Guide 1.93 (Ref. 3).
The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO.      If Condition C is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours.      This situation could lead to a total duration of 10 hours, since initial        failure of the LCO, to restore the DC distribution system.        At this time, an AC division could again become inoperable, and DC distribution could be restored OPERABLE.        This could continue indefinitely.
This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."
This allowance results in establishing the "time zero" at the time the LCO was initially      not met, instead of the time Condition C was entered.        The 16 hour Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.
D.I and D.2 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated overall plant ris    Completion Times, the plant u t be bought to a MODE in
_s miiwhich the LCO cele net apply.        To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and tl MOD9 4 ;;ithin ;6 houra.      The allowed Completion Timelie--L.
I'                        (continued)
CLINTON                                    B 3 .8-85                      Revision No. 0
 
Distribution Systems--Operating B 3.8.9 BASES ACTIONS      D.1 an4d  .2  (continued) reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
E.1 With one or more Division 3 or 4 electrical power distribution system(s) inoperable, the Division 3 or 4 powered systems are not capable of performing their intended functions. Immediately declaring the high pressure core spray inoperable allows the ACTIONS of LCO 3.5.1, "ECCS-Operating," to apply appropriate limitations on continued reactor operation.
F.1 Condition F corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost.      When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation.      LCO 3.0.3 must be entered immediately to commence a controlled shutdown.
SURVEILLANCE SR  3.8.9.1 REQUIREMENTS Meeting this Surveillance verifies that the required AC, DC, and uninterruptible AC bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment.      The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.      The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to (continued)
CLINTON                          B 3.8-86                      Revision No. 0
 
Distribution Systems--Operating B 3.8.9 BASES SURVEILLANCE SR  3.8.9.1  (continued)
REQUIREMENTS these buses. The 7 day Frequency takes into account the redundant capability of the AC, DC, and uninterruptible AC bus electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.
With regard to voltage values obtained pursuant to this SR, as read from plant indication instrumentation, the specified limit is considered to be a nominal value and therefore does not require compensation for instrument indication uncertainties (Ref. .
REFERENCES  1. USAR,  Chapter 6.
: 2. USAR,  Chapter 15.
: 3. Regulatory Guide 1.93,  December 1974.
USAR,  Section 8.3.
Calculation IP-0-0132.
CLINTON                        B 3.8-87                  Revision No. 4-6
 
Clinton Power Station TSTF-423 LAR Technical Specification Bases Page Inserts LCO 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitorinq Insert I 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 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 B. I is modified by a Note that prohibitsthe applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.5.1 ECCS-Operatinq Insert 1 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. 13) 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.
RequiredAction D.1 is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similarto or lower than the risk in MODE 4 (Ref. 13) and because the time spent in MODE 3 to perform the necessary repairsto 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.
RequiredAction G. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 3
: 13. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.6 Low-Low Set (LLS) Valves Insert 1 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 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.
RequiredAction B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissibleunder LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 C.1 and C.2 Iftwo or more LLS valves are inoperable, there could be excessive short duration S/RV cycling during an overpressure event. The plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 and 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.
Insert 3
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.7 Residual Heat Removal (RHR) Containment Spray System Insert I 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 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.
RequiredAction C. I is modified by a Note that prohibits the applicationof 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 RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.9 Feedwater Leakage Control System (FWLCS)
Insert 1 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 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 C. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordance with LCO 3.0.4.b. Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling Insert 1 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 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 B.1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissibleunder 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 RequiredAction 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 accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptability of entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 C.1 and C.2 Iftwo RHR suppression pool cooling subsystems are inoperable, 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.
Insert 3
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.4.1 Secondary Containment Insert 1 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. 3), 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 B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordance with LCO 3.0.4.b. Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.4.3 Standby Gas Treatment (SGT) System Insert I 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. 9) 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.
RequiredAction B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissibleunder 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 RequiredAction 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 assessmentmay be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 Therefore, 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. 9) 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. 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.
RequiredAction D.1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordance with LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 3
: 9.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.5.6 Drywell Post-LOCA Vacuum Relief System Insert I E.1 If one drywell post-LOCA vacuum relief subsystem is inoperable for reasons other than Condition A or two or more drywell post-LOCA vacuum relief subsystems are inoperable for reasons other than Condition A, and not restored within the provided Completion Time, the plant must be brought to a condition 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. 2) 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. 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.
RequiredAction E.1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicating that it is not permissibleunder LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performedin accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.1 Division 1 and 2 SX Subsystems and UHS Insert I C.1 Ifthe Required Action and associated Completion Time of Condition B is not met, the plant must be brought to a condition 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. 8) 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. 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.
RequiredAction C. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordance with LCO 3.0.4.a. However, where allowed, a risk assessment may be performedin accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.3 Control Room Ventilation System Insert 1 B.1 In MODE 1, 2, or 3, if the inoperableControl Room Ventilation subsystem cannot be restored to OPERABLE status within the associatedCompletion 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. 7) 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. The allowed Completion Time is reasonable,based on operating experience, to reach the requiredunit conditions from full power conditions in an orderly manner and without challenging unit systems.
Required Action B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 Therefore, 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. 7) 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. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions is an orderly manner and without challenging plant systems.
Required Action F.1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat it is not permissibleunder LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performedin accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 3
: 7. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.4 Control Room Air Conditioning (AC) System Insert 1 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. 3) 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 C. I is modified by a Note that prohibits the applicationof 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.5 Main Condenser Offaas Insert 1 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 B.3 is modified by a Note that prohibits the applicationof 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.1 AC Sources - Operatinq Insert 1 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. 8) 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 F.1 is modified by a Note that prohibits the applicationof 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordance with LCO 3.0.4.b. Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.4 DC Sources - Operatinq Insert 1 D.1 If a Division 1 or 2 DC electrical power subsystem is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition 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. 8) 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. 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.
Required Action D. I is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptable level of risk, it is not the intent of the RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.7 Inverters - Operatinq Insert I B.1 If a Division 1 or 2 inverter is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition 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. 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.
RequiredAction B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.9 Distribution Systems - Operating Insert 1 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 D. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performedin accordancewith LCO 3.0.4.b. Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
ATTACHMENT 4 Markup of Revised Proposed DNPS Technical Specifications Pages TS Note Insert:
------------------------------- NOTE ...........................
LCO 3.0.4.a is not applicable when entering MODE 3.
Revised Proposed DNPS TS Pages 3.4.3 -1 3.5.1 -1 3.5.1 -2 3.5.1 -3 3.5.3 -1 3.6.1.6 -1 3.6.1.7-1 3.6.1.7 -2 3.6.1.8 -1 3.6.2.3 -1 3.6.2.4 -1 3.6.4.1 -1 3.6.4.3 -1 3.6.4.3 -2 3.7.1 -1 3.7.4 -1" 3.7.4 -2*
3.7.5 -1 3.7.6 -1 3.8.1 -5 3.8.4 -4 3.8.7 -2
* Denotes TS pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS version Page 1 of 1
 
Safety and Relief Valves 3.4.3 3.4  REACTOR COOLANT SYSTEM (RCS) 3.4.3    Safety and Relief Valves LCO  3.4.3          The safety function of 9 safety valves shall        be OPERABLE.
AND The relief function of 5 relief valves shall        be OPERABLE.
APPLICABILITY:      MODES 1, 2, and 3.
ACTIONS CONDITION                  REQUIRED ACTION                COMPLETION TIME A. One relief valve            A.1    Restore the relief            14 days inoperable,                        valve to OPERABLE status.
-  B. Required Action and        B.1    Be in MODE 3.                12 hours associated Completion Time of Condition A        _A*&-                  ITSNotelnsert not met.
B.2    De H,- ,-.      .            36 h4ui-.
[*]  Two valvesor more  relief inoperable.        C.      Be in MODE 3.                12 hours AND OR C.2      Be in MODE 4.                36 hours One or more safety valves inoperable.
Dresden 2 and 3                        3.4.3-1                    Amendment No. 208/200
 
ECCS-Operating 3.5.1 3.5      EMERGENCY CORE COOLING SYSTEMS (ECCS)                                      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 shall 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
------------------------------------- NOT E ------------------------------------
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.
A.        Two LPCI subsystems                              P                Restore one LPCI                            72 hours
[l      inoperable for reasons                          FE                subsystem to other than Condition C.                                          OPERABLE          status.
D.      Required Action and associated                    D.1              Be in MODE 3. -                1            12 hoursI(continued)
Completion Time of Condition A,                                                    Its Note inserti B, or C not met.
Dresden 2 and 3                                                      3.5.1-1                                    Amendment No.              212/204
 
ECCS--Operati ng 3.5.1.
ACTIONS CONDITION                                REQUIRED ACTION                  COMPLETION TIME Required Action and                S-[-+/- F.1    Be in MODE 3.                  12 hours associated Completion Time of Condition-A-,              AND B, C, or D not met.
E.2 r.2    Be in MODE 4.                  36 hours
                                            .9.
HPCI System                                      Verify by                      Immediately inoperable.                                      administrative means IC System is OPERABLE.
AND F.2 f- -21      Restore HPCI System            14 days to OPERABLE status.
4                                            I r-U-1      One ADS valve                        0.1          Restore ADS valve to          14 days 1"11      inoperable.                                      OPERABLE status.
MiH1 Required Actior, and              4              Be in Mode 3.                  12 hours cazZ30iated Ccrnpleti"                      J.
Tie of *,.d.t.oi F or                AND G mt met.
Reduce reactor steam          36 hours 121    dome pressure to
                                                            <  150 psig.
Two or more ADS valves inoperable.
(continued)
Required Action and associated      1.1          Be in MODE 3.      j]        12 hours Completion Time of Condition G                              ITS Note Insert]
or H not met.
Dresden 2 and 3                                    3.5.1-2                      Amendment No. 188/183
 
ECCS-Operating 3.5.1 ACTIONS CONDITION          REQUIRED ACTION      COMPLETION TIME F. Two or more low pressure ECCS Enter LCO 3.0.3      Immediately injection/spray subsystems inoperable for reasons other than Condition C orAK OR HPCI System and one or more ADS valves inoperable.
OR One or more low pressure ECCS injection/spray subsystems inoperable and one or more ADS valves inoperable.
OR HPCI System inoperable and either one low pressure ECS injection/spray subsystem is inoperable or Condition C entered.
Dresden 2 and 3              3.5.1-3            Amendment No. 188/183
 
IC System 3.5.3 3.5  EMERGENCY CORE COOLING SYSTEMS (ECCS)    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.I      Verify by                    Immediately administrative means High Pressure Coolant Injection System is OPERABLE.
AND A.2      Restore IC System to          14 days OPERABLE status.
B. Required Action and      B.I      Be in MODE 3.                12 hours associated Completion Time not met.            A                    [TSNotelnsert B.2      Reduc2  rcct*--    tme  -%
deme ppessure te 16 5Opoig.
Dresden 2 and 3                      3.5.3-1                      Amendment No. 212/204
 
Low Set Relief  Valves 3.6.1.6 3.6  CONTAINMENT SYSTEMS 3.6.1.6    Low Set Relief Valves LCO  3.6.1.6      The low set  relief function of two relief valves shall be OPERABLE.
APPLICABILITY:      MODES  1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION                  COMPLETION TIME A. One low set relief        A.1      Restore low set                14 days valve inoperable,                    relief valve to OPERABLE status.
B. Required Action and        B.1      Be in MODE 3.                  12 hours associated Completion Time of Condition A            -                    TSNotelnsert not met.
B.2      Be in ,O      4rs 4..
0.1        Be in MODE 3.                12 hours
  ]  Two low set relief        AND valves inoperable.
C.2        Be in MODE 4.                36 hours Dresden 2 and 3                        3.6.1.6-1                    Amendment No. 185/180
 
Reactor Building-to-Suppression      Chamber Vacuum Breakers 3.6.1.7 3.6  CONTAINMENT  SYSTEMS 3.6.1.7    Reactor Building-to-Suppression      Chamber Vacuum Breakers LCO  3.6.1.7      Each reactor building-to-suppression      chamber vacuum breaker shall be OPERABLE.
APPLICABILITY:      MODES 1,  2,  and 3.
ACTIONS
---------------------------------------      NOTE------------------------------------
Separate Condition entry is allowed for each line.
CONDITION                        REQUIRED ACTION            COMPLETION TIME A. One or more lines with      A.1        Close the open vacuum    7 days one reactor building-                  breaker.
to-suppression chamber vacuum breaker not closed.
B. One or more lines with      B.1        Close one open vacuum    1 hour two reactor building-                  breaker.
to-suppression chamber vacuum breakers not closed.
C. One line with one or        C.1        Restore the vacuum      7 days more reactor building-                breaker(s) to to-suppression chamber                OPERABLE status.
vacuum breakers inoperable for opening.
(continued)
Dresden 2 and 3                          3.6. 1.7-1              Amendment No. 185/180
 
Reactor, Building-to-Suppression        Chamber Vacuum Breakers 3.6.1.7 ACTIONS CONDITION                  I              REQUIRED ACTION            I COMPLETION TIME
[jJ.          Two lines with one or                                Restore all vacuum          1 hour more reactor building-                  El          breakers in one line to-suppression chamber                              to OPERABLE status.
vacuum breakers inoperable for opening.
                                                                                          -I
*]/L{.        Required Action and                  4-      f-4F1  Be in MODE 3.                12 hours Associated Completion Time not met.                          AND
                                                      -E-.2F-2    Be in MODE 4.                36 hours lof Conditions A, B, or El
__________________________________              L _____________________________________  J _____________________
SURVEILLANCE              REQUIREMENTS SURVEILLANCE                                            FREQUENCY SR      3.6.1.7.1              ------------------- NOTES-----------------
: 1. Not required to be met for vacuum breakers that are open during Surveillances.
: 2. Not required to be met for vacuum breakers open when performing their intended function.
Verify each vacuum breaker is          closed.            14 days SR    3.6.1.7.2                Perform a functional          test of each vacuum        92 days breaker.
(continued)
Dresden        2 and 3                                    3.6.1.7-2              Amendment          No.      185/180
 
Suppression Chamber-to-Drywell          Vacuum Breakers 3.6.1.8 3.6    CONTAINMENT      SYSTEMS 3.6.1.8      Suppression Chamber-to-Drywell          Vacuum Breakers LCO  3.6.1.8          Nine suppression chamber-to-drywell          vacuum breakers    shall  be OPERABLE for opening.
AND Twelve suppression chamber-to-drywell          vacuum breakers shall be closed.
APPLICABILITY:          MODES 1,  2,  and 3.
ACTIONS CONDITION                          REQUIRED ACTION                COMPLETION TIME A. One required                    A.1        Restore one vacuum            72 hours suppression chamber-                      breaker to OPERABLE to-drywell vacuum                          status.
breaker inoperable for opening.
F~jj,. One suppression chamber-to-drywell
                                          -eD        Close the open vacuum breaker.
4 hours vacuum breaker not closed.
RD.        Required Action and                        Be in MODE 3.                12 hours associated Completion Time not met.                  AND 5 f odition C                          Be in MODE 4.                36 hours B. Required Action and            B.1        Be in MODE 3.                12 hours associated Completion Time of Condition A not met.                              TS Note Insert Dresden 2 and 3                              3.6.1.8-1                    Amendment No. 185/180
 
Suppression Pool  Cooling 3.6.2.3 3.6  CONTAINMENT SYSTEMS 3.6.2.3    Suppression Pool Cooling LCO  3.6.2.3          Two suppression pool cooling subsystems shall be OPERABLE.
APPLICABILITY:        MODES 1,    2,    and 3.
ACTIONS CONDITION                              REQUIRED ACTION          COMPLETION TIME A. One suppression pool                A.1      Restore suppression    7 days cooling subsystem                              pool cooling inoperable,                                    subsystem to OPERABLE status.
Fix    Two suppression pool                B.i      Restore one            8 hours cooling subsystems                            suppression pool inoperable.                                    cooling subsystem to OPERABLE status.
                                                                            +
Required Action and                            Be in MODE 3.          12 hours associated Completion Time not met.                        AND
[of Condition C                                Be in MODE 4.          36 hours
: 3. Required Action and associated Completion Time of Condition A not met.
                                        *g.
Dresden 2 and 3                                  3.6.2.3-1              Amendment No. 185/180
 
Suppression Pool Spray 3.6.2.4 3.6  CONTAINMENT SYSTEMS 3.6.2.4    Suppression Pool Spray LCO  3.6.2.4      Two suppression pool    spray subsystems shall    be OPERABLE.
APPLICABILITY:    MODES 1, 2,  and 3.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One suppression pool      A.1      Restore suppression        7 days spray subsystem                    pool spray subsystem inoperable,                        to OPERABLE status.
B. Two suppression pool      B.1      Restore one                8 hours spray subsystems                    suppression pool inoperable,                        spray subsystem to OPERABLE status.
C. Required Action and      C.1      Be in MODE 3.              12 hours associated Completion Time not met.                                ITS NotelInset C.2      Be in MODE..46 Dresden 2 and 3                        3.6.2.4-1                  Amendment No. 185/180
 
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, During operations with a potential for draining the reactor vessel (OPDRVs).
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      B.1      Be in MODE 3.              12 hours associated Completion Time of Condition A                              LSNotelnse T
not met.
B.2      Be  in, MODE 4.            96 Ham 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 or during OPDRVs.                    recently irradiated fuel assemblies in the secondary containment.
AND C.2      Initiate action to          Immediately        I suspend OPDRVs.
Dresden 2 and 3                      3.6.4.1-1                  Amendment No. 221/212
 
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                  I the secondary containment,                                            I During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION                COMPLETION TIME A. One SGT subsystem        A.1        Restore SGT                7 days inoperable,                          subsystem to OPERABLE status.
B. Required Action and      B.1        Be in MODE 3.              12 hours associated Completion Time of Condition A      -A-                    TSNotelnserI not met in MODE 1, 2, or 3.                    B.2      Be in. O.E 4.            4  ho....
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 during OPDRVs.
(continued)
Dresden 2 and 3,                      3.6.4.3-1                  Amendment No.      221/212
 
SGT System 3.6.4.3 ACTIONS CONDITION                REQUIRED ACTION              COMPLETION TIME C.  (continued)            C.2.1    Suspend movement of        Immediately recently irradiated fuel assemblies in secondary containment.
AND C.2.2    Initiate action to        Immediately suspend OPDRVs.
D. Two SGT subsystems      D.1      Restore one SGT            I hour inoperable in MODE 1,            subsystem to 2, or 3.                          OPERABLE status.
E. Required Action and    E.1      Be in MODE 3.              12 hours associated Completion Time of Condition D  7                    TS Note Inser not met.
E          c in MODE.
B2                        36 h4uP.
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 during OPDRVs.                recently irradiated fuel assemblies in secondary containment.
AND F.2      Initiate action to        Immediately        I suspend OPDRVs.
Dresden 2 and 3                    3.6.4.3-2                  Amendment No. 221/212
 
CCSW System 3.7.1 3.7  PLANT SYSTEMS 3.7.1    Containment Cooling Service Water (CCSW)                System LCO  3.7.1            Two CCSW subsystems shall          be OPERABLE.
APPLICABILITY:          MODES 1,    2,    and 3.
ACTIONS CONDITION                            REQUIRED ACTION                COMPLETION TIME A. One CCSW pump                      A.1      Restore CCSW pump to          30 days inoperable.                                  OPERABLE status.
B. One CCSW pump in each              B.1      Restore one CCSW pump        7 days subsystem inoperable,                        to OPERABLE status.
C. One CCSW subsystem                  C.I      Restore CCSW                  7 days inoperable for reasons                        subsystem to OPERABLE other than                                    status.
Condition A.
Both CCSW subsystems                          Restore one CCSW              8 hours inoperable for reasons                        subsystem to OPERABLE other than                                    status.
Condition B.
Required Action and                          Be in MODE 3.                12 hours associated Completion Time not met.
AND lof C5nditioE                        E 2[qF    Be in MODE 4.                36 hours D. Required Action and associated      D.A      Be in MODE 3.                  12 hours Completion Time of Conditions A, B, or C not met.
[TS Note Insert
                                      .1                                      I Dresden 2 and 3                                  3.7. 1-1                    Amendment No. 185/180
 
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 (CRE) 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, During operations with a potential for draining the reactor vessel (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 )3.icl CREV system inoperable          /.i        Initiate action to          Immediately due to inoperable CRE            r-l        implement mitigating boundary in MODE 1, 2,                      actions.
or 3.
AND
                                      /42        Verify mitigating          24 hours P~        actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
AND
                                      /93        Restore CRE boundary        90 days to OPERABLE status.
(BantinRned)
B. Required Action and associated    B.1      Be in MODE 3.'n-      r        12 hours Completion Time of Condition A                        ITS Note1nsero not met in MODE 1, 2, or 3.
A Dresden 2 and 3                                3.7.4-1                  Amendment No. 226/218
 
CREV System 3.7.4 ACTIONS (continued)
CONDITION                        REQUIRED ACTION            COMPLETION TIME
  '. Required Action and        A.1        Be in MODE 3.            12 hours associated Completion Time of Condition-A--ori    AND
    'l,*-not met in MODE 1, 2, or 3.                                Be in MODE 4.            36 hours 4                                      4 CREV System inoperable      -------------  NOTE-------------
during movement of          LCO 3.0.3 is not applicable.
recently irradiated fuel assemblies in the secondary containment      /  1        Suspend movement of      Immediately or during OPDRVs.                      recently irradiated fuel assemblies in OR                                      the secondary containment.
CREV System inoperable due to an inoperable        AND CRE boundary during movement of recently      12          Initiate action to        Immediately irradiated fuel                        suspend OPDRVs.
assemblies in the secondary containment or during OPDRVs.
Dresden 2 and 3                              3.7.4-2                  Amendment No. 226/218
 
Control  Room Emergency Venti 1 ati on 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              I the secondary containment,                                      I During operations with a potential for draining the reactor vessel (OPDRVs).
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        B.1      Be in MODE 3.              12 hours associated Completion Time of Condition A                            TS Note Inset not met in MODE 1, 2, or 3.                      B.2      Be in MO.E 4.
C. Control Room Emergency ------------- NOTE------------
Ventilation AC System      LCO 3.0.3 is not applicable.
inoperable during I
movement of recently irradiated fuel assemblies in the C.1        Suspend movement of recently irradiated Immediately        J secondary containment                fuel assemblies in or during OPDRVs.                    the secondary containment.
AND C.2        Initiate action to        Immediately suspend OPDRVs.
Dresden 2 and 3                        3.7.5-1                    Amendment No. 221/212
 
Main Condenser Offgas 3.7.6 3.7  PLANT SYSTEMS 3.7.6  Main Condenser Offgas LCO  3.7.6        The gross gamma activity rate of the noble gases measured prior to the offgas holdup line shall be 5 252,700 pCi/second after decay of 30 minutes.
APPLICABILITY:      MODE 1, MODES 2 and 3 with any main steam line not isolated and steam jet air ejector (SJAE) in operation.
ACTIONS CONDITION                    REQUIRED ACTION                COMPLETION TIME A. Gross gamma activity      A.I        Restore gross gamma          72 hours rate of the noble                    activity rate of the gases not within                    noble gases to within limit.                              limit.
B. Required Action and      B.1        Isolate all main            12 hours associated Completion                steam lines.
Time not met.
OR B.2        Isolate SJAE.                12 hours OR B.31      Be in MODE 3.                12 hours 2fiTS              Note Insert 9.3.2      Be jin 4ODE 4.
Dresden 2 and 3                        3.7.6-1                    Amendment No. 185/180
 
AC Sources-Operating 3.8.1 ACTIONS CONDITION              REQUIRED ACTION                COMPLETION TIME F. Required Action and    F.I    Be in MODE 3.                12 hours associated Completion Time of Condition A,    -              rTS Note Inset B, C, D, or E not met.
F.2    Be  in .ODE 4.
G. Three or more required G.1    Enter LCO 3.0.3.            Immediately AC sources inoperable.
Dresden 2 and 3                  3.8.1-5                    Amendment No. 185/180
 
DC Sources-Operating 3.8.4 ACTIONS CONDITION              REQUIRED ACTION                COMPLETION TIME H. Division 1 or 2        H.1    Restore Division 1          2 hours 125 VDC electrical            or 2 125 VDC power subsystem              electrical power inoperable for reasons        subsystem to OPERABLE other than                    status.
Conditions E, F, or G.
OR H.2  -------- NOTE--------
Only applicable if the opposite unit is not in MODE 1, 2, or 3.
2 hours Place associated OPERABLE alternate 125 VDC electrical power subsystem in service.
I. Opposite unit          1.1    Restore opposite unit      7 days              I Division 2 125 VDC            Division 2 125 VDC electrical power              electrical power subsystem inoperable,        subsystem to OPERABLE status.
J. Required Action and    J.1    Be in MODE 3.              12 hours associated.Completion Time not met.                            [TSNotelnser J.2    BDe in
                                      , .. [ 4.              ..  ......
Dresden 2 and 3                3.8.4-4                  Amendment No. 207/199
 
Distribution Systems-Operating 3.8.7 ACTIONS CONDITION                  REQUIRED ACTION                COMPLETION TIME B. One or more DC          B.1      Restore DC electrical        2 hours electrical power                  power distribution distribution                      subsystems to                AND subsystems inoperable.            OPERABLE status.
16 hours from discovery of failure to meet LCO 3.8.7.a C. One or more required  -------------- NOTE-----------
opposite unit Division  Enter applicable Conditions 2 AC or DC electrical  and Required Actions of power distribution      LCO 3.8.1 when Condition C subsystems inoperable,  results in the inoperability of a required offsite circuit.
C.1      Restore required            7 days opposite unit Division 2 AC and DC electrical power distribution subsystems to OPERABLE status.
D. Required Action and    D.1      Be in MODE 3.                12 hours associated Completion Time of Condition A,    AN                    ITSNotelnserI B, or C not met.
D.2      Be  in ,.u E 4.
* HO..
E. Two or more electrical  E.1      Enter LCO 3.0.3.            Immediately power distribution subsystems inoperable that, in combination, result in a loss of function.
Dresden 2 and 3                    3.8.7-2                      Amendment No. 185/180
 
ATTACHMENT 5 Markup of Revised Proposed DNPS Technical Specifications Bases Pages Revised Proposed DNPS TS Bases Pages B 3.4.3 -5*                                B 3.7.4 -5*
B 3.4.3 -7*                                B 3.7.4 -6*
B 3.4.3 -8*                                B 3.7.4 -8*
B 3.5.1 -7                                B 3.7.4 -9*
B 3.5.1 -8                                B 3.7.5 -3 B 3.5.1 -9                                B 3.7.5 -5 B 3.5.1 -10                                B3.7.6 -2 B 3.5.1 -18                                B 3.7.6 -3 B 3.5.3 -3                                B 3.8.1 -16 B 3.5.3 -4                                B 3.8.1 -17*
B 3.5.3 -6                                B 3.8.1 -18*
B 3.5.3 -7                                B 3.8.1 -19*
B 3.6.1.6 -2                                B 3.8.1 -20*
B 3.6.1.6 -3                                B 3.8.1 -22*
B 3.6.1.6 -4*                              B 3.8.1 -23*
B 3.6.1.6 -5*                              B 3.8.1 -24*
B 3.6.1.7 -4                                B 3.8.1 -25*
B 3.6.1.7 -5                                B 3.8.1 -26*
B 3.6.1.7 -6                                B 3.8.1 -27*
B 3.6.1.8 -4                                B 3.8.1 -28*
B 3.6.1.8 -6                                B 3.8.1 -29*
B 3.6.2.3 -3                                B 3.8.1 -30*
B 3.6.2.3 -4*                              B 3.8.1 -31*
B 3.6.2.4 -3                                B 3.8.1 -32*
B 3.6.2.4 -4                                B 3.8.1 -34*
B 3.6.4.1 -3                                B 3.8.4 -16 B 3.6.4.1 -6                                B 3.8.4 -17 B 3.6.4.3 -3                                B 3.8.4 -19 B 3.6.4.3 -5                                B 3.8.7 -10 B 3.6.4.3 -6                                B 3.8.7 -11 B 3.6.4.3 -7 B 3.7.1 -4 B 3.7.1 -5 B 3.7.1 -6*
* Denotes TS Bases pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS Bases page version Page 1 of 1
 
Safety and Relief Valves B 3.4.3 BASES overall plant ACTIONS        B.1  ,                                                                risk is (continued)                                                                          minimized.
With 1,, t1h*,o the ,,i,, f,,,,, m ,mbe, of ,equired    *,af ty v llves uP[RABLE,  a tri-sent may reSit in tHe ioloteiono the ASME Cde limit, o..n recetor pressure.        If the relief function of the inoperable relief valves cannot be restored to OPERABLE status within the associated Completion Time of Required Action A.1, or if the relie f6uict4if of tw          .. r mope rel~ief Yalves are inoperable, or if the safety            ufunctaio uF oine us inue saFety valves is ioperable, the pla*,t must be brought to a MODE in which the 6G@ dees Het ap+4. -To achieve this status, the plant must be brought to MODE 3 within 12 hour..          14199MOE4 io.!thin 36 hcrps. 'The    allowed Completion Time/i    e-reasonable, based on operating experience, to reach required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE    SR  3.4.3.1 REQUIREMENTS This Surveillance requires that the safety valves, including the S/RV, will open at the pressures assumed in the safety analysis of Reference 1. The demonstration of the safety valve and S/RV safety lift      settings must be performed during shutdown, since this is a bench test, to be done in accordance with the Inservice Testing Program.            The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures.
The safety valve and S/RV setpoints are +/- 3% for OPERABILITY; however, the valves are reset to +/- 1% during the Surveillance to allow for drift.
SR  3.4.3.2 The actuator of each of the Electromatic relief valves (ERVs) and the dual function safety/relief valves (S/RVs) is stroked to verify that the pilot valve strokes when manually actuated. For the S/RVs, the actuator test is performed by energizing a solenoid that pneumatically actuates a plunger located within the main valve body.          The plunger is connected to the second stage disc.          When steam pressure actuates the plunger during plant operation, this allows pressure to be vented from the top of the main valve piston, allowing reactor pressure to lift        the main valve piston, (continued)
Dresden 2 and 3                    B 3.4.3-5                                Revision 36
 
Safety and Relief Valves B 3.4.3 BASES SURVEILLANCE    SR  3.4.3.2  (continued)
REQUIREMENTS The combination of the valve testing and the valve actuator testing provide a complete check of the capability of the valves to open and close, such that full functionality is demonstrated through overlapping tests, without cycling the val ves.
The 24 month Frequency ensures that each solenoid for each relief valve is tested. The 24 month Frequency was developed based on the relief valve tests required by the 6        ASME Code (Ref.*v6. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.4.3.3 The relief valves, including the S/RV, are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the relief valve operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TESTs in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and LCO 3.3.6.3, "Relief Valve Instrumentation," overlap this SR to provide complete testing of the safety function.
The 24 month 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 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation since the valves are individually tested in accordance with SR 3.4.3.2.
(continued)
Dresden 2 and 3                    B 3.4.3-7                        Revision 43
 
Safety and Relief Valves B 3.4.3 BASES  (continued)
REFERENCES        1. UFSAR, Section 5.2.2.
: 2. UFSAR, Section 15.2.3.1.
: 3. UFSAR, Section 15.2.2.1.
: 4. UFSAR, Chapter 15.
              *j%    ASME Code for Operation and Maintenance of Nuclear I
Power Plants.
Dresden 2 and 3                  B 3.4.3-8                      Revision 43
 
ECCS-Operating B 3.5.1 BASES ACTIONS        B.1 (continued)
If a LPCI subsystem is inoperable for reasons other than Condition A or a CS subsystem is inoperable, the inoperable low pressure ECCS injection/spray subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 10) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).
c-1 If one LPCI pump in each subsystem is inoperable, one LPCI pump must be restored to OPERABLE status within 7 days.        In this Condition, the remaining OPERABLE ECCS subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced because a single failure in one of the remaining OPERABLE ECCS.subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is based on a reliability study (Ref. 10) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service.      The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).
          ~>
If two LPCI subsystems are inoperable for reasons other than Condition C, one inoperable subsystem must be restored to OPERABLE status within 72 hours. In this Condition,  the (continued)
Dresden 2 and 3                  B 3.5.1-7                        Revision 21
 
ECCS-Operating B 3.5.1 BASES ACTIONS      FE7 ---    _    (continued) remaining OPERABLE CS subsystems provide adequate core cooling during a LOCA.        However, overall ECCS reliability is reduced, because a single failure in one of the remaining CS subsystems, concurrent with a LOCA, may result in ECCS not being able to perform its intended safety function.      The 72 hour Completion Time is based on a reliability study cited in Reference 10 that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service.          The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowable repair times (i.e., Completion Times).
F.1 -andF.4 EL    a~~d [.2 E        If any Required Action and associated Completion Time of Condition4A,        -,,o    is not 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.
IG-and    1F.I anid r.2 If the HPCI System is inoperable and the IC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days.          In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS.        Also, the IC System will automatically provide core cooling at most reactor operating pressures.      Verification of IC OPERABILITY is therefore required immediately when HPCI is inoperable.          This may be performed as an administrative check by examining logs or other information to determine if IC is out of service for maintenance or other reasons.          It does not mean to perform (continued)
Dresden 2 and 3                            B 3.5.1-8                          Revision 21
 
ECCS-Operati ng B 3.5.1 BASES ACTIONS  FG.landG.21 [.I *d F.?    (continued) the Surveillances needed to demonstrate the OPERABILITY of the IC System. If the OPERABILITY of the IC System cannot be verified, however, Condition I must be immediately entered. In the event of component failures concurrent with a design basis LOCA, there is a potential, depending on the specific failures, that the minimum required ECCS equipment will not be available. A 14 day Completion Time is based on a reliability study cited in Reference 10 and has been found to be acceptable through operating experience.
The LCO requires five ADS valves to be OPERABLE in order to provide the ADS function. With one ADS valve out of service, the overall reliability of the ADS is reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability.
Therefore, operation is only allowed for a limited time.
The 14 day Completion Time is based on a reliability study cited in Reference 10 and has been found to be acceptable through operating experience.
I    d 721 11.1 and 1.
If apny Required Actien and assceiated Cempletion Time of CEIditio;  F or G is not met, or if two or more required ADS valves are inoperable, the plant must be brought to a condition 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 reactor steam dome pressure reduced to S 150 psig 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.
(continued)
Dresden 2 and 3                        B 3.5.1-9                        Revision 21
 
ECCS-Operating B 3.5.1 BASES ACTIONS              F--r (continued)
When multiple ECCS subsystems are inoperable, as stated in Conditionvz, the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
SURVEILLANCE    SR  3.5.1.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand.      This will also prevent a water hammer following an ECCS initiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points. The 31 day Frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience.
SR  3.5.1.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these 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 (continued)
Dresden 2 and 3                  B 3.5.1-10                        Revision 21
 
ECCS-Operati ng B 3.5.1 BASES REFERENCES      5. UFSAR,  Section 15.6.4.
(continued)
: 6. UFSAR,  Section 15.6.5.
: 7. 10 CFR 50,  Appendix K.
: 8. UFSAR,  Section 6.3.3
: 9. 10 CFR 50.46.
: 10. Memorandum from R. L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
Dresden 2 and 3                B 3.5.1-18                      Revision  18
 
IC System B 3.5.3 BASES ACTIONS          A.1 and A.2 (continued)
If the IC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is immediately verified to. be OPERABLE, the IC System must be restored to OPERABLE status within 14 days.          In this Condition, loss of the IC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high pressure system assumed to function during a loss of coolant accident (LOCA). OPERABILITY of HPCI is therefore verified immediately when the IC System is inoperable.        This may be performed as an administrative check, by examining logs or other information, to determine if HPCI is out of service for maintenance or other reasons.        It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the HPCI System.        If the OPERABILITY of the HPCI System cannot be immediately verified, however, Condition B must be immediately entered.        For transients and certain abnormal events with no LOCA, IC (as opposed to HPCI) is an acceptable source of core cooling which also limits the loss of the RPV water level.        Therefore, a limited time is allowed to restore the inoperable IC to OPERABLE status.
The 14 day Completion Time is based on a reliability study (Ref. 2) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (AOTs). Because of similar functions of HPCI and IC, the AOTs (i.e., Completion Times) determined for HPCI are also applied to IC.
B.1 If the IC System cannot be restored to OPERABLE status overallplant  within the associated Completion Time, or if the HPCI System riskis        is simultaneously io    rable, the plant must be brought to a minimized. condition in which the"C      *e5  met* apply,    To achieve this status,  the plant must be brought to at least MODE 3 within 12 hours and Peaetep steaffl defmoe presc redu        cod to (continued)
Dresden 2 and 3                    B 3.5.3-3                            Revision 21
 
IC System B 3.5.3 BASES ACTIONS            I.2 B..-an4        (continued)    l    a 15i psig within 36 hours. ;The allowed Completion Time/        l
                ,ape reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE    SR    3.5.3.1 REQUIREMENTS This SR verifies the water volume and temperature in the shell side of the IC to be sufficient for proper operation.
Based on a scram from 3016 MWt (102% RTP), a minimum water level of 6 feet at a temperature of
* 210&deg;F in the condenser provides sufficient decay heat removal capability for 20 minutes of operation without makeup water.      The volume and temperature allow sufficient time for the operator to provide makeup to the condenser.
The 24 hour Frequency is based on operating experience related to the trending of the parameter variations during normal operation.
SR    3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves in the IC flow path provides assurance that the proper flow path will exist for IC operation.        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 potentially being mispositioned are in the correct position.      This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The 31 day Frequency of this SR was derived from the Inservice Testing Program requirements for performing valve testing at least once every 92 days.      The Frequency of (continued)
Dresden 2 and 3                    B 3.5.3-4                        Revision 21
 
IC System B 3.5.3 BASES SURVEILLANCE    SR  3.5.3.4  (continued)
REQUIREMENTS must be available to perform this test.      Therefore, sufficient time is allowed after adequate pressure and flow are achieved to perform the test. Adequate steam pressure and flow is represented by reactor power greater than 60%.
Reactor startup is allowed prior to performing the heat removal capability test, provided an engineering evaluation has been performed which demonstrates reasonable assurance of the IC System's design heat removal capability.
Therefore, SR 3.5.3.4 is modified by a Note that states the Surveillance is not required to be performed until 12 hours after reactor power is adequate to perform the test. The 12 hours allowed for performing the heat removal capability test, after the required power level is reached, is sufficient to achieve stable conditions for testing and provides reasonable time to complete the SR.
As described in Reference A, if one or more of the IC System condenser tubes are plugged during maintenance and testing, an engineering evaluation shall be performed to assure that the required IC System decay heat removal capability is available with margin and the heat removal capability of the IC System shall be confirmed during power operation by performing SR 3.5.3.4 once the necessary reactor operating conditions are reached.      The reactor will not be operated in Mode 1 without some assurance that the necessary IC System safety function can be met with the plugged tube(s).
The 60 month Frequency is based on engineering judgement, and has been shown to be acceptable through operating experience.
REFERENCES      1. UFSAR,  Section 5.4.6.
: 2. Memorandum from R. L. Baer (NRC) to V. Stello, Jr.
(NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
: 3. Safety Evaluation transmitted by letter from L. W.
Rossbach (NRC) to 0. D. Kingsley (Exelon), "Dresden Nuclear Power Station, Units 2 and 3 - Issuance of Amendments for Extended Power Uprate," dated December 21, 2001.
                          >                                          (continued)
Dresden 2 and 3                    B 3.5.3-6                        Revision 28
 
IC System B 3.5.3 BASES REFERENCES      1A. Safety Evaluation transmitted by letter from (continued)      M. Banerjee (NRC)  to C. M. Crane (Exelon), "Dresden Nuclear Power Station, Units 2 and 3 - Issuance of Amendments RE: Isolation Condenser Surveillance Requirements," dated August 25, 2005.
Dresden 2 and 3                B 3.5.3-7                        Revision 28
 
Low Set Relief Valves B 3.6.1.6 BASES APPLICABLE      higher loads, are avoided.          The safety analysis demonstrates SAFETY ANALYSES that the low set relief functions to avoid the induced (continued) thrust loads on the relief valve discharge line resulting from "subsequent actuations" of the relief valve during Design Basis Accidents (DBAs).          Even though two low set relief valves are specified, only one low set relief valve is required to operate in any DBA analysis.
Low set relief valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO            Two low set relief valves are required to be OPERABLE to satisfy the assumptions of the safety analyses (Ref. 1).
The requirements of this LCO are applicable to the mechanical and electrical capability of the low set relief valves to function for controlling the opening and closing of the low set relief valves.
APPLICABILITY  In MODES 1, 2, and 3, an event could cause pressurization of the reactor and opening of relief valves.              In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES.        Therefore, maintaining the low set relief valves OPERABLE is not required in MODE 4 or 5.
ACTIONS        A.1 With one low set relief valve inoperable, the remaining OPERABLE low set relief valve is adequate to perform the designed function.          However, the overall reliability is reduced.        The 14 day Completion Time takes into account the redundant capability afforded by the remaining low set relief valve and the low probability of an event occurring during this period in which the remaining low set relief valve capability would be required.
B. 1 --aj+E-*
If two low        *t rel ief vaIve! ere i,,  ..... e o, f t - an inoperable low set relief valve cannot be restored to OPERABLE status within the required Completion Time, the (continued)
Dresden 2 and 3                      B 3 .6 .1 .6-2                          Revision 0
 
Low Set Relief Valves B 3.6.1.6 BASES ACTIONS          B.1I ad B.2    (continued)                                        plant riski is minimized.
F -loverall plant must be brought to a MODE in which the LCO does not
                -a#p4-y. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MO,,[ a ,,ihin
                --B6 4ebt--.4/The allowed Completion Timeg-.a-e/'reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems..
SURVEILLANCE      SR  3.6.1.6.1 REQUIREMENTS The actuator of each of the Electromatic low set relief valves (ERVs) is stroked to verify that the pilot valve strokes when manually actuated.      For the ERVs, the actuator test is performed with the pilot valve actuator mounted in its normal position. This will allow testing of the manual actuation electrical circuitry, solenoid actuator, pilot operating lever, and pilot plunger.      This test will verify pilot valve movement.      However, since this test is performed prior to establishing the reactor pressure needed to overcome main valve closure spring force, the main valve will not stroke during the test.
This SR, together with the valve testing performed as required by the ASME Code for pressure relieving devices (ASME OM Code - 1998 through 2000 Addenda), verify the capability of each relief valve to perform its function.
Valve testing will be performed at a steam test facility, where the valve (i.e., main valve and pilot valve) and an actuator representative of the actuator used at the plant will be installed on a steam header in the same orientation as the plant installation.      The test conditions in the test facility will be similar to those in the plant installation, including ambient temperature, valve insulation, and steam conditions. The valve will then be leak tested, functionally tested to ensure the valve is capable of opening and closing (including stroke time), and leak tested a final time. Valve seat tightness will be verified by a cold bar test, and if not free of fog, leakage will be measured and verified to be below design limits.        In addition, for the safety mode of S/RVs, an as-found setpoint verification and as-found leak check are performed, followed (continued)
Dresden 2 and 3                    B 3.6.1.6-3                        Rev is ion 18
 
Low Set Relief Valves B 3.6.1.6 BASES SURVEILLANCE    SR  3.6.1.6.1    (continued)
REQUIREMENTS by verification of set pressure, and delay.      The valve will then be shipped to the plant without any disassembly or alteration of the main valve or pilot valve components.
The combination of the valve testing and the valve actuator testing provide a complete check of the capability of the valves to open and close, such that full functionality is demonstrated through overlapping tests, without cycling the valves.
The 24 month Frequency was based on the relief valve tests required by the ASME Code (Ref.Y/).      The Frequency of 24 months ensures that each solenoid for each low set relief valve is tested. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.      Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.6.1.6.2 The low set relief designated relief valves are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the low set relief function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.3, "Low Set Relief Valve Instrumentation," overlaps this SR to provide complete testing of the safety function.
The 24 month 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 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents a reactor pressure vessel pressure blowdown.
(continued)
Dresden 2 and 3                    B 3.6.1.6-4                      Revision 43
 
Low Set Relief Valves B 3.6.1.6 BASES  (continued)
REFERENCES        1. UFSAR, Section 6.2.1.3.5.3.
ASME Code for Operation and Maintenance of Nuclear FI Power Plants.
Dresden 2 and 3                B 3.6.1.6-5                      Revision 43
 
Reactor Building-to-Suppression  Chamber Vacuum Breakers B 3.6.1.7 BASES  (continued)
ACTIONS            A Note has been added to provide clarification that, for the purpose of this LCO, separate Condition entry is allowed for each reactor building-to-suppression chamber vacuum breaker line.
A.1 With one or more lines with one vacuum breaker not closed, the leak tight primary containment boundary may be threatened. Therefore, the inoperable vacuum breakers must be restored to OPERABLE status or the open vacuum breaker closed within 7 days. The 7 day Completion Time takes into account the redundancy afforded by the remaining breakers, the fact that the OPERABLE breaker in each of the lines is closed, and the low probability of an event occurring that would require the vacuum breakers to be OPERABLE during this period.
With one or more lines with two vacuum breakers not closed, primary containment integrity is not maintained. Therefore, one open vacuum breaker must be closed within 1 hour.      This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, "Primary Containment," which requires that primary containment be restored to OPERABLE status within 1 hour.
With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary is intact. The ability to mitigate an event that causes a containment depressurization is threatened, however, if both vacuum breakers in at least one vacuum breaker penetration are not OPERABLE. Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 7 days. This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being maintained.
(continued)
Dresden 2 and 3                    B 3.6.1.7-4                        Revision 0
 
Reactor Building-to-Suppression  Chamber Vacuum Breakers B 3.6.1.7 BASES ACTIONS (continued)
With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact.
However, in the event of a containment depressurization, the function of the vacuum breakers is lost.        Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour. This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, which requires that primary containment be restored to OPERABLE status within 1 hour.
1 an.                                    ime of Condition A, 8,or El If any Required Action and associated Completion t4-ime- can not 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.
SURVEILLANCE    SR  3.6.1.7.1 REQUIREMENTS Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker position. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.
Two Notes are added to this SR. The first    Note allows reactor-to-suppression chamber vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR. These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.        The second Note is included to clarify that vacuum breakers open due to an actual differential pressure are not considered as failing this SR.
(continued)
Dresden 2 and 3                  B 3.6.1.7-5                                Revision 0
 
Reactor Buil ding-to-Suppression    Chamber Vacuum Breakers B 3.6.1.7 BASES SURVEILLANCE      SR    3,6.1.7.2 REQUIREMENTS (continued)  Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position.      This ensures that the safety analysis assumptions are valid. The 92 day Frequency of this SR was developed based upon Inservice Testing Program requirements to perform valve testing at least once every 92 days.
SR    3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of
                  <_ 0.5 psid is valid. The 24 month 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.      For this plant, the 24 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES      1  . UFSAR,  Section 6.2.1.2.4.
Dresden 2 and 3                    B 3.6. 1 .7-6                        Revision 0
 
Suppression Chamber-to-Drywell    Vacuum Breakers B 3.6.1.8 BASES ACTIONS        A.1    (continued) would not function as designed during an event that depressurized the drywell), the remaining eight OPERABLE vacuum breakers are capable of providing the vacuum relief function.      However, overall system reliability is reduced because a single failure in one of the remaining vacuum breakers could result in an excessive suppression chamber-to-drywell differential pressure during a DBA.          Therefore, with one of the nine required vacuum breakers inoperable, 72 hours is allowed to restore at least one of the inoperable vacuum breakers to OPERABLE status so that plant conditions are consistent with those assumed for the design basis analysis.      The 72 hour Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate.
With one vacuum breaker not closed,        communication between the drywell and suppression chamber airspace exists, and, as a result, there is the potential for primary containment overpressurization due to this bypass leakage if a LOCA were to occur.      Therefore, the open vacuum breaker must be closed. A short time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment.        The required 4 hour Completion Time is considered adequate to safely plan and complete the manual cycling necessary to close the vacuum breaker which may be located in a high radiation area.
                  .Coo1                D21                                      Cand 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 ful~l power conditions in an orderly manner and without challenging plant systems.
(continued)
Dresden 2 and 3                    B 3. 6 .1. 8- 4                      Revision 0
 
Suppression Chamber-to-Drywell  Vacuum Breakers B 3.6.1.8 BASES SURVEILLANCE    SR  3.6.1.8.3  (continued)
REQUIREMENTS the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The 24 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES      1. UFSAR, Section 6.2.1.2.4.2.
2,. UFSAR, Table 6.2-1.
Dresden 2 and 3                B 3.6.1.8-6                        Revision  0
 
Suppression  Pool Cooling B 3.6.2.3 BASES
_                  er-l ns ACTIONS (continued)
With two suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours.      In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function.      The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the suppression pool cooling subsystems to operate.
I5.1 a'ndZ21                                        of Condition__
C]
e.1    ald C.2T If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the [CO 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.
SURVEILLANCE    SR    3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual and power operated valves in the suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation.      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 is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.      This is acceptable since the suppression pool cooling mode is manually initiated.        This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.        This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an (continued)
Dresden 2 and 3                    B 3.6.2.3-3                          Revision 0
 
Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE        SR  3.6.2.3.1  (continued)
REQUIREMENTS event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR  3.6.2.3.2 Verifying that each required LPCI pump develops a flow rate
                    &#x17d; 5000 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment peak pressure and temperature can be maintained below the design limits during a DBA (Ref. 1). The flow is a normal test of centrifugal pump performance required by ASME Code (Ref.,/). This test      I lI confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice tests confirm component OPERABILITY, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.
REFERENCES          1. UFSAR,  Section 6.2.
rpnn . ASME Code for Operation and Maintenance of Nuclear Power Plants.I Dresden 2 and 3                      B 3.6.2.3-4                      Revision 43
 
Suppression Pool Spray B 3.6.2.4 BASES ACTIONS        A.1    (continued)
However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation capability.        The 7 day Completion Time was chosen in light of the redundant suppression pool spray capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
B. I With both suppression pool spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 8 hours.      In this condition, there is a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to reduce pressure in the primary containment are available.
C. I If any Required Action and associated Completion Time cannot overallplant    be met, the plant must be brought to a MODE in which the 1O-&#xfd; riskis      -*  does not app4y      To achieve this status, the plant must be minimized.      brought o at least MODE 3 within 12 hours and  . P..th DE 4 w. in 36 h-ours-.v The allowed Completion Time      Kreasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE    SR    3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual and power operated valves in the suppression pool spray mode flow path provides assurance that the proper flow path exists for system operation.      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 is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the (continued)
Dresden 2 and 3                    B 3.6.2.4-3                          Revi sion 0
 
Suppression Pool Spray B 3.6.2.4 BASES SURVEILLANCE    SR  3.6.2.4.1  (continued)
REQUIREMENTS accident analysis. This is acceptable since the suppression pool spray mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR  3.6.2.4.2 This Surveillance is performed every 10 years to verify that the spray nozzles are not obstructed and that spray flow will be provided when required. The 10 year Frequency is adequate to detect degradation in performance due to the passive nozzle design and has been shown to be acceptable through operating experience.
REFERENCES      1    UFSAR,  Section 6.2.
Dresden 2 and 3                  B 3.6.2.4-4                        Revi sion 0
 
Secondary Containment B 3.6.4.1 BASES  (continued)
ACTIONS            A.1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours. The 4 hour Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3.      This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.
overall plant risk is B.1      D.                                                    Iminimized.
If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCD9 d        n.
                                                                    . t ipply.V To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 with,,,      6 hour3. The      L allowed Completion Time7I-e-  /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.1 and C.2 Movement of recently irradiated fuel assemblies in the secondary containment and OPDRVs can be postulated to cause significant fission product release to the secondary containment. In such 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 inoperable.
Suspension of this activity shall not preclude completing an action that involves moving a component to a safe position.
Also, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.        Actions must continue until OPDRVs are suspended.
Required Action C.1 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 (continued)
Dresden 2 and 3                      B 3.6.4.1-3                          Revision 31
 
Secondary Containment B 3.6.4.1 BASES SURVEILLANCE    SR  3.6.4.1.3  (continued)
REQUIREMENTS addition to the requirements of LCO 3.6.4.3, either SGT subsystem will perform this test.      The inoperability of the SGT System does not necessarily constitute a failure of this Surveillance relative to secondary containment OPERABILITY.
Operating experience has shown the secondary containment boundary usually passes the Surveillance when performed at the 24 month Frequency.      Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES        . UFSAR, Section 15.6.5.
Dresden 2 and 3                B 3 .6.4 .1-6                        Revision 31
 
SGT System B 3.6.4.3 BASES APPLICABILITY    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 operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the SGT 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        A.I 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.
B.1I If the SGT subsystem cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, or 3, the overallplant  plant must be brought to a MODE in which the LCD does not nskis          ap-p-y. To achieve this status, the plant must be brought to minimized,    at least MQDE 3 within 12 hours and to MODE I    .ithin        is 36 ,,oirs.v The allowed Completion TimeX -eFX*reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
I C.1. C.2.1. and C.2.2 During movement of recently irradiated fuel assemblies, in
                                                                                  )
the secondary containment or during OPDRVs, when Required (continued)
Dresden 2 and 3                    B 3.6.4.3-3                      Revision 31
 
SGT System B 3.6.4.3 BASES ACTIONS            E.1      d    -smnmized                                        overall plant risk (continued)                                                                    I                  I 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          "d
                --eap-p-y-. To achieve this status, the plant must be brought to Iat              least 0DE 3 within 12 hours and to MODE 4 within J 3 6horsa.-- The allowed Completion Time/ a.e&#xfd;'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,I and F.2 When two SGT subsystems are inoperable, if applicable, I
movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended.        Suspension of        I this activity shall not preclude completion of movement of a component to a safe position. Also, if applicable, action must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release.        Actions must continue until OPDRVs are suspended.
Required Action F.1 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.
(continued)
Dresden 2 and 3                      B 3.6.4.3-5                        Revision 31
 
SGT System B 3.6.4.3 BASES  (continued)
SURVEILLANCE        SR    3.6.4.3.1 REQUIREMENTS Operating (from the control room using the manual initiation switch) each SGT subsystem for &#x17d; 10 continuous hours 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. Operation with the heaters on (automatic heater cycling to maintain temperature) for &#x17d; 10 continuous hours every 31 days eliminates moisture on the adsorbers and HEPA filters. The 31 day Frequency was developed in consideration of the known reliability of fan motors and controls and the redundancy available in the system.
SR  3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The SGT System filter test. are in accordance with Regulatory Guide 1.52 (Ref. A). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.
SR  3.6.4.3.3 This SR verifies that each SGT subsystem starts on receipt of an actual or simulated initiation signal.      While this Surveillance can be performed with the reactor at power, operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.2, "Secondary Containment Isolation Instrumentation," overlaps this SR to provide complete testing of the safety function.
Therefore, the Frequency was found to be acceptable from a reliability standpoint.
(continued)
Dresden 2 and 3                      B 3.6.4.3-6                        Revision 31
 
SGT System B 3.6.4.3 BASES  (continued)
REFERENCES          1. UFSAR, Section 3.1.2.4.12.
: 2. UFSAR, Section 6.5.3.2.
: 3. UFSAR, Section 15.6.5.
f]/. Regulatory Guide 1.52,  Rev. 2.
Dresden 2 and 3                  B 3.6.4.3-7          Revision 31f"
 
CCSW System B 3.7.1 BASES ACTIONS        A.1  (continued) failure in the OPERABLE subsystem could result in reduced CCSW capability. The 30 day Completion Time is based on the remaining CCSW heat removal capability and the low probability of a DBA with concurrent worst case single failure.
B._1 With one CCSW pump inoperable in each subsystem, if no additional failures occur in the CCSW System, then the remaining OPERABLE pumps and flow paths provide adequate heat removal capacity for long term containment cooling to maintain safe shutdown conditions. One inoperable pump is required to be restored to OPERABLE status within 7 days.
The 7 day Completion Time for restoring one inoperable CCSW pump to OPERABLE status is based on engineering judgment, considering the level of redundancy provided and the low probability of an event occurring requiring CCSW during this period.
C.I Required Action C.1 is intended to handle the inoperability of one CCSW subsystem for reasons other than Condition A.
The Completion Time of 7 days is allowed to restore the CCSW subsystem to OPERABLE status. With the unit in this condition, the remaining OPERABLE CCSW subsystem is adequate to perform the CCSW heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE CCSW subsystem could result in loss of CCSW function. The Completion Time is based on the redundant CCSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring CCSW during this period.
With both CCSW subsystems inoperable (e.g., both subsystems with inoperable pumps(s) or flow paths, or one subsystem with an inoperable pump and one subsystem with an inoperable (continued)
Dresden 2 and 3                  B 3.7.1-4                          Revision 0
 
CCSW System B 3.7.1 BASES ACTIONS        E1-B--_I  (continued) flow path), the CCSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours. The 8 hour Completion Time for restoring one CCSW subsystem to OPERABLE status, is based on the Completion Times provided for the suppression pool cooling and spray functions.
[.1 and [.2 If any Required Action and associated Completion Time of lEndtion Isl            Conditicns A, B, C, or D arerNot met, the unit must be placed in a MODE in which the LCO does not apply.      To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours.      The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR  3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual and power operated valve in each CCSW subsystem flow path provides assurance that the proper flow paths will exist for CCSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing.      A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the CCSW System is a manually initiated system.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.      This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
(continued)
Dresden 2 and 3                      B 3. 7. 1-5                        Revision  0
 
CCSW System B 3.7.1 BASES  (continued)
REFERENCES          1. UFSAR, Section 9.2.1.
: 2. UFSAR, Section 9.2.5.
: 3. UFSAR, Section 9.2.2.
: 4. UFSAR, Section 2.4.8.
: 5. UFSAR, Section 6.2.2.
: 6. UFSAR, Section 6.2.1.3.2.2.
UFSAR, Table 6.2-3.
Dresden 2 and 3                    B 3.7.1-6      Revision 45
 
CREV System B 3.7.4 BASES ACTIONS        B.1,    B.2,  affd B.3  ICAC.2, andU.30 (continued)
If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable.          Actions must be taken to restore an OPERABLE CRE boundary within 90 days.
During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke.        Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and the CRE occupants are protected from hazardous chemicals and smoke.            These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry in intentional or unintentional.
The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions.          The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA.      In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
ID.1 andD.2 ]
In MODE 1, 2, or 3, if the i,                    .
                                                        .p.r.bl GRE. Syste.m. or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE (continued)
Dresden 2 and 3                        B 3.7.4-5                            Revision 42
 
CREV System B 3.7.4 BASES ACTIONS        C.1 and C.2 FD.landD.2j (continued) that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
D.i. and  .2  FE.landE.27 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 ConditionVX are modified by      iJ1 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 during 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 isolation/pressurization mode of operation. This places the unit in a condition that minimizes the accident risk.
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 must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.
(continued)
Dresden 2 and 3                    B 3.7.4-6                        Revision 42
 
CREV System B 3.7.4 BASES SURVEILLANCE    SR  3.7.4.4    (continued)
REQUIREMENTS The CRE is considered habitable when the radiological dose to the CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.      When unfiltered air leakage is greater than the assumed flow Wi        rate, Condition'&#xfd;K must be entered. Required ActionA/-'.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident.      Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3 (Ref.
: 4) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6).      These compensatory measures may P71  also be used as mitigating actions as required by Required Action'TB.2. Temporary analytical methods may also beVksed as compensatory measures to restore OPERABILITY (Ref.AI.
Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
REFERENCES      1.      UFSAR,  Section 6.4.
: 2.      UFSAR,  Section 9.4.
: 3.      UFSAR,  Section 15.6.5.
: 4.      Regulatory Guide 1.52, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," Revision 2, March 1978.
: 5.      Regulatory Guide 1.196.
: 6.      UFSAR,  Section 9.1.4.3.2.
(continued)
Dresden 2 and 3                    B 3.7.4-8                        Revision 42
 
CREV System B 3.7.4 BASES REFERENCES (continued)
: 7. NEI 99-03,  "Control Room Habitability Assessment,"
June 2001.
9-1*X. NRC Safety Evaluation Report for the Holtec International HI-Storm 100 Storage System (Docket Number 72-1014, Certificate Number 1014, Amendment 2).
F&sect;-liY. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30,2004,    "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."  (ADAMS Accession No. ML040300694).
Dresden 2 and 3                  B 3.7.4-9                        Revision 42
 
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 pressureand temperature limitations in these MODES.          Therefore, maintaining the Control Room Emergency Ventilation AC System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
: a. During movement of recently irradiated fuel assemblies in the secondary containment; and
: b. During operations with a potential        for draining the reactor vessel (OPDRVs).
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          A.1 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.
B IaH
                    !. .  *.2-ov-eralris 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 minimizesr'risk.          To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and i        HODE 4 within 36 hourz.)VThe allowed
[*i Completion Time/-6-e-Vreasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
Dresden 2 and 3                          B 3.7.5-3                        Revision 31
 
Control  Room Emergency Ventilation AC System B 3.7.5 BASES  (continued)
REFERENCES1        UFSAR, Section  6.4.
Dresden  2 and 3                B 3.7.5-5                          Revi si on 6
 
Main Condenser Offgas B 3.7.6 BASES      (continued)
APPLICABILITY          The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System.        This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation.        In MODES 4 and 5, main steam is not being exhausted to the main condenser and the requirements are not applicable.
ACTIONS                A.1 If the offgas radioactivity rate limit is exceeded, 72 hours is allowed to restore the gross gamma activity rate to within the limit. The 72 hour Completion Time is reasonable, based on engineering judgment, the time required to complete the Required Action, the large margins associated with permissible dose and exposure limits, and the low probability of a Main Condenser Offgas System rupture.
B.1. B.2. B.3.1.
                                      .. and    3..2 If the gross gamma activity rate is not restored to within the limits in the associated Completion Time, all main steam lines or the SJAE must be isolated.      This isolates the Main Condenser Offgas System from significant sources of radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed, and at least one main steam line drain valve in each drain line is closed.      The 12 hour Completion Time is reasonable, based on operating experience, to perform the actions from full power conditions in an orderly manner and without challenging unit systems.
overall plan trisk    An alternative to Required Actions B.1 and B.2 is      to placeL
: d. I  the unit in a MODE in whi ch th-'eVLCO does no      pl  . To is minimized achieve this status, the unit must be placed in at leqt MODE 3 within 12 hours aol.i. MAOD. 4 4.tHin  .36h. rF. The il      allowed Completion Time7 -*ereasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
Dresden 2 and 3                          B 3.7.6-2                            Revision 0
 
Main Condenser Offgas B 3.7.6 BASES  (continued)
SURVEILLANCE        SR  3.7.6.1 REQUIREMENTS This SR, on a 31 day Frequency, requires an isotopic analysis of a representative offgas sample (taken at the recombiner outlet or the SJAE outlet if the recombiner is bypassed) to ensure that the required limits are satisfied.
The noble gases to be sampled are Xe-133, Xe-135, Xe-138, Kr-85M, Kr-87, and Kr-88.      If the measured rate of radioactivity increases significantly as indicated by the main condenser air ejector noble gas activity monitor (by
                    &#x17d; 50% after correcting for expected increases due to changes in THERMAL POWER), an isotopic analysis is also performed within 4 hours after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas, and is acceptable, based on operating experience.
This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.        Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.
REFERENCES          1. Letter E-DAS-015-O0  from D.A. Studley (Scientech-NUS) to T. Leffler (ComEd),    dated January 24, 2000.
: 2. 10 CFR 50.67.
Dresden  2 and 3                      B 3.7.6-3                            Revision 31
 
AC Sources-Operating B 3.8.1 BASES ACTIONS          E.1 (continued)
With two required DGs inoperable, there is no more than one remaining standby AC source.          Thus, with an assumed loss of offsite electrical power, sufficient standby AC sources may not be available to power the minimum required ESF functions.        Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown.          (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.)          Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted.          The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.
According to Regulatory Guide 1.93 (Ref. 6), with both DGs inoperable, operation may continue for a period that should not exceed 2 hours.          The Completion Time assumes complete loss of onsite (DG) AC capability to power the minimum loads needed to respond to analyzed events.
F.1        ..    .
If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply.        To achieve this status, the unit must be brought to at levt MODE 3 within 12 hours and to MODE -4
[Insert.th;. 36 h    . The allowed Completion Timee -    <
reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
G.1 Condition G corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost.        At this severely degraded level, any further losses in the AC electrical power system will cause a loss of (continued)
Dresden  2 and 3                        B 3.8.1-16                        Revision 21
 
AC Sources-Operating B 3.8.1 BASES ACTIONS        G.1  (continued) function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.
SURVEILLANCE    The AC sources are designed to permit inspection and REQUIREMENTS    testing of all important areas and features, especially those that have a standby fun tion, in accordance with UFSAR, Section 3.1.2.2.9 (Ref./").      Periodic component tests U are supplemented by extensive functional tests during refueling outages (under simulated accident conditions).
The SRs for demonstrating the OPERABILITY of the DGs are consj~tent with the recommendations of Regulatory Guide (RefRe), Regulat ry Guide 1.108 (Ref.A), and Regulatory Guide 1.137 R**'),        as addressed in the UFSAR.
11F_
The Surveillances are modified by two Notes to clearly identify how the Surveillances apply to the given unit and the opposite unit AC electrical power sources.      Note 1 states that SR 3.8.1.1 through 3.8.1.20 are applicable only to the given unit AC electrical power sources and Note 2 states that SR 3.8..1.21 is applicable to the opposite unit AC electrical power sources. These Notes are necessary since the opposite unit AC electrical power sources are not required to meet all of the requirements of the given unit AC electrical power sources (e.g., the opposite unit's DG is not required to start on the opposite unit's ECCS initiation signal to support the OPERABILITY of the given unit).
Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable.      The minimum steady state output voltage of 3952 V is 90% of the nominal 4160 V output voltaoe8      This value, which is rEl  specified in ANSI C84.1 (Ref. %*), allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating.      The specified maximum steady state output voltage of 4368 V is within the maximum operating voltage of 110% specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages.      The (continued)
Dresden 2 and 3                  B 3.8.1-17                        Revision 45
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    specified minimum and maximum frequencies of the DG are REQUIREMENTS    58.8 Hz and 61.2 Hz, respectively. These values are equal (continued)  to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Regulatory Guide 1.9 (Ref./).
SR  3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained.
The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.
SR  3.8.1.2 and SR  3.8.1.8 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.
To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note 1 for SR 3.8.1.2 and Note 1 for SR 3.8.1.8) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup prior to loading.
For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.
In order to reduce stress and wear on diesel engines, the manufacturer has recommended a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading. These start procedures are the intent of Note 2 of SR 3.8.1.2.
(continued)
Dresden 2 and 3                  B 3.8.1-18                        Revision 45
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.2 and SR  3.8.1.8    (continued)
REQUIREMENTS SR 3.8.1.8 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 13 seconds.      The 13 second start requirement supports the assumptions in the design basis LOCA analysis of UFSAR, Section 6.3 (RefY&#x17d;*.          The          13 13 second start requirement is not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2), when a modified start procedure as described above is used. If a modified start is not used, the 13 second start requirement of SR 3.8.1.8 applies.
Since SR 3.8.1.8 does require a 13 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.
In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved.        The voltage and frequency limits are normally achieved within 13 seconds. The time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
To minimize testing of the common DG, Note 3 of SR 3.8.1.2 and Note 2 of SR 3.8.1.8 allow a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.      This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. However, to the extent practicable, the tests should be alternated between units.      If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref'/5.      The 184 day Frequency for SR 3.8.1.8 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 5).      These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
(continued)
Dresden 2 and 3                  B 3.8.1-19                            Revision 21
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.3 REQUIREMENTS (continued) This Surveillance verifies that the DGs are capable of synchronizing and accepting a load approximately equivalent to that corresponding to the continuous rating. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0 when running synchronized with the grid. The 0.8 power factor value is the design rating of the machine at a particular kVA. The 1.0 power factor value is an operational condition where the reactive power component is zero, which minimizes the reactive heating of the generator. Operating the generator at a power factor between 0.8 lagging and 1.0 avoids adverse conditions associated with underexciting the generator and more closely represents the generator operating requirements when performing its safety function (running isolated on its associated 4160 V ESS bus). The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.
The 31 day Frequency for this Surveillance is    consistent with Regulatory Guide 1.9 (Ref./).
I*1 Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.
Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit do not invalidate the test.
Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.
(continued)
Dresden 2 and 3                  B 3.8.1-20                        Revision 21
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.5 and SR  3.8.1.7  (continued)
REQUIREMENTS environment in order to survive.      Removal of water from the fuel oil day tank once every 31 days eliminates the necessary environment for bacterial survival.      This is accomplished by draining a portion of the contents from the bottom of the day tank. Checking for and removal of any accumulated water from the bulk storage tank once every 92 days also eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system.      The Surveillance Freqqencies are established by Regulatory il          Guide 1.137 (Ref.*f).      This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.
SR  3.8.1.6 This Surveillance demonstrates that each fuel oil transfer pump operates and automatically transfers fuel oil from its associated storage tank to its associated day tank.        It is required to support continuous operation of standby power sources. This Surveillance provides assurance that each fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.
The Frequency for this SR is consistent with the Frequency for testing the DGs in SR 3.8.1.3.      DG operation for SR 3.8.1.3 is normally long enough that fuel oil level in the day tank will be reduced to the point where the fuel oil transfer pump automatically starts to restore fuel oil level by transferring oil from the storage tank.
(continued)
Dresden 2 and 3                  B 3.8.1-22                          Revision 25
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.9 REQUIREMENTS (continued)  Transfer of each 4160 V ESS bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads.      The 24 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
Operating experience has shown that these components usually pass the SR when performed on the 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.8.1.10 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency and while maintaining a specified margin to the overspeed trip. The largest single load for each DG is a service water pump (686 kW). The specified load value conservatively bounds the expected kW rating of the single largest loads under accident conditions. This Surveillance may be accomplished by:
: a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
: b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.
P9-I Consistent with Regulatory Guide 1.9 (Ref.      ), the load rejection test is  acceptable if  the diesel speed does not (continued)
Dresden 2 and 3                  B 3.8. 1-23                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.10  (continued)
REQUIREMENTS exceed the nominal (synchronous) speed plus 75% of the difference between nominal speed and the overspeed trip setpoint, or 115% of nominal speed, whichever is lower.
This corresponds to 66.73 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint.
The time, voltage and frequency tolerances spe ified in this SR are derived from Regulatory Guide 1.9 (Ref.YX) recommendations for response during load sequence intervals.
The 3 seconds specified in SR 3.8.1.10.b is equal to 60% of the 5 second load sequence interval associated with sequencing the ECCS low pressure pumps during an undervoltage on the bus concurrent with a LOCA.      The 4 seconds specified in SR 3.8.1.10.c is equal to 80% of the 5 second load sequence interval associated with sequencing the ECCS low pressure pumps during an undervoltage on the bus concurrent with a LOCA. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG. SR 3.8.1.10.a corresponds to the maximum frequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steady state voltage and frequency values specified to which the system must recover following load rejection. The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize testing of the common DG and allow a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.      This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should  be  considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
(continued)
Dresden 2 and 3                  B 3.8.1-24                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3 .8 .1.11                                  .l REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref.        '), paragraph C.2.2.8, this Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits.      The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions.
This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load.
These acceptance criteria provide DG damage protection.
While the DG is not expected to experience this transient during an event, and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, a load band (90% to 100%) has been specified based on Regulatory Guide 1.9 (Ref.A').
The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by two Notes.      To minimize testing of the common DG, Note 1 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.      This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit.      If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.      Note 2 modifies this Surveillance by stating that momentary transients outside the voltage limit do not invalidate this test.
(continued)
Dresden 2 and 3                  B 3 .8. 1- 25                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.12                                  fl REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 7),
paragraph C.2.2.4, this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG.      It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The DG auto-start and energization of permanently connected loads time of 13 seconds is derived from requirements of the accident analysis for responding to a design basis large break LOCA (Ref. 4-<). The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.
The requirement to verify the connection and power supply of permanently connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.      For instance, a component or system may be out-of-service and closure of its associated breaker during this test may damage the component or system. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing.        For the purpose of this testing, the DGs shall be started from standby conditions, that is, with the engine coolant and lube oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
(continued)
Dresden 2 and 3                  B 3.8.1-26                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.13 REQUIREMENTS (continued) Consistent with Regulatory Guide 1.9 (Ref. 9), paragraph C.2.2.5, this Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (13 seconds) from the design basis actuation signal (LOCA signal). In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved. The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The DG is required to operate for &#x17d; 5 minutes. The 5 minute period provides sufficient time to demonstrate stability.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with the expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
SR  3.8.1.14
                                                            @1 Consistent with Regulatory Guide 1.9 (Ref. /)  paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed and generator differential current) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.
(continued)
Dresden 2 and 3                  B 3.8.1-27                        Revi si on 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.14  (continued)
REQUIREMENTS The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR  3.8.1.15 Regulatory Guide 1.9 (Ref.L'), paragraph C.2.2.9, requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours, 22 hours of which is at a load equivalent to 90%
to 100% of the continuous rating of the DG and 2 hours of which is at a load equivalent to 105% to 110% of the continuous rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
In order to ensure that the DG is tested under load conditions that are as close to design conditions as possible, testing must be performed at a power factor as close to the accident load power factor as practicable.
When synchronized with offsite power, the power factor limit is 5 0.87. This power factor is chosen to bound the actual worst case inductive loading that the DG could experience under design basis accident conditions.
The power factor used for conducting the 24-hour endurance run must consider the effects of bus voltage on connected equipment. Therefore, "practicable" includes a criterion of minimizing potential high bus voltage on the 4 kV buses.
High bus voltage may result in exceeding the manufacturer's tolerances for safety related 4 kV motors and for devices downstream of the 4 kV system (e.g., 480 V devices).
Operating an electric motor above design rating can overexcite the motor, overheat the rotor and reduce its qualified life.
High voltage on the medium voltage buses could result in exceeding the nominal +10% voltage tolerance at the (continued)
Dresden 2 and 3                  B 3.8.1-28                      Revision 38
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.15  (continued)
REQUIREMENTS terminals of low voltage motors due to the boost in the unit substation transformers combined with the likelihood of low transformer loading at the time of the test. During the test, many accident loads would not be running, leading to a minimal voltage drop through the transformer. The transformer tap is selected based on accident loading.      The high terminal voltage could result in overexcitation of the motor. Overexcitation increases the heat rise in the winding, which decreases the qualified life of the motor.
VAR demand is not constant on any power system. The station  I operators do not have instrumentation directly indicating power factor. Control room metering indicates reactive power kVAR).
The 24 month Frequency takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This Surveillance is modified by three Notes. Note 1 states that momentary transients do not invalidate this test. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.
Similarly, momentary power factor transients above the limit do not invalidate the test. Note 2 is provided in recognition that under certain conditions, it is necessary to allow the surveillance to be conducted at a power factor other than the specified limit. During the Surveillance, the DG is normally operated paralleled to the grid, which is not the configuration when the DG is performing its safety function following a loss of offsite power (with or without a LOCA).
Therefore, the power factor shall be maintained as close as practicable to the specified limit while still ensuring that if the DG output breaker were to trip during the Surveillance that the maximum DG winding voltage would not be exceeded.    (Ref. ,14).
To minimize testing of the common DG, Note 3 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.      This is (continued)
Dresden 2 and 3                  B 3.8.1-29                        Revision 34
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.15  (continued)
REQUIREMENTS allowed since the main purpose of the Surveillance can be met by performing the test on either unit.      If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
SR  3.8.1.16 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 13 seconds.      The 13 second time is derived from the requirements of the accident analysi's for responding to a design basis large break LOCA (Ref.Y)4).          In'-L addition, the DG is required to maintain proper      voltage  and frequency limits after steady state is achieved.        The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with the expected fuel cycle lengths.
This SR is modified by three Notes.      Note 1 ensures that the test is performed with the diesel sufficiently hot.        The requirement that the diesel has operated for at least 2 hours at approximately full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.      Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.      To minimize testing of the common DG, Note 3 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
(continued)
Dresden 2 and 3                    B 3.8.1-30                          Revision 34
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.17 REQUIREMENTS (continued)  Consistent with Regulatory Guide 1.9 (Ref. V, paragraph C.2.2.11, this Surveillance ensures that the manual synchronization and load transfer from the DG to the offsite source can be made and that the DG can be returned to ready-to-load status when offsite power is restored. It also ensures that the auto-start logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs.
The DG is considered to be in ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the individual load timers are reset.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR  3.8.1.18 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequence time delay relays. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The -10% load sequence time interval limit ensures that a sufficient time interval exists for the DG to restore frequency and voltage prior to applying the next load. There is no upper limit for the load sequence time interval since, for a single load interval (i.e., the time between two load blocks), the capability of the DG to restore frequency and voltage prior to applying the second load is not negatively affected by a longer than designed load interval, and if there are additional load blocks (i.e., the design includes multiple load intervals), then the lower limit requirements (-10%) will ensure that sufficient time exists for the DG to restore frequency and voltage prior to applying the remaining load blocks (i.e.,
all load intervals must be &#x17d; 90% of the design interval).
Reference *."provides a summary of the automatic loading of ESS buses.
(continued)
Dresden 2 and 3                  B 3. 8. 1 -31                    Revision 34
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE    SR  3.8.1.18    (continued)
REQUIREMENTS The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR  3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
This Surveillance demonstrates DG operation, as discussed in the Bases for SR 3.8.1.12, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing.        For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
SR  3.8.1.20 This Surveillance demonstrates that the DG starting independence has not been compromised.      Also, this Surveillance demonstrates that each engine can achieve proper frequency and voltage within the specified time when the DGs are started simultaneously.
The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref. X).
(continued)
Dresden 2 and 3                    B 3.8.1-32                        Revision 34
 
AC Sources-Operating B 3.8.1 BASES REFERENCES          3. UFSAR,  Chapter 6.
(continued)
: 4. UFSAR,  Chapter 15.
: 5. Generic Letter 84-15,    July 2, 1984.
: 6. Regulatory Guide 1.93,    Revision 0, December 1974.
[      X UF *SAR, Section 3.1.2.2.9.8.        Regulatory Guide 1.9, 1  1      Re vision 3,  July 1993.
Regulatory Guide 1.9,    Revision 3,  July 1993.
Regulatory Guide 1.108,      Revision 1, August 1977.
ME  /. Regulatory Guide 1.137,      Revision 1, October 1979.
EIVi      ANSI C84.1,    1982.
UFSAR,  Section 6.3.
UFSAR,  Section 8.3.1.5.1.
Letter from R. M. Krich (ComEd) to NRC, "Request for Technical Specifications Changes for Dresden Nuclear Power Station, Units 2 and 3, LaSalle County Station, Units 1 and 2, and Quad Cities Nuclear Power Station, Units 1 and 2, to Convert to Improved Standard Technical Specifications," dated March 3, 2000.
Dresden 2 and 3                        B 3 .8. 1-34                        Revision 34
 
DC Sources-Operating B 3.8.4 BASES ACTIONS        1.1      (continued) design basis event were to occur.        With a standby gas treatment subsystem inoperable, LCO 3.6.4.3, "Standby Gas Treatment System" requires restoration of the inoperable SGT subsystem to OPERABLE status in 7 days.        Therefore, a 7 day Completion Time is provided to restore the opposite unit Division 2 125 VDC electrical power subsystem to OPERABLE status.      The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant system(s) and the low probability of a DBA              Eoverall occurring during this time period.                                Iriskis minimniz J , I -a-rr 1 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO <-
d:es not apply.        To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 wthin 36 hadps.\'The allowed Completion Time/ a -              -e reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. 4he C.mpl.tia. Tim. to brig the u.nit to MODE 4 i: ensistr+nt with the time required in f..gult*..y Guide 1i.99 (Re. 7).
SURVEILLANCE    SR    3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries              I to perform their intended function.        Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state, while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery.      The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float established by the battery manufacturer (continued)
Dresden 2 and 3                      B 3.8.4-16                        Rev isi on 16
 
DC Sources-Operating B 3.8.4 BASES SURVEILLANCE    SR  3.8.4.1  (continued)
REQUIREMENTS (2.17 Vpc or 260.4 V at the 250 VDC battery terminals and 125.9 V at the 125 VDC battery terminals).        This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is conservative when compared with manufacturers recommendations and IEEE-450 U  (RefYV8). SR 3.8.4.1.c is modified by a Note.      The Note requires the Unit 2 alternate battery to meet the specified voltage limit only when it is required to be OPERABLE.        This battery is required to be OPERABLE when it is being used to meet Required Actions F.1, G.1, or H.2.
SR  3.8.4.2 and SR    3.8.4.341 These SRs verify the design capacity of the battery*.
chargers. According to Regulatory Guide 1.32 (Ref. f), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensures that these requirements can be satisfied.        This SR provides two options.        One option requires that each battery charger be capable of supplying 200 amps at the minimum established float voltage for 4 hours.        The ampere requirements are based on the output rating of the chargers.
The voltage requirements are based on the charger voltage level after a response to a loss of AC power.        The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least 2 hours.
The other option requires each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur).        This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge (continued)
Dresden 2 and 3                  B 3.8.4-17                          Revision  16
 
DC Sources-Operating B 3.8.4 BASES  (continued)
REFERENCES          1. UFSAR, Section 3.1.2.2.8.
: 2. Safety Guide 6,  March 10,  1971.
: 3. IEEE Standard 308,  1974.
: 4. UFSAR, Section 8.3.2.
: 5. UFSAR, Chapter 6.
: 6. UFSAR, Chapter 15.
: 7. Regulatory Guide 1.93,  Revision 0, December 1974.
IEEE Standard 450,  1995.
Regulatory Guide 1.32,  Revision 2, February 1977.
Dresden  2 and 3                  B 3.8.4-19                        Revision 16
 
Distribution  Systems-Operating B 3.8.7 BASES ACTIONS        C.1  (continued)
The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.8.1 be entered and Required Actions taken if the inoperable opposite unit AC electrical power distribution subsystem results in an inoperable required offsite circuit.      This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO docs not oaisminimized    -p-* . To achieve this status, the plant must be brought to at least MODE 3 within 12 hours ....        .. . ........          is 96 hou -. 4\The allowed Completion Time* '-      reasonable,        U based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When the inoperability of two or more AC or DC electrical power distribution subsystems, in combination, results in the loss of a required function, 'the plant is in a condition outside the accident analysis.
Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown. The term "in combination" means that the loss of function must result from the inoperability of two or more AC and DC electrical power distribution subsystems; a loss of function solely due to a single AC or DC electrical power distribution subsystem inoperability even with another AC or DC electrical power distribution subsystem concurrently inoperable, does not require entry into Condition E.
(continued)
Dresden 2 and 3                    B 3.8.7-10                            Revision 30
 
Distribution Systems-Operating B 3.8.7 BASES  (continued)
SURVEILLANCE        SR  3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions are maintained, and the appropriate voltage is available to each required bus.
The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, redundant power supplies available to the essential service and instrument 120 VAC buses, and other indications available in the control room that alert the operator to bus and subsystem malfunctions.
REFERENCES          1. UFSAR,  Chapter 6.
: 2. UFSAR,  Chapter 15.
: 3. Regulatory Guide 1.93, December 1974.
Dresden 2 and 3                      B 3.8.7-11                        Revision 30
 
Dresden Nuclear Power Station TSTF-423 LAR Technical Specification Bases Page Inserts LCO 3.4.3 Safety and Relief Valves Insert 1 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. 5) 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 B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 C.1 and C.2 If the relief function of two or more relief valves is inoperable or if the safety function of one or more safety valves is inoperable, a transient may result in the violation of the ASME Code limit on reactor pressure. 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 MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
Insert 3
: 5.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.5.1 ECCS-Operatinq Insert 1 D.1 If any Required Action and associated Completion Time of Condition A, B, or C is not met, 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. 11) 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. 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.
RequiredAction D. I is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptablelevel of risk, it is not the intent of the Required Action to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 1.1 If any Required Action and associated Completion Time of Condition G or H is not met, the plant must be brought to a MODE in which 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. 11) 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. 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.
RequiredAction 1.1 is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
 
Insert 3
: 11. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.5.3 IC System Insert I 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 B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.6 Low-Low Set (LLS) Valves Insert 1 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 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 B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptablelevel of risk, it is not the intent of the RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 C.1 and C.2 Iftwo or more LLS valves are inoperable, there could be excessive short duration S/RV cycling during an overpressure event. The plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 and 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.
Insert 3
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers Insert 1 D.1 If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition C, the remaining breakers in the remaining lines can provide the opening function. The plant must be brought to a condition 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. 2) 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. 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.
Required Action D. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers Insert I B.1 If a required suppression chamber-to-drywell vacuum breaker is inoperable for opening and is not restored to OPERABLE status the required Completion Time, this plant must be brought to a condition 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. 3) 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. 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.
Required Action B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.2.3 Suppression Pool Cooling Insert 1 B.1 If one suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition 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. 2) 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.
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.
Required Action B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.2.4 Suppression Pool Spray Insert 1 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 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 C. 1 is modified by a Note that prohibitsthe applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptable level of risk, it is not the intent of the RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.4.1 Secondary Containment Insert 1 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), 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.
RequiredAction B. 1 is modified by a Note that prohibits the applicationof 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 acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.4.3 Standby Gas Treatment (SGT) System Insert 1 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 B. 1 is modified by a Note that prohibitsthe applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 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.
Insert 3
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.1 Containment Cooling Service Water (CCSW) System Insert 1 D.1 If one CCSW subsystem is inoperable or one CCSW pump in one or two subsystems is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition 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. 8) 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 also an acceptable low-risk state. 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 system.
Required Action D. I is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.4 Control Room Emeraencv Ventilation (CREV) System Insert 1 B. 1 In MODE 1, 2, or 3, if the inoperableCREV System cannot be restoredto OPERABLE status within the associatedCompletion 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. 8) 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. The allowed Completion Time is reasonable,based on operating experience, to reach the requiredunit conditions from full power conditions in an orderly manner and without challenging unit systems.
Required Action B. I is modified by a Note that prohibits the applicationof 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 enterMODE 3 from MODE 4 with the LCO not met. While remaining in MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
                                                              /
 
LCO 3.7.5 Control Room Emerqency Ventilation Air Conditioninq (AC) System Insert 1 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 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.
RequiredAction B. I is modified by a Note that prohibits the applicationof 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants", December 2002.
 
LCO 3.7.6 Main Condenser Offgas Insert I 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. 3) 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.
RequiredAction B.3 is modified by a Note that prohibits the applicationof 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 remainingin MODE 3 presents an acceptablelevel of risk, it is not the intent of the RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants", December 2002.
 
LCO 3.8.1 AC Sources - Operatinq Insert 1 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. 7) 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.
RequiredAction F.I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 acceptablelevel of risk, it is not the intent of the RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 7.      NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants", December 2002.
 
LCO 3.8.4 DC Sources - ODeratina Insert I 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. 8) 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.
RequiredAction J. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 acceptablelevel of risk, it is not the intent of the RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 8.      NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants", December 2002.
 
LCO 3.8.7 Distribution Systems - Oieratina Insert I 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 D. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, "Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants", December 2002.
 
ATTACHMENT 6 Markup of Revised Proposed QCNPS Technical Specifications Pages TS Note Insert:
-------------------------------                                                      NOTE-    ------------------------------
LCO 3.0.4.a is not applicable when entering MODE 3.
Revised Proposed QCNPS TS 3.4.3 -1 3.5.1 -1 3.5.1 -2 3.5.1 -3 3.5.3 -1 3.6.1.6 -1 3.6.1.7 -2 3.6.1.8-1 3.6.2.3 -1 3.6.2.4 -1 3.6.4.1 -1 3.6.4.3 -1 3.6.4.3 -2 3.7.1-1 3.7.1 -2 3.7.4 -1
* 3.7.4 -2*
3.7.5 -1 3.7.6 -1 3.8.1 -5 3.8.4-3 3.8.7 -2
* Denotes TS pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS version Page 1 of 1
 
Safety and Relief Valves 3.4.3 3.4  REACTOR COOLANT SYSTEM (RCS) 3.4.3  Safety and Relief Valves LCO  3.4.3        The safety function of 9 safety valves shall be OPERABLE.
AND The relief function of 5 relief valves shall be OPERABLE.
APPLICABILITY:      MODES 1, 2,  and 3.
ACTIONS CONDITION                    REQUIRED ACTION                COMPLETION TIME A. One relief valve          A.1      Restore the relief          14 days inoperable,                        valve to OPERABLE status.
B. Required Action and        B.1      Be in MODE 3.-              12 hours associated Completion Time of Condition A      -ANB                  ITSNoteInsert not met.
B.2      De in MODE 4.              -36heurs C  Two or more relief        0C.      Be in MODEO3.                12 hours valves inoperable.        AN OR0.2                        Be inMODE 4.                36 hours One or more safety valves inoperable.
Quad Cities 1 and 2                      3.4.3-1                    Amendment No. 199/195
 
ECCS-Operati ng 3.5.1 3.5    EMERGENCY CORE COOLING SYSTEMS (ECCS)              AND REACTOR CORE ISOLATION    COOLING (RCIC) 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 shall 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                        subsystem to OPERABLE A.                                          status.
OR One Core Spray subsystem inoperable.
C. One LPCI pump in each            C.1      Restore one LPCI pump    7 days subsystem inoperable,                      to OPERABLE status.
(continued)
D. Required Action and associated    D.1      Be in MODE T,          12 hours Completion Time of Condition A,                        I Noteours B, or C not met.                ITSNoteInse Quad Cities 1 and 2                            3.5.1-1                  Amendment No. 223/218
 
ECCS---Operati ng 3.5.1 ACTIONS CONDITION                                  REQUIRED ACTION                          COMPLETION TIME
  ,. Two LPCI subsystems                  1              Restore one LPCI                      72 hours inoperable for reasons              FE1            subsystem to OPERABLE other than Condition                                status.
C.
],. Required Action and                        F1 Be in            MODE 3.                    12 hours associated Completion Time of Condition --- E              AND B, C, @r - not met.
                                            -.- F.2 Be in MODE 4.                              36 hours
                                        ~1~                                                    ~1*
HPCI System                          -.-_I*m*'      Verify by                              Immediately inoperable.                                          administrative means RCIC System is OPERABLE.
AND
                                            -+-.4lG.2 to    Restore HPCI System                    14 days OPERABLE status.
H-1/    One ADS valve                        +.1            Restore ADS valve to                  14 days inoperable.                                          OPERABLE status.
  /. Rcqbircd Aetio an ad            -    -H.1          Be in MODE 3.                          12 hours associated ...... eti mr            FT  -1 Tifoe E4.      ditionH F or-        AND 6 mot met-Reduce reactor steam J.2            dome pressure to                      36 hours
                                                            -' 150 psig.
Two or more ADS valves inoperable.
___ _________________________(continued)
: 1. Required Action and associated      1.1              Be in MODE            No-    e          12 hours (&#xa2;ontinueQ)
Completion Time of Condition G or                                      ITSNote InsertI H not met.
Quad Cities 1 and 2                                    3.5.1-2                                Amendment No.        201/197
 
ECCS-Operating 3.5.1 ACTIONS CONDITION          [REQUIRED ACTION            COMPLETION TIME Two or more low          i .1  Enter LCO 3.0.3    Immediately pressure ECCS              1 FK.
injection/spray subsystems inoperable for reasons other, than Condition C or%.
HPCI System and one or more ADS valves inoperable.
OR One or more low pressure ECCS injection/spray subsystems inoperable and one or more ADS valves inoperable.
OR HPCI System inoperable and either one low pressure ECCS injection/spray subsystem is inoperable or Condition C entered.
Quad Cities 1 and 2                3.5.1-3          Amendment No. 201/197
 
RCIC System 3.5.3 3,5  EMERGENCY CORE COOLING SYSTEMS (ECCS)      AND REACTOR CORE ISOLATION COOLING (RCIC)  SYSTEM 3.5.3  RCIC System LCO  3.5.3        The RCIC 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 RCIC.
CONDITION                    REQUIRED ACTION            COMPLETION TIME A. RCIC System                A.1        Verify by                Immediately inoperable,                          administrative means High Pressure Coolant Injection System is OPERABLE.
AND A.2        Restore RCIC System      14 days to OPERABLE status.
B. Required Action and        B.1        Be in MODE  .          12 hours associated Completion Time not met.              _ 8TSNotelnsert B.2        Redtcz reactor storm    39 hp'-pr dome prePsure to 150 p6ig.
Quad Cities I and 2                    3.5.3-1                  Amendment No. 223/218
 
Low Set Relief Valves 3.6.1.6 3.6  CONTAINMENT  SYSTEMS 3.6.1.6  Low Set Relief Valves LCO  3.6.1.6      The low set relief function of two relief valves shall            be OPERABLE.
APPLICABILITY:    MODES 1, 2, and 3.
ACTIONS CONDITION                    REQUIRED ACTION                  COMPLETION TIME A. One low set relief      A.1      Restore low set                14 days valve inoperable,                  relief valve to OPERABLE status.
B. Required Action and      B.1      Be in MODE 3.                  12 hours associated Completion Time of Condition A                            ETS Note nser not met.
B.2      Be i    .1.[ 4.              _':-_3_,,__,o C.1      Be in MODE 3.                  12 hours Ifc Two low set relief        AND valves inoperable.
C.2      Be in MODE 4.                36 hours Quad Cities I and 2                  3.6.1.6-1                    Amendment No. 199/195
 
Reactor    Building-to-Suppression      Chamber Vacuum Breakers 3.6.1.7 ACTIONS CONDITION                IREQUIRED ACTION                        I COMPLETION TIME Two lines with one or            /    1      Restore all vacuum          1 hour more reactor building-to-suppression chamber RE          breakers in one line to OPERABLE status.
vacuum breakers inoperable for openi ng.
4                                        4 F[jJI /. Required Action and              [E.        Be in MODE 3.                12 hours Associated Completion            F.11 Tim 1&#xfd;not met.                    AND
[of Conditions A, B or El Be in MODE 4.                36 hours EF2 I                                                                                                      I D. Required Action and Associated    D.1      Be in MODE 32t    1          12 hours Completion Time of Condition C                        ITS Note Insert not met.
SURVEILLANCE      REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR  3.6.1.7.1          ------------------ NOTES------------------
: 1. Not required to be met for vacuum breakers that are open during Surveillances.
: 2. Not required to be met for vacuum breakers open when performing their intended function.
Verify each vacuum breaker is        closed.          14 days SR  3.6.1.7.2          Perform a functional        test of each vacuum        92 days breaker.
(continued)
Quad Cities 1 and 2                            3.6.1.7-2                    Amendment No. 199/195
 
Suppression Chamber-to-Orywell    Vacuum Breakers 3.6.1.8 3.6  CONTAINMENT SYSTEMS 3.6.1.8    Suppression Chamber-to-Drywell              Vacuum Breakers LCO  3.6.1.8          Nine suppression chamber-to-drywell          vacuum breakers shall      be OPERABLE for opening.
AND Twelve suppression chamber-to-drywell            vacuum breakers  shall be closed.
APPLICABILITY:        MODES 1,      2,  and 3.
ACTIONS CONDITION                              REQUIRED ACTION            COMPLETION TIME A. One required                        A.1        Restore one vacuum        72 hours suppression chamber-                          breaker to OPERABLE to-drywell vacuum                              status.
breaker inoperable for opening.
One suppression                      -B.1      Close the open vacuum    4 hours chamber-to-drywell                  C-11      breaker.
vacuum breaker not closed.
4                                    4 Required Action and                            Be in MODE 3.            12 hours associated Completion Time not met.                        AND of Condition C                      6.2        Be in MODE 4.            36 hours 0.2 B. Required Action and associated Completion Time of Condition A not met.
Quad Cities I and 2                              3.6.1.8-1                Amendment No. 199/195
 
RHR Suppression Pool      Cooling 3.6.2.3 3.6  CONTAINMENT SYSTEMS 3.6.2.3 Residual      Heat Removal  (RHR)  Suppression Pool Cooling LCO  3.6.2.3          Two RHR suppression      pool cooling subsystems shall          be OPERABLE.
APPLICABILITY:          MODES 1, 2,  and 3.
ACTIONS CONDITION                        REQUIRED ACTION                  COMPLETION TIME A. One RHR suppression          A.1        Restore RHR                    7 days pool cooling subsystem                    suppression pool inoperable,                              cooling subsystem to OPERABLE status.
I-Two RHR suppression                        Restore one RHR                8 hours pool cooling                              suppression pool subsystems inoperable.                    cooling subsystem to OPERABLE status.
I.
Required Action and                        Be in  MODE 3.                12 hours associated Completion          /1 Ti menot met.
lof Condition C,                          Be in  MODE 4.                36 hours B. Required Action and associated  B.1      Be in MODE 3S    1            12 hours Completion Time of Condition A not met.                                            TS Note InsertI Quad Cities 1 and 2                          3.6.2.3-1                    Amendment No. 199/195
 
RHR Suppression Pool Spray 3.6.2.4 3.6  CONTAINMENT SYSTEMS 3.6.2.4 Residual  Heat Removal  (RHR)  Suppression Pool Spray LCO  3.6.2.4      Two RHR suppression pool    spray subsystems shall    be OPERABLE.
APPLICABILITY:    MODES 1, 2,  and 3.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One RHR suppression      A.1      Restore RHR                7 days pool spray subsystem                suppression pool inoperable,                        spray subsystem to OPERABLE status.
B. Two RHR suppression      B.1      Restore one RHR            8 hours pool spray subsystems              suppression pool inoperable,                        spray subsystem to OPERABLE status.
C. Required Action and      C.1      Be in MODE 3.              12 hours associated Completion Time not met.                                ITSNotelnsert C .2      B      HiOC 4.
Quad Cities I and 2                  3.6.2.4-1                  Amendment No. 199/195
 
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                  I the secondary containment,                                            I During operations with a potential for draining the reactor vessel (OPDRVs).
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          B.1    Be in MODE 3.                  12 hours associated Completion Time of Condition A      ---                      ETSNotelnserI not met.
0.2    Be  ,, MNODE 4.              -96  ,,bio 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 or during OPDRVs.
Suspend movement of recently irradiated fuel assemblies in Immediately I
the secondary containment.
AND C.2    Initiate action to              Immediately suspend OPDRVs.
Quad Cities 1 and 2                  3.6.4.1-1                      Amendment No. 233/229
 
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, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. One SGT subsystem          A.1        Restore SGT              7 days inoperable,                          subsystem to OPERABLE status.
B. Required Action and        B.1      Be in MODE 3.              12 hours associated Completion Time of Condition A      -                    ETSNotelnsert not met in MODE 1, 2, or 3.                      D.2      Be in MD[ 4.              .hT    up 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 during OPDRVs.          OR (continued)
Quad Cities 1 and 2                    3.6.4.3-1                  Amendment No. 233/229
 
SGT System 3.6.4.3 ACTIONS CONDITION                  REQUIRED ACTION              COMPLETION TIME C.  (continued)            C.2.1    Suspend movement of        Immediately recently irradiated fuel assemblies in secondary containment.
AND                                                I I
C.2.2    Initiate action to        Immediately suspend OPDRVs.
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      E.1      Be in  MODE 3.            12 hours associated Completion Time of Condition D  -t                    ITSNotelnsert not met.
[.2      De in9 0ODE 4.              61O1-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 during OPDRVs.                recently irradiated fuel. assemblies in secondary containment.
AND F.2      Initiate action to        Immediately suspend OPDRVs.
Quad Cities I and 2                  3.6.4.3-2                  Amendment No. 233/229
 
RHRSW System 3.7.1 3.7  PLANT SYSTEMS 3.7.1    Residual    Heat Removal    Service Water    (RHRSW)  System LCO  3.7.1            Two RHRSW subsystems shall        be OPERABLE.
APPLICABILITY:        MODES 1,    2, and 3.
ACTIONS CONDITION                          REQUIRED ACTION            COMPLETION TIME A. One RHRSW pump                    A.1        Restore RHRSW pump to    30 days inoperable.                                  OPERABLE status.
B. One RHRSW pump in each            B.1        Restore one RHRSW        7 days subsystem inoperable,                        pump to OPERABLE status.
C. One RHRSW subsystem              C. 1      - --------NOTE-------
inoperable for reasons                      Enter applicable other than                                  Conditions and Condition A.                                Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR)
Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling subsystem made inoperable by RHRSW System.
Restore RHRSW            7 days subsystem to OPERABLE status.
: 0. Required Action and associated Completion Time of Conditions A, B, or C not met.
Quad Cities 1 and 2                          3 .7. 1-1                Amendment No. 199/195
 
RHRSW System 3.7.1 ACTIONS CONDITION            I          REQUIRED ACTION              COMPLETION TIME
[Ji. Both RHRSW subsystems        /. 1      -------- NOTE--------
inoperable for reason    S              Enter applicable other than                  IqI        Conditions and Condition B.                            Required Actions of LCO 3.4.7 for RHR shutdown cooling subsystems made inoperable by RHRSW System.
Restore one RHRSW          8 hours subsystem to OPERABLE status.
4 nFIK. Required Action and                    Be in MODE 3.              12 hours associated Completion          A.1 Time not met.                  AN_.DD 4\
lof Condition E                          Be in MODE 4.              36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR  3.7.1.1        Verify each RHRSW manual and power operated          31 days valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
Quad Cities 1 and 2                        3. 7.1-2                  Amendment No. 199/195
 
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 (CRE) 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, During operations with a potential for draining the reactor vessel (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/.                      _
CREV system                                Initiate action to        Immediately inoperable due to                        implement mitigating inoperable CRE                            actions.
boundary in MODE 1, 2, or 3.                        AND 24 hours 1.2      Verify mitigating actions ensure CRE occupant exposures to radiological, chemical,    and smoke hazards will not exceed limits.
AND 90 days X-3      Restore CRE boundary to OPERABLE status.
Required Action and associated HB.      Completion Time of Condition A not B.1      Be in MODE 3              F12 hours h u(continued) met in MODE 1. 2. or 3.
Qu d    i ie        "a n  2I..                        -                A e d  e t  No  3 / 3 Quad Cities 1 and 2                            3.7.4-1                  Amendment No. 238/233
 
CREV System 3.7.4 ACTIONS (continued)
CONDITION                  REQUIRED ACTION        I COMPLETION TIME Required Action and              Be in MODE 3.          12 hours associated Completion Time of Condition A oi  AND fc-B-not met in MODE 1, 2, or 3.                          Be in MODE 4.          36 hours
[9X*    CREV System inoperable  ------------- NOTE-----------
during movement of      LCO 3.0.3 is not applicable.
recently irradiated fuel assemblies in the secondary containment  ,K1        Suspend movement of    Immediately or during OPDRVs.                recently irradiated fuel assemblies in OR                                    the secondary containment.
CREV System inoperable due to an inoperable  AND CRE boundary during movement of recently              Initiate action to      Immediately irradiated fuel                  suspend OPDRVs.
assemblies in the secondary containment or during OPDRVs.
Quad Cities 1 and 2                  3.7.4-2              Amendment No. 238/233
 
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, During operations with a potential for draining the reactor vessel (OPDRVs).
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        B.1      Be in MODE 3.                  12 hours associated Completion Time of Condition A          B                  ITSNoteInsertI not met in MODE 1, 2, or 3.                      B.2      De ii,  .MOE 4.              .. .....
C. Control Room Emergency      ------------- NOTE------------
Ventilation AC System      LCO 3.0.3 is not applicable.
inoperable during          -----------------------------
I movement of recently irradiated fuel assemblies in the C.1      Suspend movement of recently irradiated Immediately        I secondary containment                fuel assemblies in or during OPDRVs.                    the secondary containment.
AND C.2      Initiate action to            Immediately suspend OPDRVs.
Quad Cities I and 2                    3.7.5-1                      Amendment No. 233/229
 
Main Condenser Offgas 3.7.6 3.7  PLANT SYSTEMS 3.7.6  Main Condenser Offgas LCO  3.7.6        The gross gamma activity rate of the noble gases measured prior to the offgas holdup line shall be E 251,100 pCi/second after decay of 30 minutes.
APPLICABILITY:      MODE 1, MODES 2 and 3 with any main steam line not        isolated and steam jet air ejector (SJAE) in operation.
ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME A. Gross gamma activity      A.I        Restore gross gamma        72 hours rate of the noble                    activity rate of the gases not within                    noble gases to within limit,                              limit.
B. Required Action and        B.1      Isolate all main            12 hours associated Completion                steam lines.
Time not met.
OR B.2      Isolate SJAE.              12 hours OR B.3,A&#xfd;'    Be in MODE 3                12 hours A;TS                Note Insert
                                  .3.2      c in MOD E                3  hours Quad Cities I and 2                    3.7.6-1                    Amendment No. 199/195
 
AC Sources-Operating 3.8.1 ACTIONS CONDITION                REQUIRED ACTION          COMPLETION TIME F. Required Action and    F.1    Be in MODE 3.          12 hours associated Completion Time of Condition A,  -AN4-            TSNotense B, C, D, or E not met.
F.2    Be im HOBE 4.A                .
G. Three or more required  G.1    Enter LCO 3.0.3.        Immediately AC sources inoperable.
Quad Cities 1 and 2                3.8.1-5              Amendment No. 199/195
 
DC Sources-Operating 3.8.4 ACTIONS CONDITION              REQUIRED ACTION                COMPLETION TIME D. Division I or 2        D.]    Restore Division 1 or        72 hours 125 VDC electrical          2 125 VDC electrical power subsystem              power subsystem to inoperable for reasons        OPERABLE status.
other than Conditions B or C.                OR D.2  --------- NOTE ---------
Only applicable if the opposite unit is not in MODE 1, 2, or 3.
Place associated            72 hours OPERABLE alternate 125 VDC electrical power subsystem in service.
E. Opposite unit 125 VDC  E.1    Restore the opposite        7 days electrical power              unit 125 VDC subsystem inoperable,        electrical power subsystem to OPERABLE status.
F. Required Action and    F.1    Be in MODE 3.                12 hours associated Completion Time not met.                          FITSNotelnsert F.2    Be in 0MO E 1 .                6 .....
Quad Cities 1 and 2            3.8.4-3                    Amendment No. 199/195
 
Distribution Systems-Operating 3.8.7 ACTIONS CONDITION                  REQUIRED ACTION              COMPLETION TIME B. One or more DC          B.1      Restore DC electrical      2 hours electrical power                  power distribution distribution                      subsystems to              AND subsystems inoperable.            OPERABLE status.
16 hours from discovery of failure to meet LCO 3.8.7.a C. One or more required  -------------- NOTE-----------
opposite unit AC or DC  Enter applicable Condition electrical power        and Required Actions of distribution            LCO 3.8.1 when Condition C subsystems inoperable,  results in the inoperability of a required offsite circuit.
C.1      Restore required          7 days opposite unit AC and DC electrical power distribution subsystems to OPERABLE status.
D. Required Action and    D.1      Be in MODE 3.              12 hours associated Completion Time of Condition A,    AB                  TSNotelnsert B, or C not met.
B.2      De in M,8E 4.              36 hours E. Two or more electrical  E.1      Enter LCO 3.0.3.          Immediately power distribution subsystems inoperable that, in combination, result in a loss of function.
Quad Cities I and 2                3.8.7-2                  Amendment No. 199/195
 
ATTACHMENT 7 Markup of Revised Proposed QCNPS Technical Specifications Bases Pages Revised Proposed QCNPS TS Bases Pages B 3.4.3 -4* to B 3.4.3 -7*
B 3.5.1 -8* to B 3.5.1 -10*
B 3.5.1 -12*
B 3.5.1 -18*
B 3.5.3 -4 B 3.5.3 -7 B 3.6.1.6 -3 B 3.6.1.6 -4*
B 3.6.1.6 -5*
B 3.6.1.7 -5 B 3.6.1.7 -6 B 3.6.1.8 -4 to B 3.6.1.8 -6 B 3.6.2.3 -2 to B 3.6.2.3 -4*
B 3.6.2.4 -3 B 3.6.2.4 -4 B 3.6.4.1 -3 B 3.6.4.1 -6 B 3.6.4.3 -3 to B 3.6.4.3 -5 B 3.6.4.3 -7 B 3.7.1 -4 to B 3.7.1 -6 B 3.7.4 -5*
B 3.7.4 -6*
B 3.7.4 -8*
B 3.7.4 -9*
B 3.7.5 -3 B 3.7.5 -5*
B 3.7.6 -2 B 3.7.6 -3 B 3.8.1-16 to B 3.8.1 -20 B 3.8.1 -22 B 3.8.1 -24 to B 3.8.1 -28 B 3.8.1 -30 to B 3.8.1 -34 B 3.8.4 -10*
B 3.8.4 -12*
B 3.8.4 -14*
B 3.8.4 -15*
B 3.8.7 -9 B 3.8.7 -10
* Denotes TS Bases pages re-marked up with original requested TSTF-423 changes with the addition of LCO 3.0.4.a NOTE on current TS Bases page version Page 1 of 1
 
Safety and Relief Valves B 3.4.3 BASES  (continued)
APPLICABILITY      In MODES 1, 2, and 3, all safety and relief valves must be OPERABLE, since considerable energy may be in the reactor core and the limiting design basis transients are assumed to occur in these MODES.      Thesafety and relief valves may be required to provide pressure relief to discharge energy from the core until such time that the Residual Heat Removal (RHR) System is capable of dissipating the core heat.
In MODE 4, decay heat is low enough for the RHR System to provide adequate cooling, and reactor pressure is low enough that the overpressure and MCPR limits are unlikely to be approached by assumed operational transients or accidents.
In MODE 5, the reactor vessel head is unbolted or removed and the reactor is at atmospheric pressure.            The safety and relief functions are not needed during these conditions.
ACTIONS            A.1 With the relief function of one relief valve (or S/RV) inoperable, the remaining OPERABLE relief valves are capable of providing the necessary protection.          However, the overall reliability of the pressure relief system is reduced because additional failures in the remaining OPERABLE relief valves could result in failure to adequately relieve pressure during a limiting event.      For this reason, continued operation is permitted for a limited time only.
The 14 day Completion Time to restore the inoperable required relief valve to OPERABLE status is based on the relief capability of the remaining relief valves, the low probability of an event requiring relief valve actuation, and a reasonable time to complete the Required Action.
B.1  ,, B0.2  .andC.2 With less than the minimum number of required safety valves OPERABLE, a transient may result in the violation of the ASME Code limit on reactor pressure.          If the relief ftmction of the iiioperable relief vulves ca..t          be re*et*i,    to OPERABLE  sLaLub wi thi-in t e assouciacited    ,,m, e ,tm ..... e of Required Actiom A.1, or iF the relief function of two or more relief valves are inoperable1 or if the safety function (continued)
Quad Cities 1 and 2                  B 3.4.3-4                                Revision 32
 
Safety and Relief Valves B 3.4.3 BASES ACTIONS  CdO.2.            .    (continued) of one or more safety valves is inoperable, 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 MODE 3 within 12 hours and to MODE 4 within 36 hours.      The allowed Completion Times are reasonable, based on operating experience, to reach required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR  3.4.3.1 REQUIREMENTS This Surveillance requires that the safety valves, including the S/RV, will open at the pressures assumed in the safety analysis of Reference 1. The demonstration of the safety valve and S/RV safety lift    settings must be performed during shutdown, since this is a bench test, to be done in accordance with the Inservice Testing Program.      The lift setting pressure shall correspond to ambient conditions of the valves at nominal operating temperatures and pressures.
The safety valve and S/RV setpoints are +/- 3% for OPERABILITY; however, the valves are reset to +/- 1% during the Surveillance to allow for drift.
SR  3.4.3.2 The actuator of each of the Electromatic relief valves (ERVs) and the dual function safety/relief valves (S/RVs) is stroked to verify that the pilot valve strokes when manually actuated. For the S/RVs, the actuator test is performed by energizing a solenoid that pneumatically actuates a plunger located within the main valve body. The plunger is connected to the second stage disc. When steam pressure actuates the plunger during plant operation, this allows pressure to be vented from the top of the main valve piston, allowing reactor pressure to lift    the main valve piston, which opens the main valve disc. The test will verify movement of the plunger in accordance with vendor recommendations. However, since this test is performed prior to establishing the reactor pressure needed to overcome main valve closure forces, the main valve disc will not stroke during the test.
(continued)
Quad Cities 1 and 2                  B 3.4.3-5                        Revision 33
 
Safety and Relief Valves B 3.4.3 BASES SURVEILLANCE      SR  3.4.3.2  (continued)
REQUIREMENTS For the ERVs, the actuator test is performed with the pilot valve actuator mounted in its normal position. This will allow testing of the manual actuation electrical circuitry, solenoid actuator, pilot operating lever, and pilot plunger.
This test will verify pilot valve movement. However, since this test is performed prior to establishing the reactor pressure needed to overcome main valve closure spring force, the main valve will not stroke during the test.
This SR, together with the valve testing performed as required by the ASME Code for pressure relieving devices (ASME OM Code-1998 through 2000 Addenda), verify the capability of each relief valve to perform its function.
Valve testing will be performed at a steam test facility, where the valve (i.e., main valve and pilot valve) and an actuator representative of the actuator used at the plant will be installed on a steam header in the same orientation as the plant installation. The test conditions in the test facility will be similar to those in the plant installation, including ambient temperature, valve insulation, and steam conditions. The valve will then be leak tested, functionally tested to ensure the valve is capable of opening and closing (including stroke time), and leak tested a final time. Valve seat tightness will be verified by a cold bar test, and if not free of fog, leakage will be measured and verified to be below design limits.      In addition, for the safety mode of S/RVs, an as-found setpoint verification and as-found leak check are performed, followed by verification of set pressure, and delay. The valve will then be shipped to the plant without any disassembly or alteration of the main valve or pilot valve components.
The combination of the valve testing and the valve actuator testing provide a complete check of the capability of the valves to open and close, such that full functionality is demonstrated through overlapping tests, without cycling the valves.
The 24 month Frequency ensures that each solenoid for each relief valve is tested. The 24 month Frequency was developed bases on the relief valve tests required by the ASME Code (Ref./'). Operating experience has shown that these components usually (continued)
Quad Cities 1 and 2                R 3.4-3-6                        Revision 35
 
Safety and Relief Valves B 3.4.3 BASES SURVEILLANCE      SR  3.4.3.2  (continued)
REQUIREMENTS pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.4.3.3 The relief valves, including the S/RV, are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the relief valve operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TESTs in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS) Instrumentation," and LCO 3.3.6.3, "Relief Valve Instrumentation," overlap this SR to provide complete testing of the safety function.
The 24 month 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 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation since the valves are individually tested in accordance with SR 3.4.3.2.
REFERENCES        1. UFSAR,  Section 5.2.2.1.
: 2. UFSAR,  Section 15.2.3.1.
: 3. UFSAR,  Section 15.2.2.1.
: 4. UFSAR,  Chapter 15.
F*.      ASME Code for Operation and Maintenance of Nuclear Power Plants.
Quad Cities 1 and 2                  B 3.4.3-7                        Revision 35
 
ECCS-Operating B 3.5.1 BASES ACTIONS          C.1  (continued) evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service.      The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).
                    >E.1 If two LPCI subsystems are inoperable for reasons other than Condition C, one inoperable subsystem must be restored to OPERABLE status within 72 hours.      in this Condition, the remaining OPERABLE CS subsystems provide adequate core cooling during a LOCA.      However, overall ECCS reliability is reduced, because a single failure in one of the remaining CS subsystems, concurrent with a LOCA, may result in ECCS not being able to perform its intended safety function.      The 72 hour Completion Time is based on a reliability study cited in Reference 10 that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowable repair times (i.e., Completion Times).
[.1 Md [.2    IFFlandF.2/
If iy Rquired Action and associated Completion Time of Condition A, B, C, or D is not 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.
(continued)
Quad Cities 1 and 2                  B 3.5.1-8                          Revision 22
 
ECCS-Operating B 3.5.1 BASES ACTIONS          [.I and F.2 PGlandG.21 (continued)
If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days.              In this Condition, adequate core cooling is ensured by the OPERABILITY of the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS.            Also, the RCIC System will automatically provide makeup water at most reactor operating pressures.          Verification of RCIC OPERABILITY is therefore required immediately when HPCI is inoperable.              This may be performed as an administrative check by examining logs or other information to determine if RCIC is out of service for maintenance or other reasons.            It does not mean to perform the Surveillances needed to demonstrate the OPERABILITY of the RCIC System.            If the OPERABILITY    f the RCTIyC.irtpm cannot be verified, however, Conditiony'must be immediately entered.        In the event of component failures concurrent with a design basis LOCA, there is a potential, depending on the specific failures, that the minimum required ECCS equipment will not be available.            A 14 day Completion Time is based on a reliability study cited in Reference 10 and has been found to be acceptable through operating experience.
The LCO requires five ADS valves to be OPERABLE in order to provide the ADS function.            With one ADS valve out of service, the overall reliability of the ADS is reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability.
Therefore, operation is only allowed for a limited time.
The 14 day Completion Time is based on a reliability study cited in Reference 10 and has been found to be acceptable through operating experience.
H.I    gid  11.2    i.landJ.2 If    any Rcquircd A^tion and aso.iat.
* d Completin Timo of there isa              aen      are    in-op    5r~bl mp&#xfd; AP 44 two or more required ADS depressurization      valves are inoperable, the.*.... must be brought to a dcapability. The      condition in which the LCO does not apply.              To achieve this plant                status, the plant must be brought to at least MODE 3 within 12 hours and reactor steam dome pressure reduced to (continued)
Quad Cities 1 and 2                        B 3.5.1-9                          Revision 22
 
ECCS-Operating B 3.5.1 BASES ACTIONS          1H.1 and H72- (continued)
* 150 psig 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.
ri~l  When multiple ECCS subsystems are inoperable, as stated in Condition5(i', the plant is in a condition outside of the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.
SURVEILLANCE      SR  3.5.1.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air.      Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand.        This will also prevent a water hammer following an ECCS initiation signal.      One acceptable method of ensuring that the lines are full is to vent at the high points.      The 31 day Frequency is based on the gradual nature of void buildup in the ECCS piping, the procedural controls governing system operation, and operating experience.
(continued)
Quad Cities 1 and 2                B 3 .5. 1 -10                      Revision 22
 
ECCS-Operating B 3.5.1 BASES SURVEILLANCE      SR  3.5.1.3 REQUIREMENTS (continued)    Verification every 31 days of the correct breaker alignment to the LPCI swing bus demonstrates that the AC electrical power is available to ensure proper operation of the associated LPCI injection valves and the recirculation pump discharge valves. The 31 day Frequency has been found acceptable based on engineering judgment and operating experience.
SR  3.5.1.4 Cycling the recirculation pump discharge valves through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will close when required.
Upon initiation of an automatic LPCI subsystem injection signal, these valves are required to be closed to ensure full LPCI subsystem flow injection in the reactor via the recirculation jet pumps. De-energizing the valve in the closed position will also ensure the proper flow path for the LPCI subsystem. Acceptable methods of de-energizing the valve include de-energizing breaker control power, racking out the breaker or removing the breaker.
The Frequency of this SR is in accordance with the Inservice Testing Program. If any recirculation pump discharge valve is inoperable and in the open position, both LPCI subsystems must be declared inoperable.
SR  3.5.1.5. SR  3.5.1.6. and SR  3.5.1.7 The performance requirements of the low pressure ECCS pumps are determined through application of the 10 CFR 50, Appendix K criteria (Ref. 7). This periodic Surveillance is -'12 performed (in accordance with the ASME Code (Ref Y/)  .
requirements for the ECCS pumps) to verify that the ECCS pumps will develop the flow rates required by the respective analyses. The low pressure ECCS pump flow rates ensure that adequate core cooling is provided to satisfy the acceptance criteria of Reference 9. The pump flow rates are verified against a test line pressure or system head equivalent to (continued)
Quad Cities 1 and 2                B 3.5.1-12                        Revision 35
 
ECCS-Operating B 3.5.1 BASES  (continued)
REFERENCES          1. UFSAR, Section 6.3.2.1.
: 2. UFSAR, Section 6.3.2.2.
: 3. UFSAR, Section 6.3.2.3.
: 4. UFSAR, Section 6.3.2.4.
: 5. UFSAR, Section 15.6.4.
: 6. UFSAR,  Section 15.6.5.
: 7. 10 CFR 50,  Appendix K.
: 8. UFSAR,  Section 6.3.3.
: 9. 10 CFR 50.46.
: 10. Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
NRC), "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
F2    "  ASME Code for Operation and Maintenance of Nuclear Power Plants.
Quad Cities 1 and 2                B 3.5.1-18                      Revision 35
 
RCIC System B 3.5.3 BASES ACTIONS                  B.1 -tid 0.-2 (continued)
If the RCIC System cannot be restored to OPERABLE status within the associated Completion Time, or if the HPCI System overall plant riskisminimized.*  is simultaneously ino erable, the plant must be brought to a
                                &#xfd;co~ndition in which the-."'O dees ,met apfpy. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and reactor steam dome pressure reduced to J150 pSO*;within 3.....ho.        The allowed Completion Time/
F      >      reasonable, based on operating experience, required plant conditions from full to reach the power conditions in  an orderly manner and without challenging plant systems.
SURVEILLANCE              SR  3.5.3.1 REQUIREMENTS The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge line of the RCIC System full of water ensures that the system will perform properly, injecting its full capacity into the Reactor Coolant System upon demand.        This will also prevent a water hammer following an initiation signal.        One acceptable method of ensuring the line is full is to vent at the high points. The 31 day Frequency is based on the gradual nature of void buildup in the RCIC piping, the procedural controls governing system operation, and operating experience.
SR  3.5.3.2 Verifying the correct alignment for manual, power operated, and automatic valves (including the RCIC pump flow controller) in the RCIC flow path provides assurance that the proper flow path will exist for RCIC operation.        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 potentially being mispositioned are in the correct position. This SR does not apply to valves that (continued)
Quad Cities I and 2                          B 3.5.3-4                          Revision 22
 
RCIC System B 3.5.3 BASES SURVEILLANCE      SR  3.5.3.5  (continued)
REQUIREMENTS This SR is modified by a Note that excludes vessel injection during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.
REFERENCES        1. UFSAR,  Section 5.4.6.
: 2. Memorandum from R.L. Baer (NRC)  to V. Stello, Jr.
(NRC),  "Recommended Interim Revisions to LCOs for ECCS 21>      Components," December 1, 1975.
Quad Cities 1 and 2                  B 3.5.3-7                        Revision 22
 
Low Set Relief Valves B 3.6.1.6 BASES ACTIONS            B. nd  2 kconLinueu)                                                                          overall plant risk If twe lo;    et relief valves a re i 1pe, able U-r      rf the        is minimized.
inoperable low set relief valve cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not
                  -t&#xfd;-p-. To achieve this status, the plant must be brought to Enserti E] e-tt--. k/The allowed Completion at least MODE 3 within 12 hours          6 .Wn..........
Timeg &*e. reasonable, is based on operating experience,    to reach the required plant conditions from full power conditions in an orderly manner inet2>        and without challenging plant systems.
SURVEILLANCE        SR  3,6.1.6.1 REQUIREMENTS The actuator of each of the Electromatic low set relief valves (ERVs) is stroked to verify that the pilot valve strokes when manually actuated. For the ERVs, the actuator test is performed with the pilot valve actuator mounted in its normal position. This will allow testing of the manual actuation electrical circuitry, solenoid actuator, pilot operating lever, and pilot plunger.      This test will verify pilot valve movement.      However, since this test is performed prior to establishing the reactor pressure needed to overcome main valve closure spring force, the main valve will not stroke during the test.
This SR, together with the valve testing performed as required by the ASME Code for pressure relieving devices (ASME OM Code -1998 through 2000 Addenda), verify the capability of each relief valve to perform its function.
Valve testing will be performed at a steam test facility, where the valve (i.e., main valve and pilot valve) and an actuator representative of the actuator used at the plant will be installed on a steam header in the same orientation as the plant installation.      The test conditions in the test facility will be similar to those in the plant installation, including ambient temperature, valve insulation, and steam conditions. The valve will then be leak tested, functionally tested to ensure the valve is capable of opening and closing (including stroke time), and leak tested a final time. Valve seat tightness will be verified by a cold bar test, and if not free of fog, leakage will be measured and verified to be below design limits.            In addition, for the safety mode of S/RVs, an as-found setpoint (continued)
Quad Cities 1 and 2                  B 3.6.1.6-3                              Revision 20
 
Low Set Relief Valves B 3.6.1.6 BASES SURVEILLANCE      SR  3.6.1.6.1    (continued)
REQUIREMENTS verification and as-found leak check are performed, followed by verification of set pressure, and delay.      The valve will then be shipped to the plant without any disassembly or alteration of the main valve or pilot valve components.
The combination of the valve testing and the valve actuator testing provide a complete check of the capability of the valves to open and close, such that full functionality is demonstrated through overlapping tests, without cycling the valves.
The 24 month Frequency was bas)      on the relief valve tests  JIM required by the ASME Code (Ref!        . The Frequency of 24 months ensures that each solenoid for each low set relief valve is tested. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency.      Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.6.1.6.2 The low set relief designated relief valves are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to verify that the mechanical portions (i.e., solenoids) of the low set relief function operate as designed when initiated either by an actual or simulated automatic initiation signal. The LOGIC SYSTEM FUNCTIONAL TEST in LCO 3.3.6.3, "Low Set Relief Valve Instrumentation," overlaps this SR to provide complete testing of the safety function.
The 24 month 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 24 month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents a reactor pressure vessel pressure blowdown.
(continued)
Quad Cities 1 and 2                B 3.6.1.6-4                        Revision 35
 
Low Set Relief Valves B 3.6.1.6 BASES  (continued)
REFERENCES          1. UFSAR, Section 6.2.1.3.4.2.
P-I>
IZ. ASME Code for Operation and Maintenance of Nuclear Power Plants.
Quad Cities 1 and 2              B 3 .6. 1.6- 5                  Revision 35
 
Reactor Building-to-Suppression  Chamber Vacuum Breakers B 3.6.1.7 BASES ACTIONS          C.1    (continued) are not OPERABLE.      Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 7 days.          This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being maintained.
With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact.
However, in the event of a containment depressurization, the function of the vacuum breakers is lost. Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour.      This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1,    which requires that primary containment be restored to OPERABLE status within 1 hour.
iL        El                                    of Condition A,B,or E
                      .1and 1.211 If[      Required Action and associated Completion time can not 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.
SURVEILLANCE      SR    3.6.1.7.1 REQUIREMENTS Each vacuum breaker is verified to be closed to ensure that a potential breach in the primary containment boundary is not present. This Surveillance is performed by observing local or control room indications of vacuum breaker position. The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.
(continued)
Quad Cities 1 and 2                  B 3.6.1.7-5                          Revision 0
 
Reactor Buil di ng-to- Suppression Chamber Vacuum Breakers B 3.6.1.7 BASES SURVEILLANCE      SR  3.6.1.7.1    (continued)
REQUIREMENTS Two Notes are added to this SR.      The first Note allows reactor-to-suppression chamber vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR.      These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.      The second Note is included to clarify that vacuum breakers open due to an actual differential pressure are not considered as failing this SR.
SR  3.6.1.7.2 Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position.      This ensures that the safety analysis assumptions are valid.      The 92 day Frequency of this SR was developed based upon Inservice Testing Program requirements to perform valve testing at least once every 92 days.
SR  3.6.1.7.3 Demonstration of vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of
* 0.5 psid is valid.      The 24 month 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.      For this plant, the 24 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES        1. UFSAR,  Sections 6.2.1.3.3 and 6.3.3.2.9.
: 2. UFSAR,  Section 6.2.1.2.4.1.
1ns t2---
Quad Cities I and 2                  B 3.6.1.7-6                          Revi sion 0
 
Suppression      Chamber-to-Drywell  Vacuum Breakers B 3.6.1.8 BASES ACTIONS            A.1    (continued) would not function as designed during an event that depressurized the drywell), the remaining eight OPERABLE vacuum breakers are capable of providing the vacuum relief function. However, overall system reliability is reduced because additional failures in the remaining vacuum breakers could result in an excessive suppression chamber-to-drywell differential pressure during a DBA.          Therefore, with one of the nine required vacuum breakers inoperable, 72 hours is allowed to restore at least one of the inoperable vacuum breakers to OPERABLE status so that plant conditions are consistent with the LCO requirements.          The 72 hour Completion Time is considered acceptable due to the low probability of an event in which the remaining vacuum breaker capability would not be adequate.
E    >
With one vacuum breaker not closed,          communication between the drywel'l and suppression chamber airspace exists, and, as a result, there is the potential for primary containment overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed. A short time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment.        If vacuum breaker position indication is not reliable, an alternate method of verifying that the vacuum breakers are closed is to verify that a differential pressure of 0.5 psid between the suppression chamber and drywell is maintained for 1 hour without makeup.              The required 4 hour Completion Time is considered adequate to perform this test.
0                                                  of Condition C te 1 and  X 2 If- a--y-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 (continued)
Quad Cities 1 and 2                  B 3. 6. 1. 8- 4                            Revision 0
 
Suppression Chamber-to-Drywell      Vacuum Breakers B 3.6.1.8 BASES ACTIONS              I.1an 00.2    (continued) 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.
SURVEILLANCE      SR    3.6.1.8.1 REQUIREMENTS Each vacuum breaker is verified closed to ensure that this potential large bypass leakage path is not present.            This Surveillance is performed by observing the vacuum breaker position indication or by verifying that a differential pressure of 0.5 psid between the suppression chamber and drywell is maintained for 1 hour.      The 14 day Frequency is based on engineering judgment, is considered adequate in view of other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.
Two Notes are added to this SR.      The first    Note allows suppression chamber-to-drywell vacuum breakers opened in conjunction with the performance of a Surveillance to not be considered as failing this SR.      These periods of opening vacuum breakers are controlled by plant procedures and do not represent inoperable vacuum breakers.          The second Note is included to clarify that vacuum breakers open due to an actual differential pressure are not considered as failing this SR.
SR    3.6.1.8.2 Each required vacuum breaker must be cycled to ensure that it opens adequately to perform its design function and returns to the fully closed position.        This ensures that the safety analysis assumptions are valid.          The 31 day Frequency of this SR was developed, based on Inservice Testing Program requirements to perform valve testing at least once every 92 days. A 31 day Frequency was chosen to provide additional assurance that the vacuum breakers are OPERABLE.
In addition, this functional test is required within 12 hours after a discharge of steam to the suppression chamber from the relief valves.
(continued)
Quad Cities 1 and 2                  B 3.6.1.8-5                            Revision 0
 
Suppression Chamber-to-Drywell  Vacuum Breakers B 3.6.1.8 BASES SURVEILLANCE      SR  3.6.1.8.3 REQUIREMENTS (continued)  Verification of the vacuum breaker opening setpoint from the closed position is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of _ 0.5 psid is valid. The 24 month 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. The 24 month Frequency has been shown to be acceptable, based on operating experience, and is further justified because of other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.
REFERENCES        1. UFSAR,  Section 6.2.1.2.4.1.
: 2. UFSAR,  Table 6.2-1.
Quad Cities 1 and 2                B 3.6.1.8-6                        Revision 0
 
RHR Suppression Pool Cooling B 3.6.2.3 BASES APPLICABLE        primary containment conditions within design limits.      The SAFETY ANALYSES  suppression pool temperature is calculated to remain      below (continued)  the design limit.
The RHR Suppression Pool Cooling System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).
LCO              During a DBA, a minimum of one RHR suppression pool cooling subsystem is required to maintain the primary containment peak pressure and temperature below design limits (Ref. 1).
To ensure that these requirements are met, two RHR suppression pool cooling subsystems must be OPERABLE with power from two safety related independent power supplies.
Therefore, in the event of an accident, at least one subsystem is OPERABLE assuming the worst case single active failure. An RHR suppression pool cooling subsystem is OPERABLE when one of the pumps, the heat exchanger, and associated piping, valves, instrumentation, and controls are OPERABLE.
APPLICABILITY      In MODES 1, 2, and 3, a DBA could cause both a release of radioactive material to primary containment and a heatup and pressurization of 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. Therefore, the RHR Suppression Pool Cooling System is not required to be OPERABLE in MODE 4 or 5.
ACTIONS          A.1 With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function.      However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability.      The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
(continued)
Quad Cities 1 and 2                B 3.6.2.3-2                        Revision 0
 
RHR Suppression Pool Cooling B 3.6.2.3 BASES ACTIONS (continued)
With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours.      In this condition, there is a substantial loss of the primary containment pressure and temperature mitigation function.      The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and the potential avoidance of a plant shutdown transient that could result in the need for the RHR suppression pool cooling subsystems to operate.
            *'* /.1      and LD 1.2*          ~                            lof Condition C If-a.#* Required Action and associated Completion Tim            annot 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.
SURVEILLANCE        SR    3.6.2.3.1 REQUIREMENTS Verifying the correct alignment for manual and power operated valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation.      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 is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.        This is acceptable since the RHR suppression pool cooling mode is manually initiated.      This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.      This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
(continued)
Quad Cities 1 and 2                    B 3.6.2.3-3                          Revi si on 0
 
RHR Suppression Pool Cooling B 3.6.2.3 BASES SURVEILLANCE      SR  3.6.2.3.1  (continued)
REQUIREMENTS The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR  3.6.2.3.2 Verifying that each required RHR pump develops a flow rate
                  &#x17d; 5000 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that the primary containment peak pressure and temperature can be maintained below the design limits during a DBA (Ref. 1). The flow is a normal test of centrifugal pump performance required by ASME Code (Ref.*1). This test confirms one point on the pump design curve, and the results are indicative of overall performance. Such inservice tests confirm component OPERABILITY, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.
REFERENCES        1. UFSAR, Section 6.2.
ASME Code for Operation and Maintenance of Nuclear D"        Power Plants.
Quad Cities 1 and 2                B 3.6.2.3-4                      Revision 35
 
RHR Suppression Pool Spray B 3.6.2.4 BASES ACTIONS          A.1  (continued)
However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation capability.      The 7 day Completion Time was chosen in light of the redundant RHR suppression pool spray capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.
B.1 With both RHR suppression pool spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 8 hours. In this condition, there is a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour Completion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to reduce pressure in the primary containment are available.
overall plant risk C. 1 and-C,2,                                                  minimized.
If any Required Action and associated Completion Time cannot be met, the plant must be brought to a MODE in which the-L-C-j does net apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hour.        RE        it L ZIV+F-,*The                allowed Completion Time/-aX&reasonable,                      L[
based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE      SR  3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual and power operated valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow path exists for system operation. 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 is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the (continued)
Quad Cities I and 2                B 3.6.2.4-3                          Revision 0
 
RHR Suppression  Pool Spray B 3.6.2.4 BASES SURVEILLANCE      SR  3.6.2.4.1  (continued)
REQUIREMENTS accident analysis. This is acceptable since the RHR suppression pool spray mode is manually initiated.      This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation of the system is low, and the system is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.
SR  3.6.2.4.2 This Surveillance is performed every 10 years to verify that the spray nozzles are not obstructed and that spray flow will be provided when required. The 10 year Frequency is adequate to detect degradation in performance due to the passive nozzle design and has been shown to be acceptable through operating experience.
REFERENCES        1. UFSAR,  Section 6.2.2.2.
Quad Cities 1 and 2                B 3.6.2.4-4                        Revision 0
 
Secondary Containment B 3.6.4.1 BASES  (continued)
ACTIONS              A.1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours.                The 4 hour Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3.                  This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.
B.1  -overall                                                                  plant risk
                                                                                            ,is minimized.
If secondary containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does mot apply-. To achieve this status, the plant must be brought to at least s                                                          . iT OD .E 4. w .it.i..
MODE 3 wi t h i n 1 2 h o u r s a.d t._ . ...                              he
              '-i  allowed Completion TimeeX-&e'&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.1 and C.2 Movement of recently irradiated fuel assemblies in the secondary containment and OPDRVs can be postulated to cause significant fission product release to the secondary containment.      In such 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 inoperable.
Suspension of this activity shall not preclude completing an action that involves moving a component to a safe position.
Also, action must be immediately initiated to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release.                  Actions must continue until OPDRVs are suspended.
Required Action C.1 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 (continued)
Quad Cities 1 and 2                      B 3.6.4.1-3                                  Revision    31
 
Secondary Containment B 3.6.4.1 BASES SURVEILLANCE      SR  3.6.4.1.3  (continued)
REQUIREMENTS addition to the requirements of LCO 3.6.4.3, either SGT subsystem will perform this test.        The inoperability of the SGT System does not necessarily constitute a failure of this Surveillance relative to secondary containment OPERABILITY.
Operating experience has shown the secondary containment boundary usually passes the Surveillance when performed at the 24 month Frequency.        Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES        1. UFSAR, Section 15.6.5.
: 2. UFSAR, Section 9.1.4.3.2.
: 3. NRC Safety Evaluation Report for the Holtec                    I International HI-STORM 100 Storage System (Docket Number 72-1014, Certificate Number 1014, Amendment 2).
Quad Cities 1 and 2                B 3 .6.4.]1-6                          Revision 31
 
SGT System B 3.6.4.3 BASES LCO                releases. Meeting the LCO requirements for two OPERABLE (continued)    subsystems ensures operation of at least one SGT subsystem in the event of a single active failure. OPERABILITY of a subsystem also requires the associated cooling air damper remain OPERABLE.
APPLICABILITY      In MODES 1, 2, and 3, a DBA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.
In MODES 4 and 5, the probability and consequences of these 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 operations with a potential for draining the reactor vessel (OPDRVs) or during movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the SGT 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 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.
[overall plant!
B. 1 -ard-- -                                                  risk is minimized.j 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 LCO does ot <-
                -appl4-y. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within (continued)
Quad Cities I and 2                  B 3.6.4.3-3                      Revision 31
 
SGT System B 3.6.4.3 BASES ACTIONS    R-11-B.
s-e    B.n            (continued)
                            *The  allowed Completion TimeK-a-*  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.1. C.2.1,  and C.2.2 During movement of recently irradiated fuel assemblies, in the secondary containment or during OPDRVs, when Required Action A.1 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.1 is to immediately suspend activities that represent a potential for releasing a significant amount of radioactive material to the secondary 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 must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.
The Required Actions of Condition C 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.
Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
D.1 If both SGTS subsystems are inoperable in MODE 1, 2, or 3, the SGT system may not be capable of supporting the required correct the problem that is commensurate with the importance (continued)
Quad Cities 1 and 2                B 3.6.4.3-4                        Revision  31
 
SGT System B 3.6.4.3 BASES ACTIONS            D.1  (continued) of supporting the required radioactivity release control radioactivity release control function.      Therefore, one SGT subsystem must be restored to OPERABLE status within I hour.
The 1 hour Completion Time provides a period of time to 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.                                                    loverall p E .1      [ .                                                    is m inim l In 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 tie.C.      d.      .
n.ot
                -4pply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours -4d +to OD- 4 within
                  ;6 He[.The      allowed Completion Time4-a- *rea sonabe,            LJ based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
F.1 and F.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, action must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release.      Actions must continue until OPDRVs are suspended.
Required Action F.1 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.
(continued)
Quad Cities I and 2                  B 3.6.4.3-5                        Revision 31
 
SGT System B 3.6.4.3 BASES  (continued)
REFERENCES          1. UFSAR, Section 3.1.9.1.
: 2. UFSAR, Section 6.5.1.1.
: 3. UFSAR, Section  15.6.2.
: 4. UFSAR, Section 15.6.5.
: 5. Regulatory  Guide 1.52,  Rev. 2.
: 6. UFSAR, Section 9.1.4.3.2.
: 7. NRC Safety Evaluation Report for the Holtec International HI-STORM 100 Storage System (Docket Number 72-1014, Certificate Number 1014, Amendment 2).
Quad Cities 1 and 2              B 3.6.4.3-7                      Revision 31
 
RHRSW System B 3.7.1 BASES ACTIONS          A.1  (continued) failure in the OPERABLE subsystem could result in reduced RHRSW capability. The 30 day Completion Time is based on the remaining RHRSW heat removal capability and the low probability of a DBA with concurrent worst case single failure.
With one RHRSW pump inoperable in each subsystem, the remaining OPERABLE pump in each subsystem can provide adequate heat removal capacity following a design basis LOCA with concurrent worst case single failure. One inoperable pump is required to be restored to OPERABLE status within 7 days. The 7 day Completion Time for restoring one inoperable RHRSW pump to OPERABLE status is based on engineering judgment, considering the level of redundancy provided and low probability of an event occurring requiring RHRSW during this time period.
Required Action C.1 is intended to handle the inoperability of one RHRSW subsystem for reasons other than Condition A.
The Completion Time of 7 days is allowed to restore the RHRSW subsystem to OPERABLE status. With the unit in this condition, the remaining OPERABLE RHRSW subsystem is adequate to perform the RHRSW heat removal function.
However, the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function. The Completion Time is based on the redundant RHRSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring RHRSW during this period.
The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if the inoperable RHRSW subsystem results in an inoperable RHR shutdown cooling subsystem.
This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
                      >                                              (continued)
Quad Cities 1 and 2                B 3.7.1-4                          Revision 0
 
RHRSW System B 3.7.1.
BASES ACTIONS (continued)
With both RHRSW subsystems inoperable for reasons other than Condition B (e.g., both subsystems with inoperable flow paths, or one subsystem with an inoperable pump and one subsystem with an inoperable flow path), the RHRSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours. The 8 hour Completion Time for restoring one RHRSW subsystem to OPERABLE status, is based on the Completion Times provided for the RHR suppression pool cooling and spray functions.
The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if an inoperable RHRSW subsystem results in an inoperable RHR shutdown cooling subsystem.
This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
the                    anand If-4f- Require    ction        ssociated Completion Time of ConditionV A,,    C, or 0 ar" not met, the unit must be placed in a MODE in which the LCO does not apply.      To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours.      The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
SURVEILLANCE      SR  3.7.1.1 REQUIREMENTS Verifying the correct alignment for each manual and power operated valve in each RHRSW subsystem flow path provides assurance that the proper flow paths will exist for RHRSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet (continued)
Quad Cities 1 and 2                  B 3.7.1-5                          Revision 0
 
RHRSW System B 3.7.1 BASES SURVEILLANCE      SR  3.7.1.1  (continued)
REQUIREMENTS considered in the correct position, provided it can be realigned to its accident position. This is acceptable because the RHRSW System is a manually initiated system.
This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
REFERENCES        1. UFSAR, Section 9.2.1.
: 2. UFSAR, Section 9.2.5.
: 3. UFSAR, Section 6.2.
1    4. Z UFSAR,  Section 6.2.1.3.3.
Quad Cities 1 and 2                B 3.7.1-6                        Revision 0
 
CREV System B 3.7.4 BASES FI E-i                  _
ACTIONS                      and B.3  JCAlC.2, andC (continued)
If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.
During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.
The 24 hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.
(continued)
Quad Cities 1 and 2                B 3.7.4-5                        Revision 34
 
CREV System B 3.7.4 BASES ACTIONS                  and D._
_.1 (continued)    C.1 and C.2 In MODE 1, 2, or 3, if the inoperable CREV System or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 within 36 hours.          The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
IE.1 and E.2I LCO 3.0.3 is not applicable while in MODE 4 or 5.            However, since recently irradiated fuel movement carz.Lcur in MODE 1.
2, or 3, the Required Actions of Condition*'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, during movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs or with the CREV System inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the CRE.            This places the unit in a condition that minimizes accident risk.
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 must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and the subsequent potential for fission product release.        Action must continue until the OPDRVs are suspended.
(continued)
Quad Cities 1 and 2                      B 3.7.4-6                        Revision 34
 
CREV System B 3.7.4 BASES SURVEILLANCE      SR  3.7.4.4 REQUIREMENTS (continued)  This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.
This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air 1,ipleakage is greater than the assumel flow r;  rate, Tondition&#xfd;Z must be entered. Required ActionW.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory guide 1.196, Section C.2.7.3 (Ref.
: 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). These compensatory measures may also O used as mitigating actions as required by Required rC      Action&#xfd;X.2. Temporary analytical methods may also bejused as compensatory measures to restore OPERABILITY (Ref. *).
Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequences analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.
(continued)
Quad Cities 1 and 2                B 3.7.4-8                          Revision 34
 
CREV System B 3.7.4 BASES (continued)
REFERENCES        1. UFSAR,  Section 6.4.
: 2. UFSAR,  Section 9.4.
: 3. UFSAR,  Section 15.6.5.
: 4. Regulatory Guide 1.52,    Revision 2, March 1978.
: 5. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," May 2003.
: 6. NEI 99-03,  "Control  Room Habitability Assessment,"
June 2001.
: 7. UFSAR,  Section 9.1.4.3.2.
: 8. NRC Safety Evaluation Report for the Holtec International HI-STORM 100 Storage System (Docket Amendment 2).
Number 72-1014, Certificate Number 1014, P6    Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."
(ADAMS Accession No. ML040300694).
Quad Cities 1 and 2                B 3.7.4-9                          Revision 34
 
Control  Room Eriergency Ventilation AC System B 3.7.5 BASES APPLICABILITY        emergency zone temperature will not exceed equipment (continued)      OPERABILITY limits following control room emergency zone isolation.
In MODES 4 and 5, the probability and consequences of a Design Basis Accident are reduced due to the pressure and temperature limitations in these MODES.        Therefore, maintaining the Control Room Emergency Ventilation AC System OPERABLE is not required in MODE 4 or 5, except for the following situations under which significant radioactive releases can be postulated:
: a.      During movement of recently irradiated fuel      assemblies in the secondary containment; and                            I
: b.      During operations with a potential    for draining the reactor vessel (OPDRVs).
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              A.1 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.
B .1 -aiTB.-
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 loverallplant, placed in a MODE that minimizes4'risk.      To achieve this status, the unit must be placed in at least MODE 3 within 12 hours and in MODE 4 withim 36 hos          TThe allowed Completion Time/-- e/reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
(continued)
Quad Cities I and 2                    B 3.7.5-3                          Revi si on 31
 
Control  Room Emergency Ventilation AC System B 3.7.5 BASES  (continued)
REFERENCES        1. UFSAR, Section 9.4.
: 2. UFSAR, Section 9.1.4.3.2.
: 3. NRC Safety Evaluation Report for the Holtec International HI-STORM 100 Storage System (Docket Number 72-1014, Certificate Number 1014, Amendment 2).
Quad Cities I and 2              B 3.7.5-5                        Revision 33
 
Main Condenser Offgas B 3.7.6 BASES  (continued)
APPLICABILITY      The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System.      This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation.      In MODES 4 and 5, main steam is not being exhausted to the main condenser and the requirements are not applicable.
ACTIONS            A.1 If the offgas radioactivity rate limit is exceeded, 72 hours is allowed to restore the gross gamma activity rate to within the limit. The 72 hour Completion Time is reasonable, based on engineering judgment, the time required to complete the Required Action, the large margins associated with permissible dose and exposure limits, and the low probability of a Main Condenser Offgas System rupture.
B.I. B. 2..B. 3F  a    3 If the gross gamma activity rate is not restored to within the limits in the associated Completion Time, all main steam lines or the SJAE must be isolated. This isolates the Main Condenser Offgas System from significant sources of radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed, and at least one main steam line drain valve in each drain line is closed. The 12 hour Completion Time is reasonable, based on operating experience, to perform the actions from full power conditions in an orderly manner and without challenging unit systems .                                                    overall plant risk is minimized.
An alternative to Required Actions B.1 and B.2 is to la the unit in a MODE in which the EGO does not app!          0 achieve this status, the unit must be placed in at least MODE 3 within 12 hours and i, ,,DE 4 within 36 H        . The allowed Completion Time/:;-a--reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderlymanner and without challenging unit systems.
(continued)
Quad Cities 1 and 2                  B 3.7.6-2                          Revision 0
 
Main Condenser Offgas B 3.7.6 BASES  (continued)
SURVEILLANCE        SR  3.7,6.1 REQUIREMENTS This SR, on a 31 day Frequency, requires an isotopic analysis of a representative offgas sample (taken at the recombiner outlet or the SJAE outlet if the recombiner is bypassed) to ensure that the required limits are satisfied.
The noble gases to be sampled are Xe-133, Xe-135, Xe-138, Kr-85M, Kr-87, and Kr-88.      If the measured rate of radioactivity increases significantly as indicated by the radiation monitors located prior to the offgas holdup line (by &#x17d; 50% after correcting for expected increases due to changes in THERMAL POWER), an isotopic analysis is also performed within 4 hours after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate.      The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas, and is acceptable, based on operating experience.
This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation.      Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.
REFERENCES          1. Letter E-DAS-023-00 from D. A. Studley (Scientech-NUS) to R. Tsai (ComEd),    dated January 24, 2000.
: 2. 10 CFR 50.67.
Quad Cities 1 and 2                    B 3.7.6-3                          Revision 31
 
AC Sources-Operating B 3.8.1 BASES ACTIONS          D.1 and D.2  (continued) capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.
LI With two required DGs inoperable, there is no more than one remaining standby AC source. Thus, with an assumed loss of offsite electrical power, sufficient standby AC sources may not be available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown.    (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.)    Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.
According to Regulatory Guide 1.93 (Ref. 8), with both DGs inoperable, operation may continue for a period that should not exceed 2 hours. The Completion Time assumes complete loss of onsite (DG) AC capability to power the minimum loads needed to respond to analyzed events.
F.1    d  2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the--+/--O overaliplantiriskzis      d...s nt ppl. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to iOBE 4 within 36 haur,5/.The allowed Completion Timea-*-e-          [-s]
reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
(continued)
Quad Cities 1 and 2                B 3.8.1-16                        Revision 0
 
AC Sources-Operating B 3.8.1 BASES ACTIONS            G. I (continued)
Condition G corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.
SURVEILLANCE      The AC sources are designed to permit inspection and REQUIREMENTS      testing of all important areas and features, especially I]    those that have a standby function, in accordance with UFSAR, Section 8.3.1.6.5 (Ref.-T'). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions).
The SRs for demonstrating the OPERABILITY of the DGs are consistent with the recommendations of Regulatory Guide 1.9
                  -(Ref. Yk), Regulatory Guide 1.108 (Ref .\10-r), and Regulatory" Guide 1.137 (Ref.*/), as addressed in the UFSAR.
The Surveillances are modified by two Notes to clearly identify how the Surveillances apply to the given unit and the opposite unit AC electrical power sources. Note 1 states that SR 3.8.1.1 through 3.8.1.20 are applicable only to the given unit AC electrical power sources and Note 2 states that SR 3.8.1.21 is applicable to the opposite unit AC electrical power sources. These Notes are necessary since the opposite unit AC electrical power sources are not required to meet all of the requirements of the given unit AC electrical power sources (e.g., the opposite unit's DG is not required to start on the opposite unit's ECCS initiation signal to support the OPERABILITY of the given unit).
Where the SRs discussed herein specify voltage and frequency tolerances, the following summary is applicable. The minimum steady state output voltage of 3952 V is approximately 95% of the nominal 4160 V output voltage.
This value, which is specified in ANSI C84.1 (Ref.'&#xfd;I ),
allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum (continued)
Quad Cities 1 and 2                B 3.8.1-17                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      operating voltage is also usually specified as 90% of name REQUIREMENTS      plate rating. The specified maximum steady state output (continued)  voltage of 4368 V is equal to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations found in Regulatory Guide 1.9 (Ref.X), .
SR  3.8.1.1      F*
This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source and that appropriate independence of offsite circuits is maintained.
The 7 day Frequency is adequate since breaker position is not likely to change without the operator being aware of it and because its status is displayed in the control room.
SR  38.1.2 and SR    3.818 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and maintain the unit in a safe shutdown condition.
To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note (Note I for SR 3.8.1.2 and Note I for SR 3.8.1.8) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup prior to loading.
For the purposes of this testing, the DGs are started from standby conditions. Standby conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.
(continued)
Quad Cities I and 2                B 3.8.1-18                        Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.2 and SR  3.8.1.8    (continued)
REQUIREMENTS In order to reduce stress and wear on diesel engines, the manufacturer has recommended a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading.      These start procedures are the intent of Note 2 of SR 3.8.1.2.
SR 3.8.1.8 requires that, at a 184 day Frequency, the DG starts from standby conditions and achieves required voltage and frequency within 13 seconds.      The 13 second start requirement supports the assumptions in the desiqn basis LOCA analysis of UFSAR, Section 6.3 (Ref.W,1,,.        The          E]
13 second start requirement is not applicable to SR 3.8.1.2 (see Note 2 of SR 3.8.1.2), when a modified start procedure as described above is used.      If a modified start is not used, the 13 second start requirement of SR 3.8.1.8 applies.
Since SR 3.8.1.8 does require a 13 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.
In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved.          The voltage and frequency limits are normally achieved within 13 seconds. The time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
To minimize testing of the common DG, Note 3 of SR 3.8.1.2 and Note 2 of SR 3.8.1.8 allow a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.      This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. However, to the extent practicable, the tests should be alternated between units.        If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
The 31 day Frequency for qR 3.8.1.2 is consistent with Regulatory Guide 1.9 (Ref.T-1Y4.      The 184 day Frequency for (continued)
Quad Cities 1 and 2                B 3.8.1-19                            Revision 10
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.2 and SR  3.8.1.8  (continued)
REQUIREMENTS SR 3.8.1.8 is a reduction in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.
SR  3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing and accepting a load approximately equivalent to that corresponding to the continuous rating.      A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0 when running synchronized with the grid. The 0.8 power factor value is the design rating of the machine at a particular kVA.      The 1.0 power factor value is an operational condition where the reactive power component is zero, which minimizes the reactive heating of the generator. Operating the generator at a power factor between 0.8 lagging and 1.0 avoids adverse conditions associated with underexciting the generator and more closely represents the generator operating requirements when performing its safety function (running isolated on its associated 4160 V ESS bus). The load band is provided to avoid routine overloading of the DG.      Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.
The 31 day Frequency for this Surveillance    is consistent
* with Regulatory Guide 1.9 (Ref.N&#xfd;W .                          LL Note 1 modifies this Surveillance to indicate that diesel engine runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized.
(continued)
Quad Cities 1 and 2                B 3.8.1-20                          Revision 0
 
AC Sources-Operating B3.8.1 BASES SURVEILLANCE      SR  3.8,1.4    (continued)
REQUIREMENTS provided and facility operators would be aware of any large uses of fuel oil during this period.
SR  3.8.1.5 and SR    3.8.1.7 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the fuel oil day tank once every 31 days eliminates the necessary environment for bacterial survival.      This is accomplished by draining a portion of the contents from the bottom of the day tank to the top of the storage tank.
Checking for and removal of any accumulated water from the bulk storage tank once every 92 days also eliminates the necessary environment for bacterial survival.      This is the most effective means of controlling microbiological fouling.
In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation.      Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and breakdown of the fuel oil by bacteria.      Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref.\VIU. This SR is for preventive maintenance. The presence of water does not necessarily represent a failure of this SR provided that accumulated water is removed during performance of this Surveillance.
SR  3.8.1.6 This Surveillance demonstrates that each fuel oil transfer pump operates and automatically transfers fuel oil from its associated storage tank to its associated day tank.        It is required to support continuous operation of standby power sources. This Surveillance provides assurance that each (continued)
Quad Cities I and 2                  B 3.8.1-22                        Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.10  (continued)
REQUIREMENTS a residual heat removal service water pump (722 kW). The specified load value conservatively bounds the expected kW rating of the single largest loads under accident conditions. This Surveillance may be accomplished by:
: a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or while solely supplying the bus; or
: b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.
Consistent with Regulatory Guide 1.9 (Ref. ;01, the load rejection test is acceptable if the diesel speed does not exceed the nominal (synchronous) speed plus 75% of the difference between nominal speed and the overspeed trip setpoint, or 115% of nominal speed, whichever is lower.
This corresponds to 66.73 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint.
The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref.1      .8* L_
recommendations for response during load sequence intervals.
The 3 seconds specified in SR 3.8.1.10.b is equal to 60% of the 5 second load sequence interval associated with sequencing the ECCS low pressure pumps during an undervoltage on the bus concurrent with a LOCA. The 4 seconds specified in SR 3.8.1.10.c is equal to 80% of the 5 second load sequence interval associated with sequencing the ECCS low pressure pumps during an undervoltage on the bus concurrent with a LOCA. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG. SR 3.8.1.10.a corresponds to the maximum frequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steady state voltage and frequency values to which the system must recover following load rejection.
The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
(continued)
Quad Cities 1 and 2                B 3.8.1-24                        Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.10  (continued)
REQUIREMENTS This SR is modified by a Note. The reason for the Note is to minimize testing of the common DG and allow a single test of the cormmon DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
SR  3.8.1.11 Consistent with Regulatory Guide 1.9 (Ref. X    , paragraph C.2.2.8, this Surveillance demonstrates the DG capability to reject a full load without overspeed tripping or exceeding the predetermined voltage limits. The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions.
This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load.
These acceptance criteria provide DG damage protection.
While the DG is not expected to experience this transient during an event, and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.
In order to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible, a load band (90% to 100%) has been specified based on Regulatory Guide 1.9 (Ref.\VW-f.
The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
(continued)
Quad Cities I and 2                B 3.8.1-25                          Revision 0
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE      SR    3.8.1.11    (continued)
REQUIREMENTS This SR is modified by two Notes.        To minimize testing of the common DG, Note 1 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units.        This is allowed since the main purpose of the Surveillance can be met by performing the test on either unit.      If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one. unit.      Note 2 modifies this Surveillance by stating that momentary transients outside the voltage limit do not invalidate this test.
SR    3,8,1.12                                    [l__
4, Consistent with Regulatory Guide 1.9 (Ref..,;.6, paragraph C.2.2.4, this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source.        This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG.          It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.
The OG auto-start and energization of permanently connected loads time of 13 seconds is derived from requirements of the accident analysis for responding to a design basis large 2      break LOCA (Ref.-Y)A . The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.
The requirement to verify the connection and power supply of permanently connected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation.        For instance, a component or system may be out-of-service and closure of its (continued)
Quad Cities 1 and 2                  B 3.8.1-26                          Revision 10
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.12  (continued)
REQUIREMENTS associated breaker during this test may damage the component or system. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing.      For the purpose of this testing, the DGs shall be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
SR  3.8.1.13 Consistent with Regulatory Guide 1.9 (Ref.A-l<, paragraph C.2.2.5, this Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (13 seconds) from the design basis actuation signal (LOCA signal).      In addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved. The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The DG is required to operate for &#x17d; 5 minutes.      The 5 minute period provides sufficient time to demonstrate stability.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with the expected fuel cycle lengths.
(continued)
Quad Cities I and 2                B 3.8.1-27                        Revision 10
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.13  (continued)
REQUIREMENTS This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing.      For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
SR  3.8.1.14                                l[ ]
Consistent with Regulatory Guide 1.9 (Ref.)1, paragraph C.2.2.12, this Surveillance demonstrates that DG non-critical protective functions (e.g., high jacket water temperature) are bypassed on an ECCS initiation test signal and critical protective functions (engine overspeed and generator differential current) trip the DG to avert substantial damage to the DG unit. The non-critical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.
The 24 month Frequency is based on engineering judgment, takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR  3,8.1.15 Regulatory Guide 1.9 (Ref..Ie', paragraph C.2.2.9, requires demonstration that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours, 22 hours of which is at a load equivalent to 90%
to 100% of the continuous rating of the DG and 2 hours of which is at a load equivalent to 105% to 110% of the continuous rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelube and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.
(continued)
Quad Cities 1 and 2                B 3.8.1-28                        Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.15  (continued)
REQUIREMENTS purpose of the Surveillance can    be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be    considered inoperable on both units, unless the cause of    the failure can be directly related to only one unit.
SR  3.8.1.16 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 13 seconds. The 13 second time is derived from the requirements of the accident analysis for responding to a design basis large break LOCA (Ref.        T. In  L addition, the DG is required to maintain proper voltage and frequency limits after steady state is achieved.      The time for the DG to reach the steady state voltage and frequency limits is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
The 24 month Frequency takes into consideration the plant conditions required to perform the Surveillance, and is intended to be consistent with the expected fuel cycle lengths.
This SR is modified by three Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot.      The requirement that the diesel has operated for at least 2 hours at approximately full load conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions.      Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing. To minimize testing of the common DG, Note 3 allows a single test of the common DG (instead of two tests, one for each unit) to satisfy the requirements for both units. This is allowed since the main purpose of (continued)
Quad Cities 1 and 2                B 3.8.1-30                        Revision 10
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE      SR    3.8.1.16  (continued)
REQUIREMENTS the Surveillance can be met by performing the test on either unit. If the DG fails one of these Surveillances, the DG should be considered inoperable on both units, unless the cause of the failure can be directly related to only one unit.
SR    3.8.1.17 Consistent with Regulatory Guide 1.9 (Ref.,All, paragraph C.2.2.11, this Surveillance ensures that the manual synchronization and load transfer from the DG to the offsite source can be made and that the DG can be returned to ready-to-load status when offsite power is restored.        It also ensures that the auto-start    logic is  reset to  allow  the DG to reload if a subsequent loss of offsite power occurs.
The DG is considered to be in ready-to-load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto-close signal on bus undervoltage, and the individual load timers are reset.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR    3.8.1.18 Under accident conditions with loss of offsite power loads are sequentially connected to the bus by the automatic load sequence time delay relays. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting currents. The -10% load sequence time interval limit ensures that a sufficient time interval exists for the DG to restore frequency and voltage prior to applying the next load. There is no upper limit for the load sequence time interval since, for a single load interval (i.e., the time between two load blocks), the capability of the DG to restore frequency and voltage prior to applying the second load is not negatively affected by a longer than designed load interval, and if there are additional load blocks (i.e., the design includes multiple load intervals), then (continued)
Quad Cities 1 and 2                  B 3.8.1-31                          Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8,1.18    (continued)
REQUIREMENTS the lower limit requirements (-10%) will ensure that sufficient time exists for the DG to restore frequency and voltage prior to applying the remaining load blocks (i.e.,
1all        load intervals must be &#x17d; 90% of the design interval).
Reference*/4 provides a summary of the automatic loading of ESS buses.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
SR  3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.
This Surveillance demonstrates DG operation, as discussed in the Bases for SR 3.8.1.12, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.
The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.
This SR is modified by a Note. The reason for the Note is to minimize wear and tear on the DGs during testing.      For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations.
(continued)
Quad Cities I and 2                  B 3.8. 1-32                      Revision 0
 
AC Sources-Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.20 REQUIREMENTS (continued)  This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper frequency and voltage within the specified time when the DGs are started simultaneously.
The 10 year Frequency is consistent with the recommendations of Regulatory Guide 1.9 (Ref.{)2').                              [
This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing.      For the purpose of this testing, the DGs must be started from standby conditions, that is,  with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.
SR  3.8.1.21 With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.1.1 through SR 3.8.1.20) are applied only to the given unit AC sources.
This Surveillance is provided to direct that appropriate Surveillances for the required opposite unit AC sources are governed by the applicable opposite unit Technical Specifications. Performance of the applicable opposite unit Surveillances will satisfy the opposite unit requirements, as well as satisfying the given unit Surveillance Requirement. Exceptions are noted to the opposite unit SRs of LCO 3.8.1. SR 3.8.1.9 and SR 3.8.1.20 are excepted since only one opposite unit offsite circuit and DG is required by the given unit's Specification. SR 3.8.1.13, SR 3.8.1.18, and SR 3.8.1.19 are excepted since these SRs test the opposite unit's ECCS initiation signal, which is not needed for the AC electrical power sources to be OPERABLE on the given unit.
The Frequency required by the applicable opposite unit SR also governs performance of that SR for the given unit.
(continued)
Quad Cities I and 2                B 3.8.1-33                          Revision 0
 
AC Sources--Operating B 3.8.1 BASES SURVEILLANCE      SR  3.8.1.21    (continued)
REQUIREMENTS As Noted, if the opposite unit is in MODE 4 or 5, or moving recently irradiated fuel assemblies in the secondary containment, SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.17 are not required to be performed. This ensures that a given unit SR will not require an opposite unit SR to be performed, when the opposite unit Technical Specifications exempts performance of an opposite unit SR (however, as stated in the opposite unit SR 3.8.2.1 Note 1, while performance of an SR is exempted, the SR must still be met).
REFERENCES          1. UFSAR,  Section 3.1.7.3.
: 2. UFSAR,  Section 8.2.
: 3. UFSAR,  Section 8.3.1.6.4.
: 4. Safety Guide 9.
: 5. UFSAR,  Chapter 6.
: 6. UFSAR,  Chapter 15.
: 7. Generic Letter 84-15,    July 2, 1984.
: 8. Regulatory Guide 1.93, Revision 0, December 1974.
UFSAR,  Section 8.3.1.6.5.
10X.
Regulatory Guide 1.9,    Revision 3, July 1993.
Regulatory Guide 1.108,    Revision 1, August 1977.
Regulatory Guide 1.137,    Revision 1, October 1979.
P-1,14.
ANSI C84.1,    1982.
13)61 UFSAR,  Section 6.3.
IEEE Standard 308,    1980.
Quad Cities 1 and 2                  B 3.8.1-34                        Revision 31
 
DC Sources--Operating B 3.8.4 BASES ACTIO INS        F.1      ~overall                                                  plant risk is minimized (c continued)
If the DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which th. [C0 dos n...t a      . To achieve this status, the unit must be brought to at least MODE 3 within 12 hours and to MODE 4 withinp 3-4hou      The allowed Completion Time, -- r-e-rsonable,              El based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.      TF-ie Complotion Time to brig the unit t, MO*9E 4 4s esn;i-stnt with the ti.
iequ- cd in Regulatory 6t~de 1.93 (ReF. 6).
SURVEILLANCE      SR  3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state.        The voltage requirements are based on the nominal design voltage of the battery and are consistent with the initial voltages assumed in the battery sizing calculations. The 7 day Frequency is conservative when compared with manufacturers recommendations and IEEE-450 (Ref./').
SR  3.8.4.2                        -k&#xfd; Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each intercell and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance.
The connection resistance limits established for this SR are within the values established by industry practice.        The connection resistance limits of this SR are related to the resistance of individual bolted connections and do not include the resistance of conductive components (e.g.,
cables or conductors located between cells, racks, or tiers).
(continued)
Quad Cities 1 and 2                B 3.8.4-10                            Revision 0
 
DC Sources-Operating B 3.8.4 BASES SURVEILLANCE        SR  3.8.4.4 and SR    3.8.4.5  (continued)
REQUIREMENTS The connection resistance limits established for this SR are within the values established by industry practice.        The connection resistance limits of this SR are related to the resistance of individual bolted connections and do not include the resistance of conductive components (e.g.,
cables or conductors located between cells, racks, or tiers).
The 24 month Frequency for the Surveillance is based on engineering judgement. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR  3.8.4.6 FBattery            charger capability requirements are based on the Sdesign capacity of the chargers (Ref. 1).        According to Regulatory Guide 1.32 (Ref.\), the battery charger supply is required to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences.      The minimum required amperes and duration ensures that these requirements can be satisfied.
The Frequency is acceptable given the administrative controls existing to ensure adequate charger performance during these 24 month intervals.      In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.
SR  3.8.4.7 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system.          The test can be performed using simulated or actual loads.          The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 1.
(continued)
Quad Cities 1 and 2                  B 3.8.4-12                            Revi si on 0
 
DC Sources-Operating B 3.8.4 BASES SURVEILLANCE      SR  3.8.4.8  (continued)
REQUIREMENTS A modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity.      Initial conditions for the modified performance discharge test should be identical to those specified for a service test when the modified performance discharge test is performed in lieu of the service test. Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.
For the 125 VDC battery,  the acceptance criteria for this Fste~tSurveilla~nce is consistent with IEEE-450 (Ref.        and IEEE-485 (Ref.&#xfd;X). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating, since IEEE-485 (Ref. A) recommends using an aging factor of 125% in the battery size calculation. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements., However, since the L  250 VDC batteries are not sized consistent with IEEE-485
      *L j(Ref          YX), they must be replaced when their actual capacity is below the minimum acceptable battery capacity based on the load profile, which is a value greater than 80% of the manufacturer's rating.
The Frequency for this test is normally 60 months.      If the battery shows degradation, or if the battery has reached 85%
of its expected life and capacity is < 100% of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance ,F-set Frequency is only reduced to 24 months for batteries that        (F retain capacity &#x17d; 100% of the manufacturer's rating.
Degradation is indicated, consistent with IEEE-450 (Ref..,<),
when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is (continued)
Quad Cities 1 and 2                B 3.8.4-14                          Revision 0
 
DC Sources-Operating B 3.8.4 BASES SURVEILLANCE      SR  3.8.4.8  (continued)
REQUIREMENTS
                  &#x17d;  10% below the manufacturer's rating.      The 12 month and Fs  -"  60 month Frequencies are consistent with the recommendations i    in IEEE-450 (Ref.W/T). The 24 month Frequ        is derived from the recommendations    of IEEE-450  (Ref.Y7).
REFERENCES        1. UFSAR, Section 8.3.2.
: 2. Safety Guide 6,  March 10,  1971.
: 3. IEEE Standard 308,  1978.
: 4. UFSAR,  Chapter 6.
          *~5.        UFSAR,  Chapter 15.
Rcgulatory G"ide 1.93, Rcviyion 0,              I&#xfd;I &#xfd; H CC ,eF  4:Iv 'I .
: 7. IEEE Standard 450,  1987.
: 8. Regulatory Guide 1.32,    Revision 2, February 1977.
: 9. IEEE Standard 485,  1978.
Quad Cities 1 and 2                B 3.8.4-15                            Revision 0
 
Distribution Systems-Operating B 3.8.7 BASES ACTIONS            C.A    (continued) systems are powered only from Unit 1, an inoperable Unit 1 AC electrical power distribution subsystem could result in a loss of the CREV System and Control Room Emergency Ventilation AC System functions (for both units).
With a standby gas treatment (SGT) subsystem inoperable, LCO 3.6.4.3 requires restoration of the inoperable SGT subsystem to OPERABLE status in 7 days.      Similarly, with the CREV System inoperable, LCO 3.7.4 requires restoration of the inoperable CREV System to OPERABLE status within 7 days.
With the Control Room Emergency Ventilation AC System inoperable, LCO 3.7.5 requires restoration of the inoperable Control Room Emergency Ventilation AC System to OPERABLE status in 30 days. Therefore, a 7 day Completion Time is provided to restore the required opposite unit AC and DC electrical power subsystems to OPERABLE status.      The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant system(s) and the low probability of a DBA occurring during this time period.
The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.8.1 be entered and Required Actions taken if the inoperable opposite unit AC electrical power distribution subsystem results in an inoperable required offsite circuit.      This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.
If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not overallplantriskis minimized >      y    To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to ,MO9E      14 #            H
                                -..---.. VThe allowed Completion Time/ ;-a-treasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
(continued)
Quad Cities 1 and 2                    B 3.8.7-9                          Revision 0
 
Distribution Systems-Operating B 3.8.7 BASES ACTIONS            E.I (continued)
Condition E corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost. When the inoperability of two or more AC or DC electrical power distribution subsystems, in combination, results in the loss of a required function, the plant is in a condition outside the accident analysis.
Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown. The term "in combination" means that the loss of function must result from the inoperability of two or more AC and DC electrical power distribution subsystems; a loss of function solely due to a single AC or DC electrical power distribution subsystem inoperability even with another AC or DC electrical power distribution subsystem concurrently inoperable, does not require entry into Condition E.
SURVEILLANCE      SR  3.8.7.1 REQUIREMENTS This Surveillance verifies that the AC and DC electrical power distribution subsystems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions are maintained, and the appropriate voltage is available to each required bus.
The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the AC and DC electrical power distribution subsystems, redundant power supplies available to the essential service and instrument 120 VAC buses, and other indications available in the control room that alert the operator to bus and subsystem malfunctions.
REFERENCES        1. UFSAR, Chapter 6.
: 2. UFSAR, Chapter 15.
: 3. Regulatory Guide 1.93, December 1974.
Quad Cities I and 2                B 3.8.7-10                        Revision 0
 
Quad Cities Nuclear Power Station TSTF-423 LAR Technical Specification Bases Page Inserts LCO 3.4.3 Safety and Relief Valves Insert I B.1 If the relief function of the inoperable relief valve or S/RV cannot be restored to OPERABLE status within the associated Completion Time of Required Action A.1, 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 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. 5) 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. The allowed Completion Time is reasonable, based on operating experience, to reach required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
Required Action B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 5.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.5.1 ECCS - Oneratina Insert 1 D.1 If any requiredAction and associatedCompletion Time of Condition A, B, or C is not met, 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. 11) 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. The allowed Completion Time is reasonable,based on operatingexperience, to reach the requiredplant conditions from full power conditions in an orderlymanner and without challengingplant systems.
Required Action D. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 1.1 If any required Action and associated Completion Time of Condition G or H is not met, 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. 11) 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. 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.
RequiredAction . 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 acceptablelevel 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.
 
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 3
: 11. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.5.3 Reactor Core Isolation Cooling (RCIC) System Insert 1 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. 3) 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 B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.6 Low Set Relief Valves Insert 1 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 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 B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 C.1 and C.2 Iftwo low set relief valves are inoperable, there could be excessive short duration S/RV cycling during an overpressure event and 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 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.
Insert 3
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.7 Reactor Buildincq-to-Suppression Chamber Vacuum Breakers Insert 1 D. 1I If one line has one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition C, the remaining breakers in the remaining lines can provide the opening function. The plant must be brought to a condition 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. 3) 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. 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 system.
RequiredAction D. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptable level of risk, it is not the intent of the Required Action to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordance with LCO 3.0.4.a. However, where allowed, a risk assessmentmay be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers Insert 1 B.1 If a required suppression chamber-to-drywell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition 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. 3) 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. 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.
Required Action B. 1 is modified by a Note that prohibits the applicationof 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 acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.2.3 RHR SuDDression Pool Coolina Insert 1 B.1 If one RHR suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition 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. 2) 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.
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.
RequiredAction B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 acceptablelevel 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.2.4 RHR SuDpression Pool Sprav Insert I 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 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 C. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 2.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.6.4.1 Secondary Containment Insert 1 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), 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 B. I is modified by a Note that prohibitsthe applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof enteringMODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
LCO 3.6.4.3 Standby Gas Treatment (SGT) System Insert 1 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. 8) 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 B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk of MODE 4 (Ref. 8) 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.
RequiredAction E. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 3
: 8.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.1 Residual Heat Removal Service Water System Insert 1 D.1 If one RHRSW subsystem is inoperable or one RHRSW pump in one or two subsystems is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition 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. 5) 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. 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.
RequiredAction D. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 5.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.4 Control Room Emergency Ventilation (CREV) System Insert 1 B.1 In MODE 1, 2, or 3, if the inoperableCREV System cannot be restored to OPERABLE status within the associatedCompletion Time, the unit must be placed in a MODE that minimizes overallplant 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. 9) 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 B. I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 operationin, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 9.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.5 Control Room AC System Insert 1 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 B. 1 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction 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 acceptablelevel of risk, it is not the intent of the RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.7.6 Main Condenser Offqas Insert 1 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. 3) 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 B.3 is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the Required Action by indicatingthat 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 accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 3.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.1 AC Sources - OperatinQ Insert 1 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. 9) 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 F.I is modified by a Note that prohibits the applicationof LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat 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 RequiredAction to allow entry into, and continue operation in, MODE 3 from MODE 4 in accordancewith LCO 3.0.4.a. However, where allowed, a risk assessment may be performed in accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 9.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.4 DC Sources - Operating Insert 1 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. 6) 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 F.1 is modified by a Note that prohibits the application of LCO 3.0.4.a. This Note clarifies the intent of the RequiredAction by indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessmentis required to determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 6.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
LCO 3.8.7 Distribution Systems - Operatinq Insert 1 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.
RequiredAction D. 1 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 indicatingthat it is not permissible under LCO 3.0.4.a to enter MODE 3 from MODE 4 with the LCO not met. While remainingin MODE 3 presents an acceptablelevel 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 accordancewith LCO 3.0.4.b.
Considerationof the results of this risk assessment is requiredto determine the acceptabilityof entering MODE 3 from MODE 4 when this LCO is not met.
Insert 2
: 4.      NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.
 
ATTACHMENT 8 List of Regulatory Commitments The following table identifies those actions committed to by Exelon Generation Company, LLC (EGC) in this document. Any other statements in the submittal are provided for information purposes and are not considered to be regulatory commitments.
COMMITMENT TYPE COMMITTED DATE ONE-TIME ACTION      PROGRAMMATIC (Yes/No)
(Yes/No)
EGC will follow the guidance established in Section 11 of NUMARC 93-01, "Industry Guidance              Ongoing          No              Yes for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
Nuclear Management and Resource Council, Revision 3, July 2000.
EGC will follow the guidance established in TSTF-IG-05-02, "Implementation Guidance for TSTF-423, Revision 0, 'Technical Specifications End States, NEDC-32988-A,"' Revision 1, March 2007, with an exception as described        Implement below.                                          with          No              Yes amendment The following statement on Page 2 no longer applies:
"If Primary Containment is not operable, Secondary Containment and Standby Gas Treatment must be verified operable in order to remain in Mode 3."
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Latest revision as of 13:23, 14 January 2025

Additional Information Supporting Requests for License Amendments to Adopt TSTF-423, Technical Specifications End States, NEDC-32988-A
ML090350151
Person / Time
Site: Dresden, Clinton, Quad Cities  Constellation icon.png
Issue date: 01/30/2009
From: Hansen J
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NEDC-32988-A, RS-09-003, TSTF-423
Download: ML090350151 (336)
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