RS-17-086, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.

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Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.
ML17194B069
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/13/2017
From: Simpson P R
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9295, CAC MF9296, RS-17-086
Download: ML17194B069 (34)


Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-1 7-086 10 CFR 50.

90 July 13, 201 7 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR

-19 and DPR

-25 NRC Docket Nos. 50

-237 and 50

-249

Subject:

Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF

-542, "Reactor Pressure Vessel Water Inventory Control"

References:

(1) Letter from P. R. Simpson (Exelon Generation Company, LLC (EGC)) to NRC, "Application to Revise Technical Specifications to Adopt TSTF

-542, 'Reactor Pressure Vessel Water Inventory Control,'" dated February 10, 2017 (2) Letter from R. S. Haskell (NRC) to B. C. Hanson (EGC), "Dresden Nuclear Power Station, Units 2 a nd 3 - Request f or Additional Information Related to License Amendment Request to Revise Technical Specifications t o Adopt Technical Specification Task Force Traveler

-542, Revision 2, 'Reactor Pressure Vessel Water Inventory Control

' (C AC Nos. M F 9295 a nd M F 9296)," dated Ju ly 11, 2017 In Reference 1, Exelon Generation Company, LLC (EGC) submitted a request for amendment s to the Technical Specifications (TS) for Dresden Nuclear Power Station (DNPS), Units 2 and 3. Specifically, EGC requested that the NRC complete its review and approval of the request to adopt TSTF

-542 by August 1, 2017, in order to support its implementation prior to the upcoming DNPS, Unit 2 refueling outage in October 2017.

In Reference 2, the NRC determined that additional information is required to complete the evaluation of the R eference 1 request

. The details of Reference 2 are contained in Attachment

1. Additional ly, on May 26, 2017, the NRC issued Operating License Amendment Nos. 254 and 247 for DNPS, Units 2 and 3, respectively. These amendments allow for the adoption of TSTF

-545, "TS Inservice Testing Program Removal and Clarify Surveillance Requirement Usage Rule Application to Section 5.5 Testing

." Attachment 2 to this letter provides revised markups of the DNPS, Units 2 and 3 TS to address the issues identified in Reference 2

, and the adoption of TSTF

-545. These markups supersede those provided in Reference 1, Attachment 2. Attachment 3 provides the accompanying revised TS pages associated with the modifications shown in Attachment 2 as discussed above. Likewise, these July 13 , 2017 U.S. Nuclear Regulatory Commission Page 2 pages supersede those prov i ded i n Reference 1 , Attachment

3. To account fo r the adopt i on of TSTF-545 , the lnserv i ce Testing Program definit i on is included in Attachments 2 and 3 on Page 1.1-3 , and the Frequencies for Surve i llance Requirements 3.6.1.3. 5 and 3.6.1.3.6 were updated to account for this new TS definition as shown on Attachment 3, Page 3.6.1.3-7. EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Reference
1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

EGC is notifying the State of Illinois of this supplement to a previous application for a change to the TS by sending a copy of this letter and its attachment to the designated State Official in accorda n ce with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b). Based on the NRC's rev i ew t i mel i ne assoc i ated w i th the Reference 1 request and recent te l ephone conversat i ons w it h the Office of Nuc l ear Reactor Regulation Pro j ect Manager for DNPS , Units 2 and 3 , Russe ll Haske ll, i t does not appear t ha t the Reference 1 request wi ll be approved w i th adequate t i me to i mp l e m en t the changes ahead of th e October 2017 DNPS , Unit 2 r ef u el in g outage. Therefore , EGC hereby p r oposes that once the Reference 1 request i s appro v ed , the amendments shall be implemented for DNPS , Units 2 and 3 prior to the beginning of the next Un i t 3 refue li ng outage , D3R25 , currently planned f or October 201 B. There are no r egulatory commitments contained w i thin this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13th day of July 2017. U&lR Patrick R. Simpson Manager -Licens i ng Exelon Generation Co m pany , LLC Attachments: 1. Deta il s of NRC Req u est for Add i t i ona l I n format i on 2. Proposed Techn i ca l Spec ifi cat i ons C h anges (Ma r k-U p) 3. Re v ised Technical Spec i ficat i ons Pages cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector-Dresden Nuclear Power Station Illinois Emergency Management Agency -Division of Nuclear Safety Dresden Nuclear Power Station, Units 2 and 3 Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF

-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 1 -

DETAILS OF NRC REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT 1

- DETAILS OF NRC REQUEST FOR ADDITIONAL INFORMATION 1 REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER

-542. REVISION 2.

"REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" EXELON GENERATION COMPANY. LLC DRESDEN NUCLEAR POWER STATION

- UNITS 2 AND 3 DOCKET NOS. 50

-237 AND 50

-249 By application dated February 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 17045A006), Exelon Generation Company, LLC (EGC, the licensee), requested to adopt Technical Specifications Task Force (TSTF) Traveler (TSTF

-542), "Reactor Pressure Vessel [RPV] Water Inventory Control [WIC]," Revision 2, which would change the technical specifications (TSs) for Dresden Nuclear Power Station, Units 2 and 3. TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (ADAMS Accession No. ML 16343B008). The proposed changes would replace the existing requirements in the TSs related to "operations with the potential to drain the reactor pressure vessel" with revised TSs providing an alternative for RPV WIC. These alternative requirements would protect Safety Limit 2.1.1.3, which requires RPV water level to be greater than the top of active fuel. The NRC staff has reviewed the information the licensee provided that supports the proposed amendment. The staff requests the licensee to address the following issues:

DNPS-RAl-1:

Background:

In Attachment 2, pg. 3.5.2

-1 (of the submittal), the staff identified a discrepancy in the limiting condition for operation (LCO) 3.5.2, Applicability proposed markup. The current TS LCO consists of text not shown in the proposed LCO markup as being deleted. Specifically, there is missing text associated with the MODE 5 exception (i.e., "except with the spent fuel storage pool gates removed and water level ~ 23 ft. over the top of the reactor pressure vessel flange").

ATTACHMENT 1

- DETAILS OF NRC REQUEST FOR ADDITIONAL INFORMATION 2 Request: Please correct the proposed TS markup as appropriate.

Exelon Generation Company, LLC (EGC) Response The requested change is incorporated in the revised markup included in Attachment 2 on Page 3.5.2-1. DNPS-RAl-2:

Background:

In Attachment 2, pg. 3.5.2

-6 (of the submittal), the NRC staff identified a discrepancy. The current TS surveillance requirement (SR) consists of text not shown in the proposed SR markup as being deleted. Specifically, SR 3.5.2.4 is missing the opera ting parameter data (i.e., System, Flow Rate, Pumps, Pressure), as per TSTF

-542, Revision 2.

Request:

Please correct the proposed TS markup as appropriate.

EGC Response The requested change is incorporated in the revised markup included in Attachment 2 on Page 3.5.2-5. Additionally, the Surveillance Frequencies for the proposed SR 3.5.2.5 and SR 3.5.2.6 were revised to "In accordance with the Surveillance Frequency Control Program" versus "In accordance with the Inservice Testing Program." This corrects an error in the February 10, 2017, EGC submittal and aligns with TSTF

-542. DNPS-RAl-3:

Background:

In Attachment 2, pg. 3.5.2

-6 (of the submittal), the NRC staff identified a discrepancy. The current TS SR consists of text not shown in the proposed SR markup as being deleted. Specifically, SR 3.5.2.5 is missing from the proposed markup page.

Request:

Please correct the proposed TS markup as appropriate.

EGC Response The requested change is incorporated in the revised markup included in Attachment 2 on Page 3.5.2-5.

ATTACHMENT 1

- DETAILS OF NRC REQUEST FOR ADDITIONAL INFORMATION 3 DNPS-RAl-4:

Background:

In Attachment 2 (of the submittal), the NRC staff identified a discrepancy. SR 3.8.2.1 (note 2) has not been revised to show the new title for LCO 3.5.2.

Request: Please correct the proposed TS markup as appropriate.

EGC Response The requested change is incorporated in the revised markup and revised page on Page 3.8.2-3 included in Attachment s 2 and 3, respectively

.

Dresden Nuclear Power Station, Units 2 and 3 Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF

-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 2 - PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK

-UP) 1.1-2 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 3.5.2-1 3.5.2-2 3.5.2-3 3.5.2-4 3.5.2-5 3.8.2-2 3.8.2-3 Definitions 1.1 Dresden 2 and 3 1.1-2 Amen dment No.

221/212 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTI ONAL TEST shall be the injection

of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL

TEST may be performed by m eans of any series of sequential, overlapping, or total channel steps.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the ves sel. The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replac ement); and b. Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude

completion of movement of a component to a safe position. CORE OPERATING LIMITS The COLR is the un it specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in

accordance with Specification 5.6.5. Plant operation within these limi ts is addressed in

individual Specifications.

DOSE EQUIVALENT I

-131 DOSE EQUIVALENT I

-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I

-131, I-132, I-133, I-134, an d I-135 actually present. The dose conversion factors used for this calculation shall be the inhalation

committed dose conversion factors in Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Fact ors for Inhalation, Submersion, and Ingestion," 1989.

(continued)

Definitions 1.1 Dresden 2 and 3 1.1-3 Amendment No.

221/212 1.1 Definitions (continued)

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

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

a. The water inventory above the TAF is divided by the limiting drain rate;
b. The li miting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of no rmal power, single human error), for all penetration flow paths below the TAF except: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed positi on, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or (continued)

Definitions 1.1 Dresden 2 and 3 1.1-4 Amendment No.

221/212 1.1 Definitions DRAIN TIME

3. Penetration flow paths with isolation (continued) devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.
c. The penetration flow path s required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;
d. No additional draining events occur; and
e. Realistic cross

-secti onal areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE
1. LEAKAGE into the drywell, such as that from

pump seals or valve packing, that is captured and cond ucted to a sump or

collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;
b. Un identified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE; (continued)

Definitions 1.1 Dresden 2 and 3 1.1-5 Amendment No.

191/185 1.1 Definitions LEAKAGE c. Total LEAKAGE (continued)

Sum of the identified and unidentified

LEAKAGE; and

d. Pressure Boundary LEAKAGE LEAKAGE through a n onisolable fault in a

Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per RATE (LHGR) unit length of fuel rod. It is the integral of the heat flux over the heat tra nsfer area

associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not includin g, the actuated

device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the

appropriate correlation(s) to cause some point in the assembly to experienc e boiling transition, divided by the actual assembly operating power.

MODE A MODE shall correspond to any one inclusive

combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE-OPERABILITY A system, subsystem, division, component, or

device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency

electrical power, cooling and seal water, (continued)

Definitions 1.1 Dresden 2 and 3 1.1-6 Amendmen t No. 242/235 1.1 Definitions OPERABLE-OPERABILITY lubrication, and other auxiliary equipment that (continued) are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 2957 MWt.

REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from the opening of the sensor contact until the TIME opening of the trip actuator. The response time

may be measured by means of any series of

sequential, overlapping, or total steps so that

the entire response time is measured.

SHUTDOWN MARGIN (SDM)

SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon fre e; b. The moderator temperature is

> 68°F , corresponding to the most reactive state; and

c. All control rods are fully inserted except for

the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these

control rods must be accounted for in the

determination of SDM.

THERMAL POWER THERMAL POWER shall be the total reactor core heat

transfer rate to the reactor coolant.

TURBINE BYPASS SYSTEM T he TURBINE BYPASS SYSTEM RESPONSE TIME shall be RESPONSE TIME that time interval from when the turbine bypass control unit generates a turbine bypass valve flow signal until the turbine bypass valves travel to their required positions. The response time m ay be measured by means of any series of sequential, overlapping, or total steps so that the entire

response time is measured.

Definitions 1.1 Dresden 2 and 3 1.1-7 Amendment No.

185/180 Table 1.1-1 (page 1 of 1) MODES MODE TITLE REACTOR MODE SWITCH POSITION AVERAGE REACTOR COOLANT TEMPERATURE

(°F) 1 Power Operation Run NA 2 Startup Refuel (a) or Startup/Hot Standby NA 3 Hot Shutdown (a) Shutdown 212 4 Cold Shutdown (a) Shutdown 212 5 Refueling (b) Shutdown or Refuel NA (a) All reactor vesse l head closure bolts fully tensioned.

(b) One or more reactor vessel head closure bolts less than fully tensioned.

ECCS-Shutdown RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-1 Amendment No.

244/237 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.2 ECCS-Shutdown RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fue l (TAF) shall be AND Two One low pressure ECCS injection/spray subsystems shall be OPERABLE.

APPLICABILITY:

MODE S 4

, MODE 5, except with the spent fuel storage pool gates removed and water level 23 ft over the top of the reactor pressure vessel fl ange. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r R equired ECCS injection/spray

subsystem inoperable.

A.1 Restore required ECCS injection/spray subsystem to OPERABLE status. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A not met. B.1 Initiate action to establish a method of water injection capable of operating without offsite electrical suspend operations with a potential for draining the reactor vessel (OPDRVs)

. Immediately (continued)

RPV Water Inventory Control ECCS-Shutdown 3.5.2 Dresden 2 and 3 3.5.2-2 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Verify secondary containment boundary is capable of being established in less than the DRA AND Verify each secondary containment penetration flow path is capable of being isolated in less than AND Verify one standby gas treatment subsystem is capable of being placed in operation in less 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

RPV Water Inventory Control ECCS-Shutdown 3.5.2 Dresden 2 and 3 3.5.2-3 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action C.2 and associated Completion Time not met.


NOTE -------- Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite


D.1 Initiate action to establish an additional method of water injection with water so urces capable of maintaining RPV water restore secondary containment to OPERABLE status. AND D.2 Initiate action to establish secondary containment boundary restore one standby gas treatment subsystem to OPERABLE status. AND D.3 Initiate action to restore isolation isolate each capability in each required secondary containment penetration flow path not or verify it can be manually isolated from the control room

. AND Initiate action to verify one standby gas treatment syste m is capable of being placed

Immediately

Immediately

Immediately Immediately (continued)

RPV Water Inventory Control ECCS-Shutdown 3.5.2 Dresden 2 and 3 3.5.2-4 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Required Action and associated Completion Time of Condition C or OR Initiate action to restore DRAIN TIME to Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify In accordance with the Surveillance Frequency Control Program SR 3.5.2.

1 Verify, for each the required ECCS injection/spray subsystem, the:

a. Suppression pool water level is 10 ft 4 inches; or
b. -----------------

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

Only one required ECCS injection/spray subsystem may take credit for this option during OPDRVs.


Contaminated condensate storage tanks water volume is 140,000 available gallons.

In accordance with th e Surveillance Frequency Control Program SR 3.5.2.

2 Verify, for each the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

In accordance

with the Surveillance Frequency Control Pro gram (continued)

RPV Water Inventory Control ECCS-Shutdown 3.5.2 Dresden 2 and 3 3.5.2-5 Amendment No.

254/247 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.

3 4 -------------------

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

Not required to be met for system vent flow paths opened under administrative control.


Verify each for the required ECCS injection/spray subsystem each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct

position.

In accordance

with the Surveillance Frequency Control Program

SR 3.5.2.4 Verify each required ECCS pump develops the specified flow rate against a test line pressure corresponding to the specified reactor pressure.

TEST LINE PRESSURE NO. CORRESP ONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF CS 4500 gpm 1 90 psig LPCI 4500 gpm 1 20 psig In accordance with the Inservice Testing Program

Operate the required ECCS injection/spray subsystem through the recircul ation line for In accordance with the Surveillance Frequency Control Program

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or In accordance with the Surveillance Frequency Control Program SR 3.5.2.

5 7 -------------------

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

Vessel injection/spray may be excluded.


Verify each the required ECCS injection/spray subsystem actua tes on an actual or simulated automatic initiation signal can be manually operated.

In accordance

with the Surveillance Frequency Control Program

AC Sources

-Shutdown 3.8.2 Dresden 2 and 3 3.8.2-2 Amendment No.

185/180 ACTIONS -------------------------------------

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

LCO 3.0.3 is not applicable.



CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite

circuit inoperable.


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

Enter applicable Condition and

Required Actions of LCO 3.8.8, when any required division is de-energiz ed as a result of Condition A. -----------------------------

A.1 Declare affected required feature(s),

with no offsite power available, inoperable.

OR A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of recently irradiated fuel assemblies in the secondary containment.

AND A.2.3 Initiate action to suspend operations with a potential for draining the reactor vessel (OPDRVs).

AND A.2.4 3 Initiate action to restore required

offsite power circuit to OPERABLE status.

Immediately

Immediately

Immediately Immediately Immediately (continued)

AC Sources

-Shutdown 3.8.2 Dresden 2 and 3 3.8.2-3 Amendment No.

185/180 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG inoperable.

B.1 Suspend CORE

ALTERATIONS.

AND B.2 Suspend movement of recently irradiated fuel assemb lies in secondary containment.

AND B.3 Initiate action to suspend OPDRVs.

AND B.4 3 Initiate action to restore required DG to

OPERABLE status.

Immediately

Immediately

Immediately Immediately

SURVEILLANCE REQUIREMENTS SURVEILLANCE FRE QUENCY SR 3.8.2.1


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

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through

SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.19. 2. SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, " RPV Water Inventory Control ECCS-Shutdown." -------------------------------------------

For AC sources required to be OPERABLE the SRs of Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.20, and SR 3.8.1.21 are applicable.

In accordance

with applicable SRs Dresden Nuclear Power Station, Units 2 and 3 Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF

-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 3 - REVISED TECHNICAL SPECIFICATIONS PAGES 1.1-2 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 3.5.1-1 3.5.2-1 3.5.2-2 3.5.2-3 3.5.2-4 3.5.2-5 3.6.1.3-7 3.8.2-3 Definitions 1.1 Dresden 2 and 3 1.1-2 Amendment No.

221/212 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTI ONAL TEST shall be the injection

of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL

TEST may be performed by m eans of any series of sequential, overlapping, or total channel steps.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the ves sel. The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replac ement); and b. Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude

completion of movement of a component to a safe position. CORE OPERATING LIMITS The COLR is the un it specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in

accordance with Specification 5.6.5. Plant operation within these limi ts is addressed in

individual Specifications.

DOSE EQUIVALENT I

-131 DOSE EQUIVALENT I

-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I

-131, I-132, I-133, I-134, an d I-135 actually present. The dose conversion factors used for this calculation shall be the inhalation

committed dose conversion factors in Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Fact ors for Inhalation, Submersion, and Ingestion," 1989.

(continued)

Definitions 1.1 Dresden 2 and 3 1.1-3 Amendment No.

221/212 1.1 Definitions (continued)

INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).

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

a. The water inventory above the TAF is divided by the limiting drain rate;
b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, s ingle human error), for all penetration flow paths below the TAF except: 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank fla nges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or (continued)

Definitions 1.1 Dresden 2 and 3 1.1-4 Amendment No.

221/212 1.1 Definitions DRAIN TIME

3. Penetration flow paths with isolation (continued) devices that can be closed prior to the RPV water level being equal to the TAF by a ded icated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.
c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;
d. No additional draining events occur; and
e. Realistic cross

-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE
1. LEAKAGE into the drywell, such as that from

pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;
b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE; (continued)

Definitions 1.1 Dresden 2 and 3 1.1-5 Amendment No.

191/185 1.1 Definitions LEAKAGE c. Total LEAKAGE (continued)

Sum of the identified and unidentified

LEAKAGE; and

d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per RATE (LHGR) unit length of fuel rod. It is the integral of the heat flux over the heat transfer area

associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the act uated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

MINIMUM CRITICAL POWER The MCPR shall be the smalle st critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the

appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

MODE A MODE shall correspond to any one inclusive

combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE-OPERABILITY A system, subsystem, division, component, or

device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrument ation, controls, normal or emergency

electrical power, cooling and seal water, (continued)

Definitions 1.1 Dresden 2 and 3 1.1-6 Amendment No.

242/235 1.1 Definitions OPERABLE-OPERABILITY lubrication, and other auxiliary equipment that (continued) are required for the system, subsystem, division, component , or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 2957 MWt.

REACTOR PROTECTIO N The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from the opening of the sensor contact until the TIME opening of the trip actuator. The response time

may be measured by means of any series of

sequential, overlapping, or total s teps so that

the entire response time is measured.

SHUTDOWN MARGIN (SDM)

SDM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;
b. The moderator temperature is

> 68°F , corresponding to the most reactive state; and

c. All control rods are fully inserted except for

the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable o f being fully inserted, the reactivity worth of these control rods must be accounted for in the

determination of SDM.

THERMAL POWER THERMAL POWER shall be the total reactor core heat

transfer rate to the reactor coolant.

TURBINE BYPASS SYSTEM The TURBINE BYPASS SYSTEM RESPONSE TIME shall be RESPONSE TIME that time interval from when the turbine bypass control unit generates a turbine bypass valve flow signal until the turbine bypass valves travel to their required positions. The response time may be meas ured by means of any series of sequential, overlapping, or total steps so that the entire

response time is measured.

Definitions 1.1 Dresden 2 and 3 1.1-7 Amendment No.

185/180 Table 1.1-1 (page 1 of 1) MODES MODE TITLE REACTOR MODE SWITCH POSITION AVERAGE REACTOR COOLANT TEMPERATURE

(°F) 1 Power Operation Run NA 2 Startup Refuel (a) or Startup/Hot Standby NA 3 Hot Shutdown (a) Shutdown 212 4 Cold Shutdown (a) Shutdown 212 5 Refueling (b) Shutdown or Refuel NA (a) All reactor vessel head clo sure bolts fully tensioned.

(b) One or more reactor vessel head closure bolts less than fully tensioned.

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-1 Amendment No.

244/237 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.2 RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fue l (TAF) shall be AND One low pressure ECCS injection/spray subsystems shall be OPERABLE.

APPLICABILITY:

MODE S 4 and 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. R equired ECCS injection/spray subsystem inoperable.

A.1 Restore required ECCS injection/spray

subsystem to OPERABLE status. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A not met. B.1 Initiate action to establish a method of water injection capable of operating without offsite electrical power.

Immediately (continued)

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-2 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. C.1 Verify secondary containment boundary is capable of being established in less than the DRA IN TIME. AND C.2 Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-3 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.

D.1 ------- NOTE -------- Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power. ---------------------

Initiate action to establish an additional method of water injection with water so urces capable of maintaining RPV water level > TAF for AND D.2 Initiate action to establish secondary containment boundary

. AND D.3 Initiate action to isolate each secondary containment penetration flow path

or verify it can be manually isolated from the control room. AND D.4 Initiate action to verify one standby gas treatment syste m is capable of being placed in operation.

Immediately

Immediately Immediately Immediately (continued)

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-4 Amendment No.

244/237 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and associated Completion Time of Condition C or D not met.

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

E.1 Initiate action to restore DRAIN TIME to Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify In accordance with the Surveillance Frequency Control Program SR 3.5.2.

2 Verify, for the required ECCS injection/spray subsystem, the:

a. Suppression pool water level is 10 ft 4 inches; or
b. Contaminated condensate storage tanks water volume is 140,000 available gallons. In accordance with th e Surveillance Frequency Control Program SR 3.5.2.

3 Verify, for the required ECCS injection/spray subsystem, locations

susceptible to gas accumulation are sufficiently filled with water.

In accordance

with the Surveillance

Frequency Control Pro gram (continued)

RPV Water Inventory Control 3.5.2 Dresden 2 and 3 3.5.2-5 Amendment No.

254/247 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.

4 -------------------

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

Not required to be met for system vent flow paths opened under administrative control.


Verify for the required ECCS injection/spray subsystem each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.2.5 Operate the required ECCS injection/spray subsystem through the recircul ation line In accordance with th e Surveillance Frequency Control Program

Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal.

In accordance with th e Surveillance Frequency Control Program SR 3.5.2.

7 -------------------

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

Vessel injection/spray may be excluded.


Verify the required ECCS injection/spray subsystem can be manually operated

.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 Dresden 2 and 3 3.6.1.3-7 A mendment No.

237/230 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.3


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

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
2. Not required to be met for PCIVs that are open under administrative controls. -----------------------------------------

Verify each primary containment manual

isolation valve and blind flange that is located inside primary containment and

not locked sealed, or otherwise secured and is required to be closed during accident conditi ons is closed.

Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing incore probe (TIP) shear isolation valve explosive charge.

In accordance

with the Surveillance Frequency Control Program SR 3.6.1.3.5 Verify the isolation time of each power

operated, automatic PCIV, except for MSIVs, is within limits.

In accordance

with the INSERVICE TESTING PROGRAM SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 seconds and 5 seconds.

In accordance with the INSERVICE TESTING PROGRAM (continued)

AC Sources

-Shutdown 3.8.2 Dresden 2 and 3 3.8.2-3 Amendment No.

185/180 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG inoperable.

B.1 Suspend CORE

ALTERATIONS.

AND B.2 Suspend movement of recently irradiated fuel assemblies in s econdary containment.

AND B.3 Initiate action to restore required DG

to OPERABLE status.

Immediately

Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1


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

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.19. 2. SR 3.8.1.13 and SR 3.8.1.19 are not required to be met whe n associated ECCS subsystem(s) are not required to

be OPERABLE per LCO 3.5.2, " RPV Water Inventory Control

." -------------------------------------------

For AC sources required to be OPERABLE the

SRs of Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.20, and SR 3.8.1.21 are applicable.

In accordance with applicable SRs