Text

Issuance of Amendments to Adopt TSTF-542 TS Changes (CAC Nos. MF9295 and MF9296; EPID L-2017-LLA-0176)
	ML17272A783
Person / Time
Site:	Dresden
Issue date:	01/08/2018
From:	Haskell R; Plant Licensing Branch III
To:	Bryan Hanson; Exelon Generation Co, Exelon Nuclear
	Haskell R
References
	CAC MF9295, CAC MF9296, EPID L-2017-LLA-0176
	Download: ML17272A783 (99)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 8, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNIT NOS. 2 AND 3 - ISSUANCE OF AMENDMENTS TO RENEWED FACILITY OPERATING LICENSE NOS.

DPR-19 AND DPR-25 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TRAVELER FORCE 542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NOS. MF9295 AND MF9296; EPID L-2017-LLA-0176)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 256 to Renewed Facility Operating License No. DPR-19 and Amendment No. 249 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station (DNPS), Unit Nos. 2 and 3, respectively. The amendments are in response to your application dated February 10, 2017 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17045A006), as supplemented by letters dated July 13, 2017, December 20, 2017, and December 21, 2017 (ADAMS Accession Nos. ML171948069, ML17354B196, and ML17356A134, respectively).

The amendments revise existing DNPS technical specification {TS) requirements related to "operations with a potential for draining the reactor vessel" with new requirements on reactor pressure vessel water inventory control to protect Safety Limit 2.1.1.3 which requires reactor vessel water level to be greater than the top of active irradiated fuel.

B. Hanson The Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Russell S. Haskell II, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosures:

1. Amendment No. 256 to DPR-19

2. Amendment No. 249 to DPR-25

3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-237 DRESDEN NUCLEAR POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 256 Renewed License No. DPR-19

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Exelon Generation Company, LLC (the licensee) dated February 10, 2017, as supplemented by letters dated July 13, December 20, and December 21, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-19 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 256, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Enclosure 1

3. This license amendment is effective as of the date of its issuance and shall be implemented prior to the beginning of refueling outage D3R25 currently planned for October 2018.

FOR THE NUCLEAR REGULATORY COMMISSION u//' (__;.{,. 0 v* '--"

David J. Wron( Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: January 8, 2018

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-249 DRESDEN NUCLEAR POWER STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 249 Renewed License No. DPR-25

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Exelon Generation Company, LLC (the licensee) dated February 10, 2017, as supplemented by letters dated July 13, December 20, and December 21, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Renewed Facility Operating License No. DPR-25 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 249, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Enclosure 2

3. This license amendment is effective as of the date of its issuance and shall be implemented prior to the beginning of refueling outage D3R25 currently planned for October 2018.

, 2 v/

FOR THE NUCLEAR REGULA TORY COMMISSION C .

~/~

I David J. Wrona, hief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: January 8, 2018

ATTACHMENT TO LICENSE AMENDMENT NOS. 256 AND 249 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 RENEWED FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 DOCKET NOS. 50-237 AND 50-249 Replace the following pages of the Renewed Facility Operating License with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page 3 (DPR-19) Page 3 (DPR-19)

Page 4 (DPR-25) Page 4 (DPR-25)

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert Remove Insert Remove Insert i i 3.3.5.2-1 3.3.5.2-1 3.6.4.2-1 3.6.4.2-1 ii ii 3.3.5.2-2 3.3.5.2-2 3.6.4.2-3 3.6.4.2-3 1.1-2 1.1-2 3.3.5.2-3 3.6.4.3-1 3.6.4.3-1 1.1-3 1.1-3 3.3.5.3-1 3.6.4.3-2 3.6.4.3-2 1.1-4 1.1-4 3.3.5.3-2 3. 7.4-1 3. 7.4-1 1.1-5 1.1-5 3.3.6.1-8 3.3.6.1-8 3.7.4-2 3.7.4-2 1.1-6 1.1-6 3.3.6.2-5 3.3.6.2-5 3.7.5-1 3.7.5-1 1.1-7 3.3.7.1-1 3.3.7.1-1 3.8.2-2 3.8.2-2 3.3.5.1-2 3.3.5.1-2 3.5.1-1 3.5.1-1 3.8.2-3 3.8.2-3 3.3.5.1-3 3.3.5.1-3 3.5.2-1 3.5.2-1 3.8.2-4 3.3.5.1-4 3.3.5.1-4 3.5.2-2 3.5.2-2 3.8.2-5 3.3.5.1-5 3.3.5.1-5 3.5.2-3 3.5.2-3 3.8.5-1 3.8.5-1 3.3.5.1-6 3.3.5.1-6 3.5.2-4 3.5.2-4 3.8.5-2 3.8.5-2 3.3.5.1-7 3.3.5.1-7 3.5.2-5 3.8.8-2 3.8.8-2 3.3.5.1-8 3.3.5.1-8 3.5.3-1 3.5.3-1 3.3.5.1-9 3.3.5.1-9 3.6.1.3-5 3.6.1.3-5 3.3.5.1-10 3.3.5.1-10 3.6.1.3-6 3.6.1.3-6 3.3.5.1-11 3.3.5.1-11 3.6.1.3-7 3.6.1.3-7 3.3.5.1-12 3.3.5.1-12 3.6.1.3-8 3.6.1.3-8 3.3.5.1-13 3.6.1.3-9 3.3.5.1-14 3.6.4.1-1 3.6.4.1-1

(2) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear materials as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2957 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 256, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Operation in the coastdown mode is permitted to 40% power.

Renewed License No. DPR-19 Amendment No. 256

f. Surveillance Requirement 4.9.A.1 O - Diesel Storage Tank Cleaning (Unit 3 and Unit 2/3 only)

Each of the above Surveillance Requirements shall be successfully demonstrated prior to entering into MODE 2 on the first plant startup following the fourteenth refueling outage (D3R14).

3. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level The licensee is authorized to operate the facility at steady state power levels not in excess of 2957 megawatts (thermal), except that the licensee shall not operate the facility at power levels in excess of five (5) megawatts (thermal), until satisfactory completion of modifications and final testing of the station output transformer, the auto-depressurization interlock, and the feedwater system, as described in the licensee's telegrams; dated February 26, 1971, have been verified in writing by the Commission.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 249, are hereby incorporated into this renewed operating license.

The licensee shall operate the facility in accordance with the Technical Specifications.

C. Reports The licensee shall make certain reports in accordance with the requiremerits of the Technical Specifications.

D. Records The licensee shall keep facility operating records in accordance with the requirements of the Technical Specifications.

E. Restrictions Operation in the coastdown mode is permitted to 40% power.

Renewed License No. DPR-25 Amendment No. 249

TABLE OF CONTENTS

1. 0 USE AND APPLICATION 1.1 Definitions .............................................. 1.1-1

1. 2 Logical Connectors ....................................... 1.2-1

1. 3 Completion Times ......................................... 1.3-1

1. 4 Frequency ................................................ 1.4-1 2.0 SAFETY LIMITS (SLs) 2 .1 SLs ...................................................... 2.0-1 2.2 SL Violations ............................................ 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCD) APPLICABILITY ........ 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ................. 3.0-4 3 .1 REACTIVITY CONTROL SYSTEMS 3 .1.1 SHUTDOWN MARGIN (SDM) .................................... 3.1.1-1 3 .1. 2 Reactivity Anomalies ..................................... 3.1.2-1 3 .1. 3 Control Rod OPERABILITY .................................. 3.1.3-1 3 .1. 4 Control Rod Scram Times .................................. 3.1.4-1 3 .1. 5 Control Rod Scram Accumulators ........................... 3.1.5-1 3 .1. 6 Rod Pattern Control ...................................... 3.1.6-1

3. 1. 7 Standby Liquid Control (SLC) System ...................... 3.1.7-1 3 .1. 8 Scram Discharge Volume (SDV) Vent and Drain Valves ....... 3.1.8-1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) ...... 3.2.1-1 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) ...................... 3.2.2-1 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) ...................... 3.2.3-1 3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation .......... 3.3.1.1-1 3.3.1.2 Source Range Monitor (SRM) Instrumentation ............... 3.3.1.2-1 3.3.1.3 Oscillation Power Range Monitor (OPRM) Instrumentation ... 3.3.1.3-1

3. 3. 2. 1 Control Rod Block Instrumentation ........................ 3.3.2.1-1

3. 3. 2. 2 Feedwater System and Main Turbine High Water Level Trip Instrumentation ................................... 3.3.2.2-1 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation ........... 3.3.3.1-1 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip CATWS-RPT) Instrumentation ................... 3.3.4.1-1 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation ..... 3.3.5.1-1 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation ........................................ 3.3.5.2-1 3.3.5.3 Isolation Condenser (IC) System Instrumentation .......... 3.3.5.3-1 3.3.6.1 Primary Containment Isolation Instrumentation ............ 3.3.6.1-1

3. 3. 6. 2 Secondary Containment Isolation Instrumentation .......... 3.3.6.2-1 3.3.6.3 Relief Valve Instrumentation ............................. 3.3.6.3-1 3.3.7.1 Control Room Emergency Ventilation (CREV) System Instrumentation ........................................ 3. 3. 7 . 1 - 1 3.3.7.2 Mechanical Vacuum Pump Trip Instrumentation .............. 3.3.7.2-1 (continued)

Dresden 2 and 3 Amendment No. 256/249

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.8.1 Loss of Power (LOP) Instrumentation ...................... 3.3.8.1-1 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring ............................................. 3.3.8.2-1 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 Recirculation Loops Operating ............................ 3.4.1-1 3.4.2 Jet Pumps ................................................ 3.4.2-1 3.4.3 Safety and Relief Valves ................................ 3.4.3-1 3.4.4 RCS Operational LEAKAGE .................................. 3.4.4-1 3.4.5 RCS Leakage Detection Instrumentation .................... 3.4.5-1 3.4.6 RCS Specific Activity .................................... 3.4.6-1 3.4.7 Shutdown Cooling (SOC) System-Hot Shutdown ............... 3.4.7-1 3.4.8 Shutdown Cooling (SOC) System-Cold Shutdown .............. 3.4.8-1 3.4.9 RCS Pressure and Temperature (P/T) Limits ................ 3.4.9-1 3.4.10 Reactor Steam Dome Pressure .............................. 3.4.10-1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM

3. 5 .1 ECCS-Operating ........................................... 3.5.1-1 3.5.2 RPV Water Inventory Control. ............................. 3.5.2-1 3.5.3 IC System ................................................ 3.5.3-1 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment ...................................... 3.6.1.1-1 3.6.1.2 Primary Containment Air Lock ............................. 3.6.1.2-1 3.6.1.3 Primary Containment Isolation Valves (PCIVs) ............. 3.6.1.3-1 3.6.1.4 Drywell Pressure ......................................... 3.6.1.4-1 3.6.1.5 Drywell Air Temperature .................................. 3.6.1.5-1 3.6.1.6 Low Set Relief Valves .................................... 3.6.1.6-1 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers ............................................... 3.6.1.7-1 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers ........... 3.6.1.8-1 3.6.2.1 Suppression Pool Average Temperature ..................... 3.6.2.1-1 3.6.2.2 Suppression Pool Water Level ............................. 3.6.2.2-1 3.6.2.3 Suppression Pool Cooling ................................. 3.6.2.3-1

3. 6. 2. 4 Suppression Pool Spray ................................... 3.6.2.4-1 3.6.2.5 Drywell-to-Suppression Chamber Differential Pressure ..... 3.6.2.5-1

3. 6. 3 .1 Primary Containment Oxygen Concentration ................. 3.6.3.1-1 3.6.4.1 Secondary Containment. ................................... 3.6.4.1-1 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) ........... 3.6.4.2-1 3.6.4.3 Standby Gas Treatment (SGT) System ....................... 3.6.4.3-1 (continued)

Dresden 2 and 3 ii Amendment No. 256/249

Definitions 1.1 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps.

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

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);

and

b. Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The dose conversion factors used for this calculation shall be the inhalation committed dose conversion factors in Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," 1989.

(continued)

Dresden 2 and 3 1. 1- 2 Amendment No. 256/249

Definitions 1.1 1.1 Definitions (continued)

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

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

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error),

for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

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

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

(continued)

Dresden 2 and 3 1. 1- 3 Amendment No. 256~49

Definitions 1.1 1.1 Definitions DRAIN TIME c. The penetration flow paths required to be (continued) evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;

d. No additional draining events occur; and

e. Realistic cross-sectional areas and drain rates are used.

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

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

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE into the drywel l, such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or

2. LEAKAGE into the drywel l atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE; (continued)

Dresden 2 and 3 1. 1-4 Amendment No. 256~49

Definitions

1. 1 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 actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.

MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE-OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, (continued)

Dresden 2 and 3 1. 1- 5 Amendment No. 256 / 249

Definitions

1. 1 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 (SOM) SOM shall be the amount of reactivity by which the reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is~ 68°F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn.

With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SOM.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

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

Dresden 2 and 3 1. 1- 6 Amendment No. 256 / 249

Definitions 1.1 Table 1.1-1 (page 1 of 1)

MODES REACTOR MODE AVERAGE REACTOR MODE TITLE SWITCH POSITION COOLANT TEMPERATURE

( o F) 1 Power Operation Run NA 2 Startup Refuel cai or Startup/Hot NA Standby 3 Hot Shutdown iai Shutdown > 212 4 Cold Shutdowncai Shutdown ~ 212 5 Refuel i ngcbi Shutdown or Refuel NA (a) All reactor vessel head closure bolts fully tensioned.

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

Dresden 2 and 3 1. 1- 7 Amendment No. 256/249

ECCS Instrumentation 3.3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. As required by B.1 - - - - - - - -NOTE- - - - - - - -

Required Action A.1 Only applicable for and referenced in Functions 1.a, l.b, Table 3.3.5.1-1. 2.a, 2.b, 2.d, and

2. j.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions B.2 --------NOTE---------

Only applicable for Functions 3.a and 3.b.

Declare High Pressure 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Coolant Injection discovery of (HPCI) System loss of HPCI inoperable. initiation capability B.3 Place channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

(continued)

Dresden 2 and 3 3.3.5.1-2 Amendment No. 256/249

ECCS Instrumentation 3.3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. As required by C .1 - - - - - - - - NOTE - - - - - - - -

Required Action A.1 Only applicable for and referenced in Functions 1.c, l.e, Table 3.3.5.1-1. 2.c, 2.e, 2.g, 2.h, 2.i, and 2.k.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. feature(s) in both divisions C.2 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

D. As required by D .1 - - - - - - - - NOTE - - - - - - - - -

Required Action A.1 Only applicable if and referenced in HPCI pump suction is Table 3.3.5.1-1. not aligned to the suppression pool.

Declare HPCI System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 'from inoperable. discovery of loss of HPCI initiation capability D. 2. 1 Pl ace channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

0.2.2 Align the HPCI pump 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months suction to the suppression pool.

(continued)

Dresden 2 and 3 3.3.5.1-3 Amendment No. 256/249

ECCS Instrumentation 3.3.5.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. As required by E.l - - - - - - - - NOTE - - - - - - - -

Required Action A.l Only applicable for and referenced in Functions l.d Table 3.3.5.1-1. and 2.f.

Declare supported 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from feature(s) inoperable discovery of when its redundant loss of feature ECCS initiation initiation capability capability for is inoperable. subsystems in both divisions E.2 Restore channel to 7 days OPERABLE status.

F. As required by F.l Declare Automatic 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Required Action A.l Depressurization discovery of and referenced in System (ADS) valves loss of ADS Table 3.3.5.1-1. inoperable. initiation capability in both trip systems F.2 Pl ace channel in 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from trip. discovery of inoperable channel concurrent with HPCI or isolation condenser (IC) inoperable 8 days (continued)

Dresden 2 and 3 3.3.5.1-4 Amendment No. 256 / 249

ECCS Instrumentation

3. 3. 5 .1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME G. As required by G.1 Declare ADS valves 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Required Action A.1 inoperable. discovery of and referenced in loss of ADS Table 3.3.5.1-1. initiation capability in both trip systems G.2 Restore channel to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from OPERABLE status. discovery of inoperable channel concurrent with HPCI or IC inoperable 8 days H. Required Action and H .1 Declare associated Immediately associated Completion supported feature(s)

Time of Condition B, inoperable.

C, D, E, F, or G not met.

Dresden 2 and 3 3.3.5.1-5 Amendment No. 256/249

ECCS Instrumentation

3. 3. 5. 1 SURVEILLANCE REQUIREMENTS NOTES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1. Refer to Table 3.3.5.1-1 to determine which SRs apply for each ECCS Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions 3.c, 3.f, and 3.g; and (b) for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for Functions other than 3.c, 3.f, and 3.g provided the associated Function or the redundant Function maintains ECCS initiation capability.

SURVEILLANCE FREQUENCY In accordance with the SR 3.3.5.1.1 Perform CHANNEL CHECK. Surveillance Frequency Control Program SR 3.3.5.1.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.3 Calibrate the trip unit. In accordance with the Surveillance Frequency Control Program SR 3.3.5.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program (continued)

Dresden 2 and 3 3.3.5.1-6 Amendment No. 256/ 249

ECCS Instrumentation 3.3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1.5 Perform CHANNEL CALIBRATION. In accordance with the Survei 11 ance Frequency Control Program SR 3.3.5.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Dresden 2 and 3 3.3.5.1-7 Amendment No. 256 / 249

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 1 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEI LLA.NCE ALLOWABLE FUN CTI ON CONDITIONS FUN CT ION ACTION A.l REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Vessel Water 1, 2, 3 4,J1 B SR 3. 3. 5. 1. 1 ;, -54.15 Level-Low Low SR 3. 3. 5. 1. 2 inches SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

b. Drywell Pressure-High 1, 2, 3 4,,, B SR 3.3.5.1.2 ~ 1. 81 psig SR 3.3.5.1.4 SR 3.3.5.1.6

c. Reactor Steam Dome 1, 2, 3 2 C SR 3.3.5.1.2 2 308.5 psig Pressure-Low SR 3.3.5.1.4 and (Permissive) SR 3.3.5.1.6 s 341. 7 psig

d. Core Spray Pump 1, 2, 3 1 per pump SR 3.3.5.1.2 2 802 gpm Di sch a rge Flow-Low SR 3.3.5.1.3 and (Bypass) SR 3.3.5.1.5 s 992 gpm SR 3.3.5.1.6

e. Core Spray Pump 1, 2, 3 1 per pump C SR 3.3.5.1.5 $ 11. 0 seconds Start-Time Delay Relay SR 3.3.5.1.6

2. Low Pressure Coolant Injection ( LPC I l System

a. Reactor Vessel Water 1, 2, 3 4 B SR 3.3.5.1.1 ;, -54 .15 Level-Low Low SR 3.3.5.1.2 Inches SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6 SR 3.3.5.1.2

b. Drywell Pressure-High 1, 2, 3 4 B SR 3.3.5.1.4 " 1. 81 psig SR 3.3.5.1.6 C. Reactor Steam Dome 1, 2, 3 2 C SR 3.3.5.1.2 ;, 308.5 psig Pressure-Low SR 3. 3. 5 .1. 4 and (Permissive) SR 3.3.5.1.6 $ 341. 7 psig (continued l Ca) Also required to initiate the associated diesel generator ( DG).

Dresden 2 and 3 3.3.5.1-8 Amendment No. 256 / 249

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 2 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACT ION A. 1 REQUIREMENTS VALUE

2. LPC I System (continued)

d. Reactor Steam Dome 1, 2, 3 4 B SR 3.3.5.1.Z 2: 802 psig and Pressure-Low (Break SR 3.3.5.1.5 <; 898 psig Detection) SR 3.3.5.1.6

e. Low Pressure Coolant 1, 2, 3 1 per pump C SR 3. 3. 5. 1. 5 s 5.5 seconds Injection Pump SR 3. 3. 5. 1. 6 Start-Time Delay Relay Pumps B and D

f. Low Pressure 1, 2, 3 1 per loop SR 3.3.5.1.2 ;, 1107 gpm Coolant Injection Pump SR 3.3.5.1.3 Discharge Flow-Low SR 3.3.5.1.5 (Bypass) SR 3.3.5.1.6

g. Recirculation Pump 1, 2, 3 4 per pump C SR 3.3.5.1.2 s 5.9 psid Differential SR 3.3.5.1.5 Pressure-High (Break SR 3.3.5.1.6 Detection)

h. Recirculation Riser 1, 2, 3 4 C SR 3.3.5.1.2 <; 2.0 psi d Differential SR 3.3.5.1.5 Pressure-High (Break SR 3.3.5.1.6 Detection)

i. Reci rcul at ion Pump 1, 2, 3 2 C SR 3.3.5.1.5 s 0.53 seconds Differential Pressure SR 3.3.5.1.6 Time Delay-Relay (Break Detection)

j. Reactor Steam Dome 1, 2, 3 2 B SR 3.3.5.1.5 s Z. 12 seconds Pressure Time Delay- SR 3.3.5.1.6 Relay (Break Detection)

k. Recirculation Riser 1, 2, 3 C SR 3.3.5.1.5 s 0.53 seconds Differential Pressure SR 3.3.5.1.6 Time Delay-Relay (Break Detection)

(continued)

Dresden 2 and 3 3.3.5.1-9 Amendment No. 256 / 249

ECCS Instrumentation

3. 3. 5 .1 Table 3.3.5.1-1 (page 3 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUN CTI ON CONDITIONS FUNCTION ACTION A. l REQUIREMENTS VALUE

3. High Pressure Coolant Injection ( HPC I l System

a. Reactor Vessel Water 1, 4 B SR 3. 3. 5. 1. 1 2 - 54 .15 Level-Low Low SR 3.3.5.1.2 Inches 2' b , 3 C) SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

b. Drywell Pressure-High 1, 4 B SR 3.3.5.1.2 5 1. 81 psig SR 3.3.5.1.4 z, b,, 3, b, SR 3.3.5.1.6 C. Reactor Vessel Water 1, 2 C SR 3.3.5.1.1 5 46.2 inches Level-High SR 3. 3. 5. 1. 2 2rb1, 3,, SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

d. Contaminated 1, 2 per CCST D SR 3.3.5.1.2 2 11.1158 ft Condensate Storage SR 3. 3. 5. 1. 5 for CCST 2/3 A Tank (CCST) Level-Low 2 b , 3,b, SR 3. 3. 5. 1. 6 and 2 7.5637 ft for CCST 2/3 B

e. Suppression Pool Water 1, D SR 3. 3. 5. 1. 2 5 15 ft Level-High SR 3. 3. 5. 1. 5 5.625 inches 2 b',, 3'b, SR 3.3.5.1.6

f. High Pressure Coolant 1, SR 3. 3. 5 .1. 2 2 616 gpm Injection Pump SR 3.3.5.1.4 Discharge Fl ow-Low 2 b,, 3, ,, SR 3.3.5.1.6 (Bypass)

g. Manual I nit i at ion 1, C SR 3.3.5.1.6 NA 2, b,, 3, t, (continued)

(bl With reactor steam dome pressure> 150 psig.

Dresden 2 and 3 3.3.5.1-10 Amendment No. 256/249

ECCS Instrumentation

3. 3. 5. 1 Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDIT IONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.l REQUIREMENTS VALUE

4. Automatic Depressurization Sys tern (ADS) Trip System A

a. Reactor Vessel Water 1, SR 3.3.5.1.1 2 - 54. 15 Level-Low Low SR 3.3.5.1.2 Inches 2 b', 3' h, SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3. 3. 5. 1. 6

b. Drywell Pressure-High 1, SR 3.3.5.1.2 $ l . 81 psig SR 3.3.5.1.4 2' b,' 3' bl SR 3.3.5.1.6 C. Automatic 1, G SR 3.3.5.1.5 $ 113 seconds Depressurization SR 3.3.5.1.6 System lnitiation 2* b,' 3, ,,,

Timer

d. Core Spray Pump 1, G SR 3.3.5.1.2 2 101. 5 psig Discharge SR 3.3.5.1.4 and Pressure-High 2, b*, 3, b SR 3.3.5.1.6 $ 148.5 psig

e. Low Pressure Coolant 1, 4 G SR 3. 3. 5. 1. 2 2 101.5 psig Injection Pump SR 3. 3. 5. 1. 4 and Discharge 2* h*' 3 b SR 3. 3. 5. 1. 6 ,; 148. 5 psig Pressure-High

f. Automatic 1' G SR 3.3.5.1.5 s 580 seconds Depressurization SR 3.3.5.1.6 System Low Low Water 2* b ( ' 3*b, Level Actuation Timer (continued)

Cb) With reactor steam dome pressure> 150 psig.

Dresden 2 and 3 3.3.5.1-11 Amendment No. 256/249

ECCS Instrumentation

3. 3. 5. 1 Table 3.3.5.1-1 (page 5 of 5)

Emergency Core Cooling Sys tern Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER REQUIRED SURVEILLANCE ALLOWABLE FUN CTI ON CONDITIONS FUNCTION ACTION A.l REQUIREMENTS VA LUE

5. ADS Trip System B

a. Reactor Vessel Water 1, SR 3.3.5.1.1 2 -54.15 Level-Low Low SR 3.3.5.1.2 inches 21 tJI > 3, l], SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

b. Drywell Pressure-High 1, 2 SR 3.3.5.1.2 ,; 1.81 psig SR 3.3.5.1.4 2, bi, 3, b SR 3. 3. 5. 1. 6 C. Automatic 1' G SR 3.3.5.1.5 ,; 113 seconds Depressurization SR 3.3.5.1.6 System Initiation 2' b)' 3, b)

Timer

d. Core Spray Pump 1, G SR 3.3.5.1.2 ;, 101. 5 psig Discharge SR 3.3.5.1.4 and Pressure-High 2' b), 3, b' SR 3.3.5.1.6 ,; 148.5 psig

e. Low Pressure Coolant 1, 4 G SR 3.3.5.1.2 ;, 101. 5 psig Injection Pump SR 3.3.5.1.4 and Discharge 2,0,, 3 ' SR 3.3.5.1.6 ,; 148.5 psig Pressure-High

f. Automatic 1, G SR 3.3.5.1.5 ,; 580 seconds Depressurization SR 3.3.5.1.6 System Low Low Water 21b)' 3 ,,

Level Actuation Timer (b) With reactor steam dome pressure> 150 psig.

Dresden 2 and 3 3.3.5.1-12 Amendment No. 256/249

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

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

B. As required by B.1 Declare associated Immediately Required Action A.1 penetration flow and referenced in path(s) incapable of Table 3.3.5.2-1. automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by C. 1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action A.1 and referenced in Table 3.3.5.2 1.

D. As required by D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Required Action A.1 OPERABLE status.

and referenced in Table 3.3.5.2-1.

(continued) I Dresden 2 and 3 3.3.5.2-1 Amendment No. 256 / 249

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or injection/spray D not met. subsystem inoperable.

SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Dresden 2 and 3 3.3.5.2-2 Amendment No. 256/249

RPV Water Inventory Control :nstrumentation 3.3.5.2 Table 3.3.5.2-1 (Page 1 of 1)

RPV Water Inventory Control Jnstrume"Lation APPL! CABLE CONDITIONS MODES REFERENCED OR OTHER REOU I RED FROM SPECIFIED CHANNELS PER REQUIRED SURVEJLLAI-ICE ALLOWABLE FUN CT 101-1 COIIDJTIONS FUI-ICTJON ACT I ON A l REQUIREMENTS VALUE Core Spray System

a. Reactor Steam Dome 4, 5 2 (al SR 3.3.5.2.2 ,;: 341. 7 psig Pressure-Low

( Pe rmi ss iv el

b. Core Spray Pump 4, 5 l per D SR 3.3.5.2.2 ;;, 802 gpm Discharge Flow-Low pump (al and (Bypass) ,;: 992 gpm

2. Low Pressure Coolant Injection (LPCIJ System

a. Reactor Steam Dome 4, 5 2 (al SR 3.3.5.2.2 "341.7 psig Pressure-Low (Permissive)

b. Low Pressure Coolant 4, 5 1 per D SR 3.3.5.2.2 2 1107 gpm Injection Pump loop (a)

Discharge Flow-Low (Bypass)

3. Shutdown Cooling System (SOC) Isolation

a. Reactor Vessel WatHr (bl per trip B SR 3.3.5.2.l :c 2.65 inches Level-Low system SR 3.3.5.2.2

4. Reactor Water Cleanup System Isolation

a. Reactor Vessel Water (b) per trip SR 3.3.5.2.1 ;;, 2.65 inches Level-Low system SR 3.3.5.2.2 (al Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Woter nventory Control.

(bl When automatic isolation of the associated penetration flow path(sl is credited in calculating DRAII-I TIME.

Dresden 2 and 3 3.3.5.2-3 Amendment No. 256/249

IC System Instrumentation 3.3.5.3 3.3 INSTRUMENTATION 3.3.5.3 Isolation Condenser (IC) System Instrumentation LCO 3.3.5.3 Four channels of Reactor Vessel Pressure-High instrumentation shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Reactor A.1 Declare IC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from Vessel Pressure-High inoperable. discovery of channels inoperable. loss of IC initiation capability AND A.Z Place channel(s) i n 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

B. Required Action and B.l Declare IC System Immediately associated Completion inoperable.

Time not met.

Dresden 2 and 3 3.3.5.3-1 Amendment No. 256 / 249

IC System Instrumentation 3.3.5.3 SURVEILLANCE REQUIREMENTS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - __ - - - __

When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the Reactor Vessel Pressure-High Function maintains IC initiation capability.

SURVEILLANCE FREQUENCY SR 3.3.5.3.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.3.2 - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - -

Not required for the time delay portion of the channel.

Perform CHANNEL CALIBRATION. The In accordance Allowable Value shall be~ 1068 psig. with the Surveillance Frequency Control Program SR 3.3.5.3.3 Perform CHANNEL CALIBRATION for the time In accordance delay portion of the channel. The with the Allowable Value shall be~ 15 seconds. Survei 11 ance Frequency Control Program SR 3.3.5.3.4 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program Dresden 2 and 3 3.3.5.3-2 Amendment No. 256/249

Primary Containment Isolation Instrumentation

3. 3. 6 .1 Table 3.3.6.1-1 (page 3 of 3)

Primary Containment Isolation Instrumentation APPLICABLE CONDIT I ON S MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPEC! FI ED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.l REQUIREMENTS VALUE

5. Reactor Water Cleanup System Isolation

a. SLC System Initiation 1,2,3 H SR 3.3.6.1.7 NA

b. Reactor Vessel Water 1, 2, 3 2 SR 3.3.6.1.1 ;, 2.65 inches Leve 1-Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7

6. Shutdown Cooling System Isolation

a. Reactor Vessel 1, 2, 3 SR 3.3.6.1.2 ,; 114.1 psig Pressure High SR 3.3.6.1.6 ( Loop 1, SR 3.3.6.1.7 Reactor Wide Range Pressure)

,; 110.4 psig (Loop 2, Reactor Pressure Feedwater Control J

b. Reactor Vessel Water SR 3.3.6.1.1 ;, 2.65 inches Level-Low SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 Dresden 2 and 3 3.3.6.1-8 Amendment No. 256 / 249

Secondary Containment Isolation Instrumentation 3.3.6.2 Table 3.3.6.2-1 (page 1 of ll Secondary Containment Isolation Instrumentation APPLICABLE MODES OR REQUIRED OTHER CHANNELS SPECIFIED PER SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS TRIP SYSTEM REQUIREMENTS VA LUE

1. Reactor Vessel Water 1, 2, 3 SR 3.3.6.2.1 2 2.65 inches Level-Low SR 3.3.6.2.2 SR 3.3.6.2.3 SR 3.3.6.2.5 SR 3.3.6.2.6

2. Drywell-Pressure-High 1, 2, 3 SR 3.3.6.2.2 :5 1.94 psig SR 3.3.6.2.4 SR 3.3.6.2.6

3. Reactor Building Exhaust 1, 2, 3, SR 3. 3. 6. 2. 1 :; 14.9 mR/hr Radiation-High (a) SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.6

4. Refueling Floor 1, 2, 3, SR 3. 3. 6. 2 .1 :5 100 mR/hr Radiation-High (al SR 3.3.6.2.2 SR 3.3.6.2.4 SR 3.3.6.2.6 (al During movement of recently irradiated fuel assemblies in secondary containment.

Dresden 2 and 3 3.3.6.2-5 Amendment No. 256/249

CREV System Instrumentation 3.3.7.1 3.3 INSTRUMENTATION 3.3.7.1 Control Room Emergency Ventilation (CREV) System Instrumentation LCO 3.3.7.1 Two channels of the Reactor Building Ventilation System-High High Radiation Alarm Function shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - __ - - - __

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A .1 Declare CREV System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from inoperable. inoperable. discovery of loss of CREV System Instrumentation alarm capability in both trip systems A.2 Restore channel to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OPERABLE status.

(continued)

Dresden 2 and 3 3.3.7.1-1 Amendment No. 256/249

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (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.

( LPC I ) pump inoperable.

B. One LPCI subsystem B.l 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.l Restore one LPCI 7 days subsystem inoperable. pump to OPERABLE status.

(continued)

Dresden 2 and 3 3.5.1-1 Amendment No. 256 / 249

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS CECCS), REACTOR PRESSURE VESSEL CRPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER CIC) SYSTEM 3.5.2 RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel CTAF) shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACT ION COMPLETION TIME A. Required ECCS A.l Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and 8.1 Initiate action to Immediately associated Completion establish a method of Time of Condition A water injection not met. capable of operating without offsite electrical power.

Ccontinued)

Dresden 2 and 3 3.5.2-1 Amendment No. 256/249

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

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

C.3 Verify one standby 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

(continued)

Dresden 2 and 3 3.5.2-2 Amendment No. 256 / 249

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . 0.1 ------- NOTE --------

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

Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for

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

0.2 Initiate action to Immediately establish secondary containment boundary.

0.3 Initiate action to Immediately isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room.

0.4 Initiate action to Immediately verify one standby gas treatment subsystem is capable of being placed in operation.

(continued)

Dresden 2 and 3 3.5.2-3 Amendment No. 256/249

RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.l Initiate action to Immediately associated Completion restore DRAIN TIME to Time of Condition C or ;:o: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

D not met.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME ;:o: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for the required ECCS In accordance injection/spray subsystem, the: with the Surveillance

a. Suppression pool water level is Frequency

o

10 ft 4 inches; or Control Program

b. Contaminated condensate storage tanks water volume is 2 140,000 available gallons.

SR 3.5.2.3 Verify, for the required ECCS In accordance injection/spray subsystem, locations with the susceptible to gas accumulation are Surveillance sufficiently filled with water. Frequency Control Program (continued)

Dresden 2 and 3 3.5.2-4 Amendment No. 256 / 249

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.4 - - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -

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

Verify for the required ECCS In accordance injection/spray subsystem each manual, with the power operated, and automatic valve in the Survei 11 ance flow path, that is not locked, sealed, or Frequency otherwise secured in position, is in the Control Program correct position.

SR 3.5.2.5 Operate the required ECCS injection/spray In accordance subsystem through the recirculation line with the for~ 10 minutes. Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for In accordance automatically isolating a penetration flow with the path actuates to the isolation position on Survei 11 ance an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.7 - - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - - -

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray In accordance subsystem can be manually operated. with the Survei 11 ance Frequency Control Program Dresden 2 and 3 3.5.2-5 Amendment No.256/249

IC System

3. 5. 3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND ISOLATION CONDENSER (IC) SYSTEM 3.5.3 IC System LCO 3.5.3 The IC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _- - - - __

LCO 3.0.4.b is not applicable to IC.

CONDITION REQUIRED ACTION COMPLETION TIME A. IC System inoperable. A.1 Verify by Immediately administrative means High Pressure Coolant Injection System i s OPERABLE.

AND A.2 Restore IC System to 14 days OPERABLE status.

B. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

associated Completion LCO 3. o. 4. a i s not applicable Time not met. when entering MODE 3.

B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Dresden 2 and 3 3.5.3-1 Amendment No.256/249

PCIVs 3.6.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 - - - - - - - - NOTES- - - - - - - -

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are a locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

D. MSIV leakage rate 0.1 Restore leakage rate 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months not within limit. to within limit.

E. Required Action and E.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, C, or D not met in MODE 1, 2, or 3. E. 2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Dresden 2 and 3 3.6.1.3-5 Amendment No.256/249

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.1 - - - - - - - - - - - - - - - - - -NOTE- - - - - - - - - - - - - - - - - - -

Not required to be met when the 18 inch primary containment vent and purge valves are open for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open, provided the drywel l vent and purge valves and their associated suppression chamber vent and purge valves are not open simultaneously.

Verify each 18 inch primary containment In accordance vent and purge valve, except the torus with the purge valve, is closed. Surveillance Frequency Control Program SR 3.6.1.3.2 - - - - - - - - - - - - - - - - - -NOTES- - - - - - - - - - - - - - - - - -

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment isolation In accordance manual valve and blind flange that is with the located outside primary containment and Survei 11 a nee not locked, sealed, or otherwise secured Frequency and is required to be closed during Control Program accident conditions is closed.

(continued)

Dresden 2 and 3 3.6.1.3-6 Amendment No. 256/249

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.3 - - - - - - - - - - - - - - - - - - NOTES - - - - - - - - - - - - - - - - - -

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual Prior to isolation valve and blind flange that is entering MODE 2 located inside primary containment and or 3 from not locked sealed, or otherwise secured MODE 4 if and is required to be closed during primary accident conditions is closed. containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing In accordance incore probe (TIP) shear isolation valve with the explosive charge. Survei 11 ance Frequency Control Program SR 3.6.1.3.5 Verify the isolation time of each power In accordance operated, automatic PCIV, except for with the MSIVs, is within limits. INSERVICE TEST I NG PROGRAM SR 3.6.1.3.6 Verify the isolation time of each MSIV is In accordance

~ 3 seconds and~ 5 seconds. with the INSERVICE TESTING PROGRAM (continued)

Dresden 2 and 3 3.6.1.3-7 Amendment No. 256 / 249

PCIVs 3.6.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.3.7 Verify each automatic PCIV actuates to In accordance the isolation position on an actual or with the simulated isolation signal. Surveillance Frequency Control Program SR 3.6.1.3.8 Verify a representative sample of reactor In accordance instrumentation line EFCVs actuate to the with the isolation position on an actual or Survei 11 ance simulated instrument line break signal. Frequency Control Program SR 3.6.1.3.9 Remove and test the explosive squib from In accordance each shear isolation valve of the TIP with the System. Survei 11 ance Frequency Control Program SR 3.6.1.3.10 Verify the leakage rate through each MSIV In accordance leakage path is~ 34 scfh when tested at with the

~ 25 psig, and the combined leakage rate Primary for all MSIV leakage paths is~ 86 scfh Containment when tested at~ 25 psig. Leakage Rate Testing Program Dresden 2 and 3 3.6.1.3-8 Amendment No.256/249

Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACT! ON COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, containment to 2, or 3. OPERABLE status.

B. Required Action and - - - - - - - - - - - - NOTE - - - - - - - - - - - - -

associated Completion LCO 3.0.4.a is not applicable Time of Condition A when entering MODE 3.

not met.

B .1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Secondary containment C.1 - - - - - - - -NOTE- - - - - - - - -

inoperable during LCO 3.0.3 is not movement of recently applicable.

irradiated fuel assemblies in the secondary containment. Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

Dresden 2 and 3 3.6.4.1-1 Amendment No. 256/249

SCI Vs 3.6.4.2 3.6 CONTAINMENT SYSTEMS 3.6.4.2 Secondary Containment Isolation Valves (SCIVs)

LCO 3.6.4.2 Each SCIV shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS NOTES- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

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

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

3. Enter applicable Conditions and Required Actions for systems made inoperable by SCIVs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months penetration flow paths penetration flow path with one SCIV by use of at least inoperable. one closed and de-activated automatic valve, closed manual valve, or blind flange.

(continued)

Dresden 2 and 3 3.6.4.2-1 Amendment No. 2561 249

SCIVs 3.6.4.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 - - - - - - - - NOTE- - - - - - - - -

associated Completion LCO 3.0.3 is not Time of Condition A applicable.

or B not met during movement of recently irradiated fuel Suspend movement of Immediately assemblies in the recently irradiated secondary containment. fuel assemblies in the secondary containment.

Dresden 2 and 3 3.6.4.2-3 Amendment No. 256/249

SGT System

3. 6. 4. 3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SGT subsystem A .1 Restore SGT 7 days inoperable. subsystem to OPERABLE status.

B. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

associated Completion LCO 3.0.4.a is not applicable Time of Condition A when entering MODE 3.

not met in MODE 1, 2, or 3.

B .1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - -

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not met during movement of recently C.l Place OPERABLE SGT Immediately irradiated fuel subsystem in assemblies in the operation.

secondary containment.

C.2 Suspend movement of Immediately recently irradiated fuel assemblies in secondary containment.

(continued)

Dresden 2 and 3 3.6.4.3-1 Amendment No. 256 / 249

SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Two SGT subsystems D.1 Restore one SGT 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable in MODE 1, subsystem to 2, or 3. OPERABLE status.

E. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

associated Completion LCO 3.0.4.a is not applicable Time of Condition D when entering MODE 3.

not met.

E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. Two SGT subsystems F. 1 - - - - - - - - NDTE - - - - - - - -

inoperable during LCO 3.0.3 is not movement of recently applicable.

irradiated fuel assemblies in the secondary Suspend movement of Immediately containment. recently irradiated fuel assemblies in secondary containment.

Dresden 2 and 3 3.6.4.3-2 Amendment No. 256/249

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 sha 11 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.

ACTIONS CONDITION REQUIRED ACT ION COMPLETION TIME A. CREV System inoperable A. 1 Restore CREV System 7 days in MODE 1' 2, or 3 for to OPERABLE status.

reasons other than Condition C.

8. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

associated Completion LCO 3.0.4.a i s not applicable Time of Condition A when entering MODE 3.

not met in MODE 1' 2, -----------------------------

or 3.

B.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

Dresden 2 and 3 3.7.4-1 Amendment No. 256/249

CREV System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. CREV system inoperable C.l Initiate action to Immediately due to inoperable CRE implement mitigating boundary in MODE 1, 2, actions.

or 3.

C.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

C.3 Restore CRE boundary 90 days to OPERABLE status.

D. Required Action and D.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition C not met in MODE 1, 2, or 3. D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. CREV System inoperable ------------NOTE-------------

during movement of LCO 3.0.3 is not applicable.

recently irradiated -----------------------------

fuel assemblies in the secondary containment. E.l Suspend movement of Immediately recently irradiated fuel assemblies in the secondary CREV System inoperable containment.

due to an inoperable CRE boundary during movement of recently irradiated fuel assemblies in the secondary containment.

Dresden 2 and 3 3.7.4-2 Amendment No. 256/249

Control Room Emergency Ventilation AC System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Control Room Emergency Ventilation Air Conditioning (AC) System LCO 3.7.5 The Control Room Emergency Ventilation AC System shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control Room Emergency A.1 Restore Control Room 30 days Ventilation AC System Emergency Ventilation inoperable in MODE 1, AC System to OPERABLE 2, or 3. status.

B. Required Action and - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

associated Completion LCO 3.0.4.a is not applicable Time of Condition A when entering MODE 3.

not met in MODE 1, 2, or 3.

B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Control Room Emergency - - - - - - - - - - - -NOTE- - - - - - - - - - - - -

Ventilation AC System LCO 3.0.3 is not applicable.

inoperable during movement of recently irradiated fuel C.1 Suspend movement of Immediately assemblies in the recently irradiated secondary containment. fuel assemblies in the secondary containment.

Dresden Zand 3 3.7.5-1 Amendment No. 256/249

AC Sources-Shutdown 3.8.2 ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite - - - - - - - - - - - - NOTE- - - - - - - - - - - - -

circuit inoperable. Enter applicable Condition and Required Actions of LCO 3.8.8, when any required division is de-energized as a result of Condition A.

A.l Declare affected Immediately required feature(s),

with no offsite power available, inoperable.

A.2.1 Suspend CORE Immediately AL TE RATIONS.

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

A.2.3 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

(continued)

Dresden 2 and 3 3.8.2-2 Amendment No. 256 / 249

AC Sources-Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B .1 Suspend CORE Immediately inoperable. AL TE RATIONS.

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

B.3 Initiate action to Immediately restore required DG to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 - - - - - - - - - - - - - - -NOTES- - - - - - - - - - - - - - - - - - -

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.19.

2. SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(sl are not required to be OPERABLE per LCO 3.5.2, "RPV Water Inventory Control."

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

Dresden 2 and 3 3.8.2-3 Amendment No. 256 / 249

DC Sources-Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LCO 3.8.5 One 250 VDC and one 125 VDC electrical power subsystem shall be OPERABLE to support the 250 voe and one 125 voe Class lE electrical power distribution subsystems required by LCO 3.8.8, "Distribution Systems-Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of recently irradiated fuel assemblies in the secondary containment.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately DC electrical power required feature(s) subsystems inoperable. inoperable.

A.2.1 Suspend CORE Immediately AL TERA TI ONS.

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

A.2.3 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

Dresden 2 and 3 3.8.5-1 Amendment No. 256/249

DC Sources-Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - -

The following SRs are not required to be performed for the 250 voe electrical power subsystem: SR 3.8.4.2 and SR 3.8.4.4.

For DC* electrical power subsystems required In accordance to be OPERABLE the following SRs are with applicable applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.

Dresden 2 and 3 3.8.5-2 Amendment No. 256 / 249

Distribution Systems-Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

A.2.3 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystems to OPERABLE status.

A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and In accordance voltage to required AC and DC electrical with the power distribution subsystems. Surveillance Frequency Control Program Dresden 2 and 3 3.8.8-2 Amendment No. 256 / 249

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING THE LICENSE AMENDMENT REQUEST FOR ADOPTION OF TSTF-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" EXELON GENERATION COMPANY, LLC DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 CAC NOS. MF9295 AND MF9296, EPID: L-2017-LLA-0176 DOCKET NOS. 50-237 AND 50-249

1.0 INTRODUCTION

By application dated February 10, 2017, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A006 (Reference 1), as supplemented by letters dated July 13, 2017 (Reference 2), December 20, 2017 (Reference 3), and December 21, 2017 (Reference 4) (ADAMS Accession Nos. ML171948069, ML173548196, and ML17356A134 respectively), Exelon Generation Company, LLC {the licensee), requested to adopt Technical Specifications Task Force Traveler (TSTF) 542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" (Reference 5) for Dresden Nuclear Power Station, Units 2 and 3 (DNPS).

The final safety evaluation (SE) for TSTF-542, Revision 2 (Reference 6), was approved by the U.S. Nuclear Regulatory Commission (NRC or Commission) on December 20, 2016 (ADAMS Accession No. ML163438008).

The proposed changes replace existing technical specifications {TSs) requirements associated with "operations with the potential for draining the reactor vessel," (OPDRVs) with revised TSs providing an alternative requirement for Reactor Pressure Vessel (RPV) Water Inventory Control (WIC). These alternative requirements would protect Safety Limit 2.1.1.3. DNPS TS Section 2.0, "Safety Limits," 2.1.1.3, states "Reactor vessel water level shall be greater than the top of active irradiated fuel."

Additionally, a new definition "DRAIN TIME" is added to the DNPS TSs, Section 1.1, "Definitions." DRAIN TIME establishes requirements for the licensee to make RPV water level inventory determinations and to calculate RPV water inventory drain rates for MODE 4 and 5 outage related activities. Adequate licensee management of secondary containment requirements or mitigation of certain emergency core cooling system safety injection/spray systems during MODE 4 and 5 requires a properly calculated Drain Time.

Enclosure 3

The licensee has proposed several variations from the TS changes described in the applicable parts of TSTF-542, Revision 2, or the NRG-approved TSTF-542 SE. These are explained below in Section 2.2.5 and evaluated in Section 3.5 of this SE.

The supplements dated July 13, 2017, December 20, 2017, and December 21, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on April 11, 2017 (82 FR 17457).

2.0 REGULATORY EVALUATION

2.1 System Description The boiling-water reactor (BWR) RPVs have a number of penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup, and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release.

During operation in Modes 1 (Power Operation - Reactor Mode Switch in Run), 2 (Startup -

Reactor Mode Switch in Refuel (with all reactor vessel head closure bolts fully tensioned or Startup/Hot Standby), and 3 (Hot Shutdown - Reactor Mode Switch in Shutdown and average reactor coolant temperature > 212 °F (degrees Fahrenheit)), the TS for instrumentation and emergency core cooling systems (ECCS) require operability of sufficient equipment to ensure large quantities of water will be injected into the vessel should level decrease below the preselected value. These requirements are designed to mitigate the effects of a loss-of-coolant accident (LOCA), but also provide protection for other accidents and transients that involve a water inventory loss.

During BWR operation in MODE 4 (Cold Shutdown - Reactor Mode Switch in Shutdown with all reactor vessel head closure bolts fully tensioned and average reactor coolant temperature

212 °F, and Mode 5 (Refueling - one or more reactor vessel head closure bolts less than fully tensioned and Reactor Mode Switch in Shutdown or Refuel), the pressures and temperatures that could cause a LOCA are not present. During certain phases of refueling (MODE 5) a large volume of water is available above the RPV (i.e., the RPV head is removed, the water level is

~ 23 feet over the top of the RPV flange, and the spent fuel storage pool gates are removed).

The large volume of water available in and above the RPV (during much of the time when in Mode 5) provides time for operator detection and manual operator action to stop and mitigate an RPV draining event. However, typically at other times during a refueling outage, during Cold Shutdown (MODE 4) or Refueling (MODE 5), there may be a potential for significant drainage paths from certain outage activities, human error, and other events when it is more likely to have some normally available equipment, instrumentation, and systems inoperable due to maintenance and outage activities. There may not be as much time for operator action as compared to times when there are large volumes of water above the RPV.

In comparison to Modes 1, 2, and 3, with typical high temperatures and pressures (especially in Modes 1 and 2), Modes 4 and 5 generally do not have the high pressure and temperature considered necessary for a LOCA envisioned from a high energy pipe failure. Thus, while the

potential sudden loss of large volumes of water from a LOCA are not expected, operators monitor for BWR RPV water level decrease from potential significant or even unexpected drainage paths. These potential drainage paths in Modes 4 and 5 generally would require less water replacement capability to maintain water above TAF. "

To address the drain down potential during Modes 4 and 5, the existing DNPS TSs contain specifications that are applicable during OPDRVs, or require suspension of OPDRVs if certain equipment is inoperable. The term OPDRVs is not specifically defined in the TS and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions and surveillance requirements (SR), and deleting references to OPDRVs throughout the TSs.

2.2 Proposed TS Changes Section 2.2.1 discusses the addition of a new definition, DRAIN TIME (evaluated below in Section 3.1). Section 2.2.2 discusses TS 3.3, "INSTRUMENTATION," revisions including TS 3.3.5.1, "ECCS Instrumentation;" adds new TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" (including Table 3.3.5.2) and renumbers existing TS 3.3.5.2, "Isolation Condenser (IC) System Instrumentation" to 3.3.5.3; revises TS pages for TS 3.3.6.1, "Primary Containment Isolation Instrumentation" (including Table 3.3.6.1 ); revises TS 3.3.6.2, "Secondary Containment Isolation Instrumentation" (including Table 3.3.6.2); and revises TS 3.3.7.1, "Control Room Emergency Ventilation (GREV) System Instrumentation" (evaluated below in Section 3.2.1 ). Section 2.2.3 discusses TS 3.5, "EMERGENCY CORE COOLING SYSTEM (ECCS) AND ISOLATION CONDENSER (IC) SYSTEM," revisions including TS 3.5.2 "RPV Water Inventory Control" (evaluated below in Section 3.3.1 ). Section 2.2.4 discusses deletion of existing TS references to OPDRVs (evaluated below in Section 3.6). Section 2.2.5 discusses DNPS plant-specific variations to TSTF-542, Revision 2 (evaluated below in Section 3.5).

2.2.1 Addition of DRAIN TIME Definition Reference 1 includes the following definition of "DRAIN TIME" that would be added to DNPS TS Section 1.1, "Definitions."

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

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

b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically

without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

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

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.

2.2.2 TS 3.3, "Instrumentation" The following subsections describe the existing and proposed changes to the DNPS TS, Section 3.3, "Instrumentation."

2.2.2.1 TS 3.3.5.1, "ECCS Instrumentation," Changes to TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation" Proposed changes to TS 3.3.5.1 include the deletion of Note 1 in Required Actions B.1, C.1, and E.1 which states:

"Only applicable in Modes 1, 2 and 3."

For Table 3.3.5.1-1, the applicability in Modes 4 and 5 was proposed for deletion because the instrumentation requirements during shutdown would be consolidated into the new TS 3.3.5.2, "RPV Water Inventory Control Instrumentation." Modes 4 and 5 Applicability and associated requirements would be deleted for the following functions:

Core Spray (CS) System (a) Reactor Vessel Water Level - Low Low (c) Reactor Steam Dome Pressure - Low (Permissive)

(d) CS Pump Discharge Flow-Low (Bypass)

(e) CS Pump Start-Time Delay Relay Low Pressure Coolant Injection (LPCI) System (a) Reactor Vessel Water Level - Low (Low)

(c) Reactor Steam Dome Pressure - Low (Permissive)

(e) Low Pressure Coolant Injection Pump Start Time Delay Relay (Pumps Band D)

(f) Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

Table 3.3.5.1-1 Footnote (a), which states, When associated ECCS system(s) are required to be OPERABLE per limiting condition for operation (LCO) 3.5.2, 'ECCS Shutdown,"' would be deleted. As a result, existing Footnotes (b) and (c) would be renumbered (a) and (b),

respectively.

2.2.2.2 TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation" The proposed insertion of new TS 3.3.5.2 would contain functions that are comprised of requirements moved from TSs 3.3.5.1 and 3.3.6.1, as well as new requirements. The new TS 3.3.5.2 is shown below:

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

APPLICABILITY: According to Table 3.3.5.2-1 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition referenced Immediately inoperable. in Table 3.3.5.2-1 for the channel.

B. As required by Required B.1 Declare associated Immediately Action A.1 and referenced penetration flow path(s) in Table 3.3.5.2-1. incapable of automatic isolation.

AND B.2 Calculate DRAIN TIME. Immediately C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A. 1 and referenced in Table 3.3.5.2-1.

D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and referenced OPERABLE status.

in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS injection/spray Time of Condition C or D subsystem inoperable.

not met.

SURVEILLANCE REQUIREMENTS

N()TE--------------------------------------------------------------

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Proqram

7 Table 3.3.5.2-1 (Page 1 of 1)

RPV Water lnventorv Control lnstrumentaf APPLICABLE CONDITIONS MODES REQUIRED REFERENCED OR OTHER CHANNELS FROM SPECIFIED PER FUNCTION REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System

a. Reactor Steam Dome 4,5 2 C SR 3.3.5.2.2 ~ 308.5 psig and Pressure - Low (Permissive) s 341.7 psig

b. Core Spray Pump Discharge 4,5 1 per pump (a) D SR 3.3.5.2.2 ~ 802 gpm and Flow-Low (Bypass) s 992 qpm

2. Low Pressure Coolant Injection (LPCI) System

a. Reactor Steam Dome 4,5 2 C SR 3.3.5.2.2 ~ 308.5 psig and Pressure - Low (Permissive) s 341.7 psig

b. Low Pressure Coolant 4,5 1 per loop (a) D SR 3.3.5.2.2 ~ 1107 gpm Injection Pump Discharge Flow-Low (Bypass)

3. Shutdown Cooling System (SOC) Isolation

a. Reactor Vessel Water Level - (b) 1 per trip system B SR 3.3.5.2.1 ~ 2.65 inches Low SR 3.3.5.2.2

4. Reactor Water Cleanup System Isolation

a. Reactor Vessel Water Level - (b) 1 per trip system B SR 3.3.5.2.1 ~ 2.65 inches Low SR 3.3.5.2.2 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, "RPV Water Inventory Control."

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

2.2.2.3 TS 3.3.5.2, "Isolation Condenser (IC) System Instrumentation" The existing TS 3.3.5.2, "Isolation Condenser (IC) System Instrumentation," and its subsection would be renumbered to TS 3.3.5.3 in order to maintain the TS numbering conventions.

2.2.2.4 TS 3.3.6.1, "Primary Containment Isolation Instrumentation" In Table 3.3.6.1-1, Function 6.b, Shutdown Cooling System (SOC) Isolation, Reactor Vessel Water Level - Low, the Applicability in Modes 4 and 5 was proposed for deletion. Also, Footnote (b) to Table 3.3.6.1-1 was proposed to be deleted, as it is applicable only to Function 6.b during Modes 4 and 5. This function would move to the new TS Table 3.3.5.2-1, Function 3.a, as shown above in Section 2.2.2.2 of this SE.

2.2.3 TS Section 3.5, "Emergency Core Cooling Systems (ECCS) and Isolation Condenser (IC) System" The title of TS Section 3.5 would be revised from "Emergency Core Cooling Systems (ECCS) and Isolation Condenser (IC) System" to "Emergency Core Cooling Systems (ECCS), Reactor Pressure Vessel (RPV) Water Inventory Control, and Isolation Condenser (IC) System."

The title of DNPS TS Section 3.5.2 would be revised from "ECCS - Shutdown" to "RPV Water Inventory Control," and TS 3.5.2 would be revised as follows:

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel {TAF) shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

One low pressure ECCS injection/spray subsystem shall be OPERABLE.

APPLICABILITY: Modes 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1. Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1. Initiate action to establish a Immediately associated Completion Time method of water injection of Condition A not met. capable of operating without offsite electrical power.

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

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

AND C.3 Verify one standby gas treatment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystem is capable of being placed in operation in less than the DRAIN TIME.

D. DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 --------------N()TE------------

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 Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for ::::: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately 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 Immediately gas treatment subsystem is capable of being placed in operation.

E. Required Action and E.1 Initiate action to restore DRAIN Immediately associated Completion Time TIME to.:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

of Condition C or D not met.

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

The proposed SR 3.5.2 are shown below:

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME.:: 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for the required ECCS injection/spray subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is .:: 1O ft 4 inches; or Program

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

SR 3.5.2.3 Verify, for the required ECCS injection/spray subsystem, In accordance with locations susceptible to gas accumulation are sufficiently the Surveillance filled with water. Frequency Control Program 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 In accordance with each manual, power operated, and automatic valve in the the Surveillance flow path, that is not locked, sealed, or otherwise secured Frequency Control in position, is in the correct position. Program SR 3.5.2.5 Operate the required ECCS injection/spray subsystem In accordance with through the recirculation line for.:: 1O minutes. the Surveillance Frequency Control Program SR 3.5.2.6 Verify each valve credited for automatically isolating a In accordance with penetration flow path actuates to the isolation position on the Surveillance an actual or simulated isolation signal. Frequency Control Program

SR 3. 5 .2. 7 ----------------------NOTE---------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem can In accordance with be manually operated. the Surveillance Frequency Control Program 2.2.4 Deletion of References to OPDRVs Term In Reference 1, the licensee proposed to revise existing TS requirements related to "operations with a potential for draining the reactor vessel" or "OPDRVs," with new requirements on RPV WIG that will protect Safety Limit 2.1.1.3. To remain consistent with the TSTS-542, all references to the term OPDRVs in the DNPS TSs will be deleted. The TS location of these references are summarized as follows: '

DNPS LCO Location of References 3.3.6.1, Primary Containment Isolation Table 3.3.6.1-1 Footnote (b)

Instrumentation 3.3.6.2, Secondary Containment Isolation Table 3.3.6.2-1 Footnote (a)

Instrumentation 3.3.7.1, Control Room Emergency Ventilation Applicability (GREV) System Instrumentation 3.5.2, RPV Water Inventory Control Required Action B.1, Condition C, SR 3.5.2.2 3.6.1.3, Primary Containment Isolation Condition F Valves (PCIVs) 3.6.4.1, Secondary Containment Applicability, Condition C 3.6.4.2, Secondary Containment Isolation Applicability, Condition D Valves (SCIVs) 3.6.4.3, Standby Gas Treatment (SGT)

Applicability, Condition C, Condition F System 3.7.4, Control Room Emergency Ventilation Applicability, Condition E (GREV) System 3.7.5, Control Room Emergency Ventilation Applicability, Condition C Air Conditioninq (AC) System 3.8.2, AC Sources - Shutdown Condition A, Condition B 3.8.5, DC (direct current) Sources -

Condition A Shutdown 3.8.8, Distribution Systems - Shutdown Condition A Other miscellaneous changes.

In a letter dated July 13, 2017 (Reference 2), the licensee corrected the proposed change to SR 3.8.2.1, Note 2 which states; "SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown."" Since the title of LCO 3.5.2 was proposed to be changed, this note will be revised to read:

[Note] 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."

In a letter dated December 20, 2017 (Reference 3), the licensee corrected a typographical omission associated with TS Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation,"

CS Function 1.a, Reactor Steam Dome Pressure - Low (Permissive) and LPCI Function 2.a, Reactor Steam Dome Pressure - Low (Permissive). A reference to Footnote (a) was added to the REQUIRED CHANNELS PER FUNCTION column. Additionally, 2 typographical errors were corrected on TS pages 3.5.2-1 and 3.5.2-3.

In a letter dated December 21, 2017 (Reference 4), the licensee corrected an error associated with the letter dated December 20, 2017, regarding TS Table 3.3.5.2-1 Functions 1.a and 2.a.

The NRC staff reviewed this supplemental information and finds the licensee's revisions to be acceptable.

SR 3.8.2.1, Note 2 which states; "SR 3.8.1.13 and SR 3.8.1.19 are not required to be met when associated ECCS subsystem(s) are not required to be OPERABLE per LCO 3.5.2, "ECCS-Shutdown."" Since the title of LCO 3.5.2 was proposed to be changed, this note will be revised to read:

[Note] 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."

2.2.5 DNPS Plant-Specific TSTF-542 TS Variations In Section 2.2 of Reference 1, the licensee identified several DNPS plant-specific TS variations from the TSTF-542, Revision 2 (Reference 5), or the NRG-approved TSTF-542 SE (Reference 6). The licensee states these variations do not affect the applicability of the TSTF-542 or the NRC staff's SE. The staff has determined the licensee's proposed variations can be characterized as either administrative or technical. Section 3.5 of this SE includes the staff's technical evaluation of each of these technical variations.

2.2.5.1 Variation 1, Instrumentation functions - pump start time delay relays There are ON PS-specific instrumentation functions that differ from the Standard Technical Specifications (STS) (References 7 and 8). DNPS TS Table 3.3.5.1-1, Functions 1.e and 2.e describe pump start time delay relays related to the automatic starting of the CS and LPCI pumps. The licensee proposed to remove these Functions' requirements in Modes 4 and 5 from TSs.

2.2.5.2 Variation 2, Dedicated SOC The DNPS design features a SOC system that is dedicated to the removal of core decay heat and maintaining the temperature of the reactor coolant. Residual heat removal (RHR) is not a mode of another system like LPCI; therefore, the potential for system misalignments are less likely for the DNPS SOC system. This Function was proposed to be moved from TS 3.3.6.1, Table 3.3.6.1-1, Function 6.b, to new TS 3.3.5.2, Table 3.3.5.2-1 Function 3.a.

The licensee also proposed a variation to retain TS 3.3.6.1, "Primary Containment Isolation Instrumentation," Required Actions 1.1 and 1.2, which require for an inoperable channel to either immediately restore the channel to operable status or to immediately initiate action to isolate the SOC system. DNPS TS 3.3.6.1, Required Action 1.2, "Initiate action to isolate the Shutdown Cooling System," is similar to STS 3.3.6.1 Required Action J.2, "Initiate action to isolate the Residual Heat Removal (RHR) Shutdown Cooling System," which is deleted by TSTF-542. The licensee stated in Reference 1 that:

"TS 3.3.6.1 Required Action 1.2 is retained to account for SOC system flow path isolation in Mode 3 ... "

2.2.5.3 Variation 3, Channel checks DNPS does not currently have the capability to perform Channel Checks for the following proposed new Table 3.3.5.2-1, Functions; 1.a, "Reactor Steam Dome Pressure-Low (Permissive),"

1.b, "Core Spray Pump Discharge Flow-Low (Bypass),"

2.a, "Reactor Steam Dome Pressure-Low (Permissive)," and 2.b, "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)."

Since the existing DNPS TSs do not include Channel Checks for these functions, no Channel Check SR was proposed for these functions.

2.2.5.4 Variation 4, Channels per loop Each DNPS unit has two LPCI loops with two pumps in each loop (i.e., four LPCI pumps per unit). The existing DNPS TSs require one operable channel for each LPCI loop for the "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)," Function. The licensee proposed to maintain the one channel per loop for new TS 3.3.5.2, Function 2.b, in lieu of one channel per pump as described in the TSTF-542, since DNPS has only one flow transmitter for each loop which monitors the flow of both pumps in that loop.

2.2.5.5 Variation 5, Manual initiation logic The existing DNPS TSs do not include a manual initiation logic function for the CS or LPCI subsystems. Since this function does not exist at DNPS, manual initiation functions for LPCI and CS were not proposed for new Table 3.3.5.2-1. Therefore, new TS 3.3.5.2 as proposed for DNPS does not include a logic system functional test SR, which would only apply to the manual initiation functions. As an alternative, the licensee proposed that TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," include SR 3.5.2.7 to verify that the DNPS LPCI and CS subsystems can be manually operated through the manipulation of subsystem components from the main control room (MCR).

2.2.5.6 Variation 6, Reactor water cleanup isolation The DNPS design provides for isolation of the reactor water cleanup (RWCU) system at Reactor Vessel Water Level-Low versus Reactor Vessel Water Level-Low Low as specified in TSTF-542; therefore, the proposed new Table 3.3.5.2-1 reflects this RWCU isolation difference.

2.2.5.7 Variation 7, Automatic isolation on low water level The automatic isolation on Reactor Vessel Water Level-Low functions for the RWCU and SOC systems at DNPS varies slightly from the system described in the STS (Reference 7). These functions receive input from four reactor vessel water level channels. Each channel provides input to a trip string. There are two trip systems, each having two trip strings. In order to cause an isolation of the RWCU or SOC, the trip logic scheme requires one-out-of-two taken twice (i.e., at least one trip). Proposed Table 3.3.5.2-1 has been revised from TSTF-542 to reflect the DNPS requirement for one operable channel in each Reactor Vessel Water Level-Low isolation trip system for RWCU and SOC.

2.2.5.8 Variation 8, Note for TS LCO 3.5.2 The existing DNPS TSs do not contain a Note applicable to LCO 3.5.2 regarding realignment to the LPCI mode, as specified in TSTF-542, Revision 2. This Note is not applicable to DNPS because of the separate SOC system that provides for the removal of reactor residual heat.

2.2.5.9 Variation 9, Suppression Pool and Contaminated Condensate Storage Tank At DNPS, verification of suppression pool and contaminated condensate storage tank volumes is contained in a single SR (i.e., SR 3.5.2.2) versus in separate SRs in the STS (SRs 3.5.2.1 and 3.5.2.2).

2.2.5.1 O Variation 10, TS 3.6.1.3, Condition F The licensee proposed to delete DNPS TS 3.6.1.3, Condition F, and all of its associated Required Actions. The Applicability for TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs);" is 'When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1, "Primary Containment Isolation Instrumentation."" This change was proposed because the MODE 4 and 5 PCIV requirements in TSs 3.3.6.1 and 3.6.1.3 would be moved to new TS 3.3.5.2.

2.3 Applicable Regulatory Requirements The regulation at Title 1O of the Code of Federal Regulations (10 CFR), Section 50.36(a)(1 ),

requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must include in the application, a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." However, per 10 CFR 50.36(a)(1 ), these TS bases "shall not become part of the technical specifications."

As required by 10 CFR 50.36(c)(1 )(i)(A), Technical specifications will include items in the following categories: ( 1) Safety limits, limiting safety system settings, and limiting control settings. (i)(A) Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission.

As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulation at 10 CFR 50.36(c)(2)(ii) requires licensees to establish TS LCOs for items meeting one or more of the listed criteria. Specifically, Criterion 4, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety," supports the establishment of LCOs for RPV WIC due to insights gained via operating experience.

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

Pursuant to 10 CFR 50.90, whenever a holder of an operating license desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. The technical information to be included in an application for an operating license is governed in particular by 10 CFR 50.34(b).

As described in 10 CFR 50.92(a}, in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate. The general considerations that guide the Commission include, as stated in 10 CFR 50.40(a), how the TSs provide reasonable assurance the health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, including finding the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

NUREG-1433, Revision 4, contains the STS for BWR/4 plants; 1 and is part of the regulatory standardization effort, the NRC staff has prepared STS for each of the light-water reactor nuclear designs. The changes would be incorporated into future revisions of NUREG-1433, Volumes 1 and 2 (References 7 and 8).

The NRC staff's guidance for review of TSs is in Chapter 16, Technical Specifications, of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), dated March 201 O (ADAMS Accession No. ML100351425)

(Reference 9).

2.3.1 DNPS, Unit 3, Applicable Design Requirements DNPS updated final safety analysis report (UFSAR), Section 3.1.1, "Compliance with Draft Design Criteria," describes an evaluation of the proposed general design criteria (GDC) (issued July 1967) which were used by the Atomic Energy Commission to evaluate the original design of DNPS station. The following criteria are related to this license amendment request (LAR):

1 Dresden Nuclear Power Station, Units 2 and 3 are BWR/3 Mark 1 designs and have adopted the improved STS (BWR/4).

Criterion 9 - "Reactor Coolant Pressure Boundary." The reactor coolant pressure boundary (RCPB) shall be designed and constructed so as to have an exceedingly low probability of gross rupture or significant leakage throughout its design lifetime.

Criterion 12 - "Instrumentation and Control Systems." Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribed operating ranges.

Criterion 13 - "Fission Process Monitors and Controls." Means shall be provided for monitoring and maintaining control over the fission process throughout core life and for all conditions that can be reasonably be anticipated to cause variations in reactivity of the core, such as indication of position of control rods and concentration of soluble reactivity control poisons.

Criterion 16 - "Monitoring Reactor Coolant Pressure Boundary." Means shall be provided for monitoring the RCPB to detect leakage.

Criterion 33- "Reactor Coolant Pressure Boundary Capability." The RCPB shall be capable of accommodating without rupture, and with only limited allowance for energy absorption through plastic deformation, the static and dynamic loads imposed on any boundary component as a result of any inadvertent and sudden release of energy to the coolant. As a design reference, this sudden release shall be taken as that which would result from a sudden reactivity insertion such as a rod ejection (unless prevented by positive mechanical means), rod dropout, or cold water addition.

Criterion 37 - "Engineered Safety Features Basis for Design." Engineered safety features (ESFs) shall be provided in the facility to back up the safety provided by the core design, the RCPB, and their protection systems. As a minimum, such ESFs shall be designed to cope with any size RCPB break up to and including the circumferential rupture of any pipe in that boundary assuming unobstructed discharge from both ends.

Criterion 41 - "ESF Performance Capability." ESFs such as emergency core cooling and containment heat removal systems shall provide sufficient performance capability to accommodate partial loss of installed capacity and still fulfill the required safety function. As a minimum, each ESF shall provide this required safety function assuming a failure of a single active component.

Criterion 44 - "Emergency Core Cooling System Capability." At least two emergency core cooling systems, preferably of different design principles, each with a capability for accomplishing abundant emergency core cooling, shall be provided. Each emergency core cooling system and the core shall be designed to prevent fuel and clad damage that would interfere with the emergency core cooling function and to limit the clad metal-water reaction to negligible amounts for all sizes of breaks in the reactor coolant pressure boundary, including the double-ended rupture of the largest pipe. The performance of each emergency core cooling system shall be evaluated conservatively in each area of uncertainty. The systems shall not share active components and shall not share other features or components unless it can be demonstrated that: (a) the capability of the shared feature or component to perform its required function can be readily ascertained during reactor operation, (b) failure of the shared feature or component does not initiate a loss-of-coolant accident, and (c) capability of the shared feature or component to perform its required function is not impaired by the effects of a loss-of-coolant accident and is not lost during the entire period this function is required following the accident.

2.3.2 DNPS, Unit 2, Applicable Design Requirements DNPS, UFSAR, Section 3.1.2, "Compliance with Final Design Criteria," describes an evaluation of the design basis of the DNPS, Unit 2, as measured against the NRC GDC for nuclear power plants, Appendix A of 10 CFR 50, effective May 21, 1971, and subsequently amended July 7, 1971. The following criteria are related to this LAR.

Criterion 13 - "Instrumentation and Control." Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

Criterion 14 - "Reactor Coolant Pressure Boundary." The reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure and of gross rupture.

Criterion 30 - "Quality of Reactor Coolant Pressure Boundary." Components which are part of the reactor coolant pressure boundary shall be designed, fabricated, erected and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

Criterion 33 - "Reactor Coolant Makeup." A system to supply reactor coolant makeup for protection against small breaks in the reactor coolant pressure boundary shall be provided. The system safety function shall be to assure that specified acceptable fuel design limits are not exceeded as a result of reactor coolant loss due to leakage from the reactor coolant pressure boundary and rupture of small piping or other small components which are part of the boundary.

The system shall be designed to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished using the piping, pumps, and valves used to maintain coolant inventory during normal reactor operation.

Criterion 35 - "Emergency Core Cooling." A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that: (1) fuel and clad damage that could interfere with continued effective core cooling is prevented, and (2) clad metal-water reaction is limited to negligible amounts. Suitable redundancy in components and features and suitable interconnections, leak detection, isolation and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

3.0 TECHNICAL EVALUATION

Section 2.2 above lists proposed TS changes, as included in References 1 and 2, for the licensee to adopt TSTF-542, Revision 2. The following sections include the NRC staff's evaluation of each of these proposed changes.

3.1 Staff Evaluation of Proposed DRAIN TIME Definition As discussed in Section 2.2.1 above, the DRAIN TIME is the time it would take the RPV water inventory to drain from the current level to the TAF assuming the most limiting of the RPV penetrations flow paths with the largest flow rate, or a combination of penetration flow paths that could open due to a common mode failure, were to open and the licensee took no mitigating action.

The NRC staff reviewed the proposed DRAIN TIME definition from the TSTF-542 traveler. For the purpose of NRC staff considerations, the term "break" describes a pathway for water to drain from the RPV that has not been prescribed in the "DRAIN TIME" definition proposed in TSTF-542. Based on information furnished by the licensee in Reference 1, the NRC staff have determined the licensee is appropriately adopting the principles of DRAIN TIME as specified in TSTF-542. The NRC has reasonable assurance the licensee will include all RPV penetrations below the TAF in the determination of DRAIN TIME as potential pathways. As part of this evaluation, the staff reviewed requests for additional information used during the development of TSTF-542, Revision 2, which provided examples of bounding DRAIN TIME calculations for three examples: (1) water level at or below the reactor flange; {2) water level above RPV flange with fuel pool gates installed, and; (3) water level above reactor flange with fuel pool gates removed. The DRAIN TIME is calculated by taking the water inventory above the break and dividing by the limiting drain rate until the TAF is reached. The limiting drain rate is a variable parameter depending on the break size and the reduction of elevation head above break location during the drain down event. The discharge point will depend on the lowest potential drain point for each RPV penetration flow path on a plant-specific basis. This calculation provides a conservative approach to determining the DRAIN TIME of the RPV.

The NRC staff concluded that the licensee will use methods resulting in conservative calculations to determine RPV DRAIN TIME, thereby, protecting Safety Limit 2.1.1.3 which meets the requirements of 10 CFR 50.36{c)(3). Based on these considerations, the NRC staff has determined the licensee's proposed addition of DRAIN TIME definition to DNPS TSs to be acceptable.

3.2 TS 3.3.5.2, RPV WIC Instrumentation The existing TS 3.3.5.2, "Isolation Condenser {IC} System Instrumentation," is renumbered as TS 3.3.5.3. This achieves consistency within the DNPS TSs and is acceptable.

The purpose of the RPV WIC instrumentation is to support the requirements of new TS LCO 3.5.2, and the definition of DRAIN TIME. There are instrumentation and controls and their signal functions that are required for manual pump starts or required as a permissive or operational controls on the equipment of the systems that provide water injection capability, certain start commands, pump protection, and isolation functions. These instruments are required to be operable if the systems that provide water injection and isolation functions are to be considered operable as described in Section 3.3 of this SE for new TS 3.5.2. For DNPS, reactor operators have alternate, often more complex means, of starting and injecting water than the preferred simple push button start.

Specifically, the RPV WIC instrumentation supports operation of the CS and LPCI including manual starts when needed as well as the system isolation of the SOC system and the RWCU system. The equipment involved with each of these systems is described in the evaluation of TS 3.5.2 and the Bases for LCO 3.5.2.

3.2.1 Staff Evaluation of Proposed TS 3.3.5.2 LCO and Applicability In Reference 1, the licensee proposed a new TS 3.3.5.2 to provide alternative instrumentation requirements to support manual initiation of the low pressure ECCS injection/spray subsystem required in new TS 3.5.2 and automatic isolation of penetration flow paths that may be credited in the determination of DRAIN TIME. The existing TSs contain instrumentation requirements related to OPDRVs in TS Tables 3.3.5.1-1, 3.3.6.1-1, 3.3.6.2-1, and 3.3. 7 .1. These requirements from Tables 3.3.5.1-1 and 3.3.6.1-1 would be consolidated into new TS 3.3.5.2.

The proposed LCO 3.3.5.2 would state:

"The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE."

The proposed Applicability would state:

"According to Table 3.3.5.2-1."

TSTF-542 selected Table 3.3.5.2-1 to contain those instrumentation Functions needed to support manual initiation of the low pressure ECCS injection/spray subsystem required by LCO 3.5.2, and automatic isolation of penetration flow paths that may be credited in a calculation of DRAIN TIME. The functions in Table 3.3.5.2-1 are moved from existing TS 3.3.5.1, "ECCS Instrumentation," and TS 3.3.6.1, "Primary Containment Isolation Instrumentation" functions that are required in Modes 4 or 5 or during OPDRVs. Creation of TS 3.3.5.2 places these functions in a single location with requirements appropriate to support the safety function for TS 3.5.2. As identified in Section 2.2.5.5 above (Variation 5), the DNPS current design-basis does not include a manual initiation logic for the CS or LPCI systems. Therefore, as an alternative, the licensee proposed to add new SR 3.5.2.7 to TS 3.5.2 to verify that CS and LPCI can be manually operated through the manipulation of subsystem components from the MCR.

The NRC staff concluded the licensee's proposed alternative is acceptable for DNPS since either CS or LPCI (or both) subsystems would be available to perform the intended function to inject water into the RPV which meets the requirements of TSTF-542.

3.2.2 Staff Evaluation of Proposed TS 3.3.5.2 Actions As discussed in Section 2.2.2.2 above, the NRC staff has determined the licensee's proposed TS 3.3.5.2 Actions are sufficient and necessary, because when one or more instrument channels are inoperable the equipment and function controlled by these instruments cannot complete the required function in the normal manner. The Actions are evaluated as follows; Action A would be applicable when one or more instrument channels are inoperable from Table 3.3.5.2-1 and directs the licensee to immediately enter the Condition referenced in Table 3.3.5.2-1 for that channel.

Action B (concerning the SOC system isolation and RWCU system isolation functions) would be applicable when automatic isolation of the associated penetration flow path is credited as a path for potential drainage in calculating drain time. If the instrumentation is inoperable, Required Action B.1 directs an immediate declaration that the associated penetration flow path(s) are incapable of automatic isolation. Required Action B.2 requires an immediate re-calculation of drain time, but automatic isolation of the affected penetration flow paths cannot be credited.

Action C (concerning low reactor steam dome pressure permissive Functions necessary for ECCS subsystem manual injection valve opening) would address an event in which the permissive is inoperable. The function must be placed in the trip condition within one-hour. With the permissive function instrument in the trip condition, manual injection valve opening may now be performed using the preferred control board switches. This one-hour completion time is acceptable, because despite the preferred start method being prevented, the reactor operator can take manual control of the pump and the injection valve to inject water into the RPV and achieve the safety function. The time of one-hour also provides reasonable time for evaluation and placing the channel in trip.

Action D (concerning pump discharge flow bypass Functions) would address actions when the bypass is inoperable and there is a possible risk that the associated ECCS pump could overheat when the pump is operating and the associated injection valve is not fully open. In this condition, the operator can take manual control of the pump and the injection. Similar to justification in Action C, while this is not the preferred method, the CS and LPCI subsystem pumps can be started manually and the valves can be opened manually. The 24-hour completion time is acceptable, because the functions can be performed manually and it allows time for the operator to evaluate and have necessary repairs completed.

Action E would be needed and become necessary if the Required Actions and associated completion times of Condition C or D, were not met. If they were not met, then the associated low pressure ECCS injection/spray subsystem might be incapable of performing the intended function, and the CS/LPCI subsystem would be declared inoperable immediately.

These Actions direct the licensee to take appropriate actions as necessary and enter immediately into the Conditions referenced in Table 3.3.5.2-1. The NRC staff has determined these Actions satisfy the requirements of 10 CFR 50.36(c)(2)(i) by providing a remedial action permitted by the TS until the LCO can be met. Therefore, the staff has concluded there is reasonable assurance the licensee will take appropriate Actions during an unexpected drain event to either prevent or to mitigate RPV water level being lowered to the TAF and is therefore acceptable.

3.2.3 Staff Evaluation of Proposed TS 3.3.5.2 Surveillances The proposed TS 3.3.5.2 SRs include Channel Checks and Channel Functional Tests numbered SR 3.3.5.2.1 and SR 3.3.5.2.2, respectively. The NRC staff finds these tests are sufficient and adequate because they are essential to ensure the Functions of TS 3.3.5.2 are operable (i.e., capable of performing the specified safety function in support of TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in Modes 4 and 5). The NRC staff finds the proposed SRs of LCO 3.3.5.2 as described in Section 3.3.3 of TSTF-542 justification, satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained.

SR 3.3.5.2.1 would require a Channel Check and applies to system isolation functions in TS Table 3.3.5.2-1 for SOC isolation and RWCU system isolation. Performance of the Channel Check would ensure that a gross failure of instrumentation has not occurred. A Channel Check is normally a comparison of the parameter indicated on one channel to a similar parameter on other related channels. A Channel Check is significant in assuring that there is a low probability of an undetected complete channel failure and is a key safety practice to verifying the instrumentation continues to operate properly between each Channel Functional test. The NRC

staff has determined this is acceptable because the frequency is in accordance with the surveillance frequency control program (SFCP), which is consistent with the existing requirements and supports operating shift situational awareness.

SR 3.3.5.2.2 would require a Channel Functional test and applies to all functions in TS Table 3.3.5.2-1. A Channel Functional test is 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. It would be performed on each required channel to ensure that the entire channel will perform the intended function. The frequency is in accordance with the SFCP. The NRC staff has determined this is acceptable because it is consistent with the existing requirements for these Functions and is based upon operating experience that demonstrates channel failure is rare. In addition, this SR could be included as part of a refueling activity since during refueling outages periods in Modes 4 and 5 are often 30 days or less.

TSTF-542 did not include SRs to verify or adjust the instrument setpoint derived from the allowable value using a Channel Calibration or a surveillance to calibrate the trip unit. A draining event in MODE 4 or 5 is not an analyzed accident and, therefore, there is no accident analysis on which to base the calculation of a setpoint. The purpose of the Functions is to allow ECCS manual initiation or to automatically isolate a penetration flow path, but no specific RPV water level is assumed for those actions. Therefore, the MODE 3 Allowable Value was chosen for use in Modes 4 and 5 as it will perform the desired function. Calibrating the Functions in Modes 4 and 5 is not necessary, as TSs 3.3.5.1 and 3.3.6.1 continue to require the Functions to be calibrated on an established interval. Also, a draining event in MODE 4 or 5 is not an analyzed accident and, therefore, there are no accident analysis assumptions on response time.

The staff has determined this is acceptable, because this is adequate to ensure the channel responds with the required pumping systems to inject water when needed and isolation equipment to perform when commanded.

Based on the above determinations, the NRC staff has concluded the proposed SRs of LCO 3.3.5.2 satisfy 10 CFR 50.36(c)(3) by providing the specific SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained and is therefore acceptable.

3.2.4 Staff Evaluation of Proposed Table 3.3.5.2-1, RPV Water Inventory Control Instrumentation In order to support the requirements of proposed TS 3.5.2, "RPV Water Inventory Control," the associated instrumentation requirements are designated in Table 3.3.5.2-1. These instruments would be required to be operable if the systems that provide water injection and isolation functions were to be considered operable as described in the NRC staff's evaluation of TS 3.5.2 (Section 3.3 below).

Table 3.3.5.2-1 specifies the instrumentation that shall be operable for each function in the table for Modes 4 and 5 (or other specified conditions), the required number of channels per function, conditions referenced from Required Action A.1, SR for the Functions, the Allowable Value, and footnotes concerning items of the table.

Proposed TS Table 3.3.5.2-1, "RPV Water Inventory Control Instrumentation," presents details on the functions required to support the equipment and functions of TS 3.5.2. The NRC staff finds the presentation in this table to be acceptable, because this section sufficiently discusses the purpose of the functions, the applicability, the number of required channels, the references to the Condition to be entered by letter (e.g., A, B, C) if the function is inoperable, the applicable

SRs, the selection of the allowable value, and justification of differences between the existing and proposed TS functions. This RPV WIC instrumentation set is acceptable because it is adequate to ensure that the channels of instrumentation respond with the required accuracy permitting pumps and associated subsystems to operate to inject water when needed and isolating equipment when commanded to support the prevention of or to mitigate a potential RPV draining event.

Each of the ECCS subsystems in Modes 4 and 5 can be started by manual alignment of a small number of components. Automatic initiation of a low pressure ECCS injection/spray subsystem may be undesirable because it could lead to overflowing the RPV cavity due to injection rates of thousands of gallons per minute (gpm). Thus, there is adequate time to take manual actions (e.g., hours versus minutes). Considering the action statements as the DRAIN TIME decreases (the proposed TS 3.5.2, Action E, prohibits plant conditions that could result in drain times less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ), there is sufficient time for the reactor operators to take manual action to stop the draining event and to manually start a low pressure ECCS injection/spray subsystem or additional method of water injection as needed. Consequently, there is no need for automatic initiation of ECCS to respond to an unexpected draining event. This is acceptable, because a draining event is a slow evolution when compared to a design basis LOCA assumed to occur at a significant power level.

3.2.4.1 Staff Evaluation of Proposed Table 3.3.5.2-1 Functions For the Table 3.3.5.2-1, Functions 1.a and 2.a, CS and LPCI systems, Reactor Steam Dome Pressure - Low (Permissive), these signals would be used as permissives and protection for these low pressure ECCS injection/spray subsystem manual initiation functions. This function would ensure that the reactor pressure has fallen to a value below these subsystems' maximum design pressure before permitting the operator to open the injection valves of the low pressure ECCS subsystems. Even though the reactor steam dome pressure is expected to virtually always be below the ECCS maximum design pumping pressure during Modes 4 and 5, the Reactor Steam Dome Pressure - Low signals would be required to be operable and capable of permitting initiation of the ECCS. The proposed allowable value would be between ~ 308.5 pounds per square inch gauge (psig) and::; 341.7 psig, with two required channels per function, as it is currently in DNPS TS Table 3.3.5.1-1.

For Table 3.3.5.2-1, Functions 1.b and 2.b, CS and LPCI systems, Pump Discharge Flow - Low (Bypass), these minimum flow instruments were proposed to protect the associated low pressure ECCS pumps from overheating when the pump is operating and the associated injection valve is not fully open.

For LPCI, the minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump. The proposed required channels per function would be one per pump, as it is currently found in DNPS TS Table 3.3.5.1-1.

For CS, the minimum flow line valve is opened when low flow is sensed, and the valve is automatically closed when the flow rate is adequate to protect the pump, yet low enough to ensure that the closure of the minimum flow valve is initiated to allow full flow into the core. The proposed required channels per function is one per loop, as it is currently found in DNPS TS Table 3.3.5.1-1.

The proposed allowable values for Functions 1.b and 2.b are as follows (moved from DNPS TS Table 3.3.5.1-1):

CS ~ 802 gpm and s; 992 gpm LPCI ~ 1107 gpm For Table 3.3.5.2-1, Function 3.a, [SDC] system isolation, Reactor Vessel Water Level - Low, the function would only be required to be operable when automatic isolation of the associated penetration flow path is credited in the DRAIN TIME calculation. The proposed number of required instrument channels is one per trip system, which retains the requirement specified in existing TS Table 3.3.6.1-1 footnote (b) which states, "In MODES 4 and 5, provided Shutdown Cooling System integrity is maintained, only one channel per trip system with an isolation signal available to one shutdown cooling pump suction isolation valve is required."

The condition that the SDC system integrity be maintained is a concept related to OPDRVs, so it would not be carried over into TS 3.3.5.2 for RPV WIG instrumentation.

The Reactor Vessel Water Level-Low Function receives input from four reactor vessel water level channels. Each channel inputs into one of four trip strings. Two trip strings make up a trip system and both trip systems must trip to cause an isolation of the SDC suction isolation valves.

Any channel will trip the associated trip string. Only one trip string must trip to trip the associated trip system. The trip strings are arranged in a one-out-of-two taken twice logic to initiate isolation. Therefore, one trip string in each trip system is required to provide for automatic SDC system isolation. The Allowable Value was chosen to be the same as the Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low, Allowable Value from LCO 3.3.6.1 (2:. 2.65 inches).

For Table 3.3.5.2-1, Function 4.a, RWCU system isolation, Reactor Vessel Water Level - Low, the function is only required to be operable when automatic isolation of the associated penetration flow path is credited in the DRAIN TIME calculation. The proposed number of required channels is one per trip system. The Reactor Vessel Water Level-Low Isolation Function receives input from four reactor vessel water level channels. Each channel inputs into one of four trip strings. Two trip strings make up a trip system and both trip systems must trip to cause an isolation of the RWCU valves. Any channel will trip the associated trip string. Only one trip string must trip to trip the associated trip system. The trip strings are arranged in a one-out-of-two taken twice logic to initiate isolation. Therefore, one trip string in each trip system is required to provide for automatic RWCU system isolation. This proposed change is a new requirement in Modes 4 and 5 for the RWCU system. However, the instrumentation function is the same as TS Table 3.3.6.1, Function 6.b, which contains the requirements for Modes 1, 2, and 3, with the same allowable value, ~ 2.65 inches.

The NRG staff finds that proposed LCO 3.3.5.2 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public. This meets the requirements of 10 CFR 50.36(c)(2)(i) and, therefore, the staff has determined the licensee's proposed changes to LCO 3.3.5.2 are acceptable.

3.3 TS 3.5.2 - RPV WIG The NRG staff reviewed the water sources that would be applicable to the proposed TS 3.5.2.

LCO 3.5.2 would state, in part; "One low pressure ECCS injection/spray subsystem shall be OPERABLE."

'One' low pressure ECCS injection/spray subsystem would consist of either one CS subsystem or one LPCI subsystem. A CS subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or contaminated condensate storage tanks (CCSTs) to the RPV. An LPCI subsystem consists of one motor-driven pump, piping, and valves to transfer water from the suppression pool or the CCSTs to the RPV.

The ECCS pumps are high-capacity pumps, with flow rates of thousands of gpm. Most RPV penetration flow paths would have a drain rate on the order of tens or hundreds of gpm. The manual initiation/start of an ECCS pump would provide the necessary water source to counter these expected drain rates. Decay heat removal (OHR) in Modes 4 and 5 is not affected by the proposed DNPS TS change as these requirements on the number of SOC subsystems that must be operable and in operation to ensure adequate OHR from the core are unchanged.

These requirements can be found in the DNPS TS 3.4.8, "Shutdown Cooling (SOC) System -

Cold Shutdown," TS 3.9.7, "Reactor Pressure Vessel (RPV) Water Level - New Fuel or Control Rods," TS 3.9.8, "Shutdown Cooling (SOC) - High Water Level," and TS 3.9.9, "Shutdown Cooling (SOC) - Low Water Level." These DNPS OHR requirements are similar to the NU REG and can be found in the NUREG-1433 TS 3.4.9, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," TS 3.9.8, "Residual Heat Removal (RHR) - High Water Level, "and TS 3.9.1 O, "Residual Heat Removal (RHR) - Low Water Level." Based on these considerations, the NRG staff finds that the water sources provide assurances that the lowest functional capability required for safe operation is maintained and protecting the safety limit.

The proposed TS 3.5.2, "RPV Water Inventory Control," LCO contains two parts. The first part states that DRAIN TIME of RPV WIG to the TAF shall be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and the second part states that one low pressure ECCS injection/spray subsystem shall be OPERABLE. The proposed Applicability for TS 3.5.2 is Modes 4 and 5.

The NRG staff reviewed the proposed TS 3.5.2, focusing on ensuring the fuel remains covered with water and the changes made compared to the current TS. The proposed TS 3.5.2 contains Conditions A through E based on either required low pressure ECCS injection/spray subsystem operability or DRAIN TIME.

The existing TS LCO states that two low pressure ECCS injection/spray subsystems shall be operable, whereas the proposed LCO 3.5.2 states that only one low pressure ECCS injection/spray subsystem shall be operable. This change is reflected in Condition A. The change from two low pressure ECCS injection/spray subsystem to one low pressure ECCS injection/spray subsystem is because this redundancy is not required. With one low pressure ECCS injection/spray subsystem and nonsafety-related injection sources, defense in depth (DID) will be maintained. The DID measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to the required low pressure ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The proposed Modes 4 and 5 Applicability of TS 3.5.2 is appropriate given that the TS requirements on ECCS in Modes 1, 2, and 3, will be unaffected.

The proposed Condition A states that if the required low pressure ECCS injection/spray subsystem is inoperable, it is to be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Proposed Condition B states that if Condition A is not met, a method of water injection capable of operating without offsite electrical power shall be established immediately. The proposed Condition B provides adequate assurance of an available water source should Condition A not be met within the 4-hour completion time.

The proposed Condition C states that for a DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , to (C.1) verify secondary containment boundary is capable of being established in less than the DRAIN TIME with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.2) verify each secondary containment penetration flow path is capable of being isolated less than the DRAIN TIME with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and (C.3) verify required one SGT subsystem is capable of being placed in operation in less than the drain time with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The proposed Condition C provides adequate protection should the DRAIN TIME be< 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the ability to establish secondary containment, isolate additional flow paths, and have the SGT subsystem capable of being placed in operations.

The proposed Condition D states that when DRAIN TIME< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to (D.1) immediately initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level > T AF for ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , and (D.2) immediately initiate action to establish secondary containment boundary, and (D.3) immediately initiate action to isolate each secondary containment penetration flow path or verify it can be manually isolated from the control room, and (D.4) immediately initiate action to verify one SGT system is capable of being placed in operation. Additionally, there is a note stating that required low pressure ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power, which is similar to proposed Condition B. The existing DNPS TS for Condition D (Required Action C.2 and associated completion time not met) is similar to proposed Condition D. The proposed Condition D provides adequate protection should the DRAIN TIME be< 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months because of the requirement for the ability to establish an additional method of water injection (without offsite electrical power), establish secondary containment, isolate additional flow paths, and have the SGT subsystem capable of being placed in operation.

The proposed Condition E states that when the required action and associated completion time of Condition C or Dis not met, or the DRAIN TIME is< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , then immediately initiate action to restore DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed Condition Eis new, as it is not present in the current DNPS TS. The proposed Condition Eis acceptable, as it provides the necessary step to restore the DRAIN TIME to~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months should the other conditions not be met, or if the DRAIN TIME is< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The NRC staff evaluated the proposed changes to TS 3.5.2 and finds them acceptable based on the actions taken to mitigate the water level reaching the TAF with the water sources available, and maintaining drain time ~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . LCO 3.5.2 correctly specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the Required Actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public.

3.3.1 Staff Evaluation of Proposed TS 3.5.2 Surveillances The proposed TS 3.5.2 SRs (Section 2.2.3 above) includes verification of Drain Time, verification of water levels/volumes that support low pressure ECCS injection/spray subsystems, verification of water filled pipes to preclude water hammer events, verification of correct valves positions for the required low pressure ECCS injection/spray subsystem, operation of the low pressure ECCS injection/spray systems in the recirculation line, verification of valves credited for automatic isolation actuated to the isolation position, and verification that the required low pressure ECCS injection/spray subsystem can be manually operated. Each of the seven SRs are described below.

SR 3.5.2.1: The DRAIN TIME would be determined or calculated, and required to be verified to be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months in accordance with the SFCP. The NRC staff has determined the option to place this frequency in the licensees SFCP is appropriate and consistent with similar LCOs and surveillances. This surveillance would verify the LCO for DRAIN TIME is met. Numerous indications of changes in RPV level are available to the operator. The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant (normally 3 operator shifts). Changes in RPV level would necessitate recalculation of the DRAIN TIME. As plant conditions change, the DRAIN TIME must be confirmed to be~ 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months or the LCO must be declared not met and the appropriate TS Actions followed.

SR 3.5.2.2: The suppression pool water level (~ 1O feet 4 inches) or contaminated condensate storage tank level (~ 140,000 available gallons) for a required ECCS injection/spray subsystem would be required to be verified to ensure pump net positive suction head and vortex prevention is available for the ECCS injection/spray subsystem required to be operable by the LCO.

Indications are available either locally or in the control room regarding suppression pool water level and contaminated condensate storage tank level. This surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.3: The surveillance requirement to verify the ECCS injection/spray subsystem piping is sufficiently filled of water would be retained from the existing TS 3.5.2. The proposed change would update the SR to reflect the change to LCO 3.5.2, which would require, in part, one low pressure ECCS injection/spray subsystem to be operable instead of two. SR 3.5.2.3 wording would change from "Verify, for each required ECCS ... " to "Verify, for the required ECCS ... " This change clarifies the requirement to maintain consistency with the proposed LCO. Maintaining the pump discharge lines of the required ECCS injection/spray subsystem sufficiently full of water ensures that the ECCS subsystem will perform properly. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at*one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), then the surveillance is not met. This surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.4: The SR to verify the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path would be retained from the existing TS 3.5.2.

Similar to the change discussed above for proposed SR 3.5.2.3, changes to SR 3.5.2.4 would clarify a proposed requirement for LCO 3.5.2. The proposed SR wording, "Verify for the required ECCS injection/spray subsystem each manual. .. " would replace "Verify each required ECCS injection/spray subsystem manual. .. " SR 3.5.2.4 would provide assurance that the proper flow path will be available for ECCS operation to support TS 3.5.2. This SR would not apply to valves that are locked, sealed, or otherwise secured in position, since these valves would be verified to be in the correct position prior to locking, sealing, or securing. This

surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.5: The required ECCS injection/spray subsystem would be required to be operated through its recirculation line for 2: 10 minutes in accordance with the SFCP. This would demonstrate that the subsystem is capable for operation to support TS 3.5.2, RPV water inventory control. Testing the ECCS injection/spray subsystem through the recirculation line is necessary to avoid overfilling the refueling cavity. The minimum operating time of 1O minutes is based on engineering judgement.

SR 3.5.2.6: Verification that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal would be required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur. This surveillance would be required to be performed in accordance with the SFCP.

SR 3.5.2.7: This SR would state, "Verify the required ECCS injection/spray subsystem can be manually operated." It would demonstrate that the required CS or LPCI subsystem could be manually initiated to provide additional RPV water inventory, if needed. By operating the associated pump and valve switches which operates all active components, water flow can be demonstrated by recirculation through the test line. Vessel injection/spray may be excluded from the SR, per the existing Note. This surveillance would be required to be performed in accordance with the SFCP.

The NRC staff evaluated each of these proposed SRs associated with the new LCO 3.5.2 and concluded they are appropriate for ensuring the operability of the equipment and instrumentation specified in LCO 3.5.2. As indicated in the traveler for TSTF-542, Revision 2, there has been only one traveler approved since the issuance of Revision 4 of NUREG-1433 and NUREG-1434 which affects the TSs revised by TSTF-542. That traveler is TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation," which was approved by the NRC on January 15, 2014. TSTF-523 affected SR 3.5.2.3, which verifies that the ECCS piping is full of water, and SR 3.5.2.4, which verifies that valves are in the correct position. Furthermore, the staff concluded that each of the proposed SRs are acceptable since they meet the requirements of 10 CFR 50.36(c)(2)(ii) regarding insights gained via operating experience and 10 CFR 50.36(c)(3) for surveillances by ensuring that the necessary quality of systems and components are maintained.

3.4 TS Table 3.3.5.1, Emergency Core Cooling System Instrumentation 3.4.1 Staff Evaluation of Proposed Changes to TS Table 3.3.5.1-1 LCO 3.3.5.1 currently states, "the ECCS instrumentation for each Function in Table 3.3.5.1-1, shall be OPERABLE," with the applicability as stated in the table. Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," which contains requirements for function operability during Modes 4 and 5 when the associated ECCS subsystem(s) are required to be operable per LCO 3.5.2, "ECCS - Shutdown." Conforming changes were proposed for the Actions table of LCO 3.3.5.1 as well.

As discussed above in Section 2.2.2.1, the licensee proposed to delete the following Modes 4 and 5, Table 3.3.5.1-1, function requirements:

1. CS system functions: (a) Reactor Vessel Water Level - Low Low, (c) Reactor Steam Dome Pressure - Low (Permissive), (d) Core Spray Pump Discharge Flow-Low (Bypass), (e) Core Spray Pump Start-Time Delay Relay,

and

2. LPCI functions; (a) Reactor Vessel Water Level - Low Low, (c) Reactor Steam Dome Pressure - Low (Permissive), (e) Low Pressure Coolant Injection Pump Start Time Delay Relay (Pumps B and D), (f) Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass)

These functions would be deleted to support consolidation of RPV WIC instrumentation requirements into proposed TS 3.3.5.2. The requirements for Functions 1(c), 1(d), 2(c), and 2(f) would be moved to proposed TS Table 3.3.5.2-1 as discussed in Section 3.2.4.1 of this SE.

For the other TS Table 3.3.5.1-1 Functions, 1(a), 1(e), 2(a), and 2(e), the Modes 4 and 5 requirements would not be retained. The existing DNPS TSs require automatic initiation of ECCS pumps on low reactor vessel water level. However, in Modes 4 and 5, automatic initiation of ECCS pumps (high capacity pumps) could result in overfilling the refueling cavity or water flowing into the main steam lines, potentially damaging plant equipment.

The NRC staff has determined it is acceptable to delete TS Table 3.3.5.1-1 Functions 1(a) and 2(a) on the bases that manual ECCS initiation is preferred over automatic initiation during Modes 4 and 5, and the operator would be able to use other, more appropriately sized pumps if needed to mitigate a draining event. The deletion of Functions 1.e and 2.e is evaluated below in Section 3.5.1 of this SE.

3.5 Staff Evaluation of Proposed Technical Variations The licensee proposed the following technical variations from the TS changes described in TSTF-542 or the applicable parts of the NRC staff's SE. The licensee stated in the LAR (Reference 1), that these variations do not affect the applicability of TSTF-542 or the NRC staff's SE to the proposed license amendment. The NRC staff evaluated each variation below.

3.5.1 Variation 1, Instrumentation functions - pump start time delay relays DNPS TS Table 3.3.5.1, Functions 1.e and 2.e, describe pump start time delay relays for the CS and LPCI pumps. These functions do not have an equivalent as described in the STS. The purpose of these pump start time delays is to stagger the automatic starting of the pumps thus limiting the starting electrical transients on the 4.16 kV emergency buses. The staggered starting of the CS and LPCI pumps is unnecessary for manual operation. Therefore, the staff finds that the deletion of the Mode 4 and 5 requirements listed TS Table 3.3.5.1 Functions 1.e and 2.e for the CS and LPCI pump start time delay relays, to be acceptable.

3.5.2 Variation 2, Dedicated Shutdown Cooling As stated in Reference 1, DNPS uses the SDC system which is dedicated to OHR. The DNPS SOC system is similar to the shutdown cooling function of the RHR system described the STS, except that SOC is not a mode of another system. The licensee proposed to use "Shutdown Cooling (SOC) System Isolation" instead of "RHR System Isolation" for Function 3 of TS Table 3.3.5.2-1, RPV WIC instrumentation.

The NRC staff determined the proposed variation is acceptable because the DNPS SDC system has a OHR function equivalent to the RHR system, and retaining the system name for TS Table 3.3.5.2-1 is consistent with the current licensing basis.

The licensee proposed a variation to retain TS 3.3.6.1, "Primary Containment Isolation Instrumentation," Required Actions 1.1 and 1.2, which require for an inoperable channel to either immediately restore the channel to operable status or to immediately initiate action to isolate the Shutdown Cooling System. DNPS TS 3.3.6.1, Required Action 1.2, "Initiate action to isolate the Shutdown Cooling System," is similar to STS 3.3.6.1 Required Action J.2, "Initiate action to isolate the Residual Heat Removal (RHR) Shutdown Cooling System," which is deleted by TSTF-542. The licensee stated in Reference 1, that, "TS 3.3.6.1 Required Action 1.2 is retained to account for SOC system flow path isolation in Mode 3 ... "

The NRG staff determined that retaining TS 3.3.6.1, Required Action 1.2, "Initiate action to isolate the Shutdown Cooling System," for reactor level channel inoperability is acceptable since this action is applicable to MODE 3, SOC isolation requirements.

Based on these determinations, the NRG staff concludes that the licensees proposed variations regarding the SDC are acceptable to support the adoption of TSTF-542 at DNPS.

3.5.3 Variation 3, Channel checks As identified in Section 2.2.5.3 above, DNPS does not currently have the capability to perform Channel Checks for the following proposed Table 3.3.5.2-1 Functions:

1.a, "Reactor Steam Dome Pressure-Low (Permissive),"

1.b, "Core Spray Pump Discharge Flow-Low (Bypass),"

2.a, "Reactor Steam Dome Pressure-Low (Permissive)," and 2.b, "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)."

The NRG staff has determined that the above instrument Functions do not have existing Channel Checks (TS Table 3.3.5.1-1) and no future Channel Checks were proposed for the instruments being relocated to new TS Table 3.3.5.2-1. Since Channel Checks for these Functions have no impact on manual low pressure ECCS injection/spray capabilities for CS or LPCI and the licensee will retain its current licensing basis for these instruments, the NRG staff has determined the proposed variation to be acceptable.

3.5.4 Variation 4, Channels per loop Each DNPS unit has two LPCI loops with two pumps in each loop. The DNPS TSs currently require one operable channel for each LPCI loop for the "Low Pressure Coolant Injection Pump Discharge Flow-Low (Bypass)," Function. The licensee proposed to maintain the one channel per loop for TS 3.3.5.2, Function 2.b, in lieu of one channel per pump as described in the STS, since at DNPS, there is only one flow transmitter for each loop that monitors the flow of both pumps in that loop (i.e., two LPCI loop flow transmitters per unit).

The NRG staff reviewed this variation and determined that the slight design differences between DNPS (loop) and STS (pump) do not have a negative impact associated with DRAIN TIME, and automatic actions to the LPCI pump protection for overheating during low flow conditions. The licensee has chosen to retain the current licensing basis for these instruments, and, therefore, the NRG staff finds the proposed variation to be acceptable.

3.5.5 Variation 5, Manual initiation logic The existing ONPS TSs do not include a manual initiation logic function for the CS or LPCI subsystems. This is due to the fact that the ONPS design does not include this feature.

Therefore, since this function does not exist at ONPS, manual initiation functions for LPCI and CS were not proposed in TS 3.3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control,"

Table 3.3.5.2-1. Additionally, since the manual initiation functions are not included in Table 3.3.5.2-1, the associated logic system functional test would likewise not be required for TS 3.3.5.2. Therefore, TS 3.3.5.2 as proposed for ONPS does not include a logic system functional test SR. As an alternative, the licensee proposed that TS 3.5.2, "Reactor Pressure Vessel (RPV) Water Inventory Control," include SR 3.5.2.7 to verify that the CS and LPCI subsystems can be manually operated through the manipulation of subsystem components from licensed operators in the ONPS MCR.

The NRC staff reviewed the licensee proposed alternative and determined that although ONPS does not have the capability to start an ECCS subsystem with a single push button, the components that provide low pressure ECCS injection/spray into the RPV can be started from the MCR, as required, to support Modes 4 and 5 operations. The manipulation of low pressure ECCS subsystem components from the MCR would be verified in accordance with new SR 3.5.2.7. This SR verifies that the required CS or LPCI subsystem (including associated pump switches, and valve(s)) can be manually operated to provide additional RPV water inventory, if needed. Therefore, the NRC staff concludes that the licensees proposed alternative (variation) is acceptable.

3.5.6 Variation 6, RWCU System Isolation The ONPS design provides for isolation of the RWCU system at the Reactor Vessel Water Level-Low signal versus the Reactor Vessel Water Level-Low Low signal in STS. The licensee proposed that Table 3.3.5.2-1 reflects this RWCU isolation difference.

The NRC staff evaluated this variation and made the comparison to that specified in STS Table 3.3.5.2-1, Function 4.a, RWCU system isolation, Reactor Vessel Water Level - Low Low, Level 2 (Reference 7) which has an Allowable Value of~ -47 inches. The licensee will retain the current licensing basis for ONPS by proposing TS Table 3.3.5.2-1, Function 4.a, RWCU system isolation, Reactor Vessel Water Level - Low, which has an Allowable Value of~ 2.65 inches. The NRC staff has concluded the licensees proposed variation for the RWCU system isolation Allowable Value includes increased conservatisms compared to the STS value and meets the TSTF-542 requirements and is, therefore, acceptable.

3.5.7 Variation 7, Automatic Isolation on Reactor Water Level ONPS Table 3.3.5.2-1, Functions 3.a and 4.a, specify requirements for the automatic isolation on Reactor Vessel Water Level-Low for the SOC and RWCU, which at ONPS varies slightly from the STS (Reference 7). These functions receive input from four reactor vessel water level channels. Each channel inputs into one of four trip strings and two trip strings make up a trip system. The trip systems are aligned in a parallel configuration, both trip systems must trip in order to cause an isolation of the SOC or RWCU subsystem valves. Any channel will trip its associated trip string and trip system. Therefore, both trip systems with one trip string in each trip system is required to provide for automatic SOC and RWCU system isolation. The licensee's proposed Table 3.3.5.2-1 has been revised from TSTF-542 to reflect the ONPS requirement for one operable channel in each Reactor Vessel Water Level-Low isolation trip system for SOC and RWCU.

The NRC staff has determined that the differences between the DNPS and STS requirements for RWCU and RHR/SDC system trip systems do not negatively affect the ability of DNPS to initiate system isolation when needed to support DRAIN TIME. The staff have concluded that any single channel will trip its associated trip string and trip system; and, therefore, the proposed variation is acceptable.

3.5.8 Variation 8, Note for TS LCO 3.5.2 The existing DNPS TSs do not contain a Note applicable to LCO 3.5.2 regarding realignment to the low pressure coolant injection mode. This Note is not applicable to DNPS because of the separate SOC system that provides for the removal of reactor residual heat. This has no effect on the adoption of TSTF-542.

The NRC staff reviewed this variation and has concluded that the absence of this LCO 3.5.2 Note from the existing DNPS TSs has no effect on the adoption of TSTF-542, and, is, therefore, acceptable.

3.5.9 Variation 9, Suppression Pool and CCST Verification of DNPS suppression pool and CCST volumes is contained in a single SR (i.e., SR 3.5.2.2) versus in separate SRs specified in the STS (SRs 3.5.2.1 and 3.5.2.2).

The NRC staff has concluded that the licensee proposed variation is equivalent to the STS and has no impact on the adoption of TSTF-542 at DNPS, therefore, this variation is acceptable.

3.5.10 Variation 10, TS 3.6.1.3, Condition F The licensee proposed to delete DNPS TS 3.6.1.3, Condition F, and all of its associated Required Actions. The Applicability for TS 3.6.1.3, "Primary Containment Isolation Valves (PCIVs);" is 'When associated instrumentation is required to be OPERABLE per LCO 3.3.6.1,

'Primary Containment Isolation Instrumentation." In Reference 1, the licensee states; "This change is justified since OPDRVs requirements have been deleted, and Mode 4 and 5 PCIV requirements have been relocated from TS 3.3.6.1 and 3.6.1.3 to the proposed TS 3.3.5.2. Thus, there are no longer any PCIVs required to be operable by TS 3.6.1.3 during Mode 4 or 5. These requirements are addressed by the proposed TS 3.3.5.2 in their entirety. Following the removal of OPDRVs and relocation of Mode 4 and 5 requirements as discussed above, this Condition and associated Actions in TS 3.6.1 .3 would never be applicable; therefore, are no longer necessary. These requirements are addressed by the proposed TS 3.3.5.2 in their entirety."

The NRC staff evaluated the licensees proposed variation. DNPS TS 3.6.1.3, Condition F, states, "Required Action and associated Completion Time of Condition A, B, C, or D not met for PCIV(s) required to be OPERABLE during MODE 4 or 5." (TS 3.6.1.3, Condition E, is similar to Condition F, but applies to Modes 1, 2, or 3). The staff determined that since the RPV WIC requirements would be consolidated into TSs 3.3.5.2 and 3.5.2, the Modes 4 and 5 requirements in TS 3.6.1.3 would no longer be applicable. Therefore, the NRC staff have concluded that the proposed variation is consistent with the requirements of TSTF-542 and is, therefore, acceptable.

3.6 Staff Evaluation of Proposed Deletion of References to OPDRVs Term Section 2.2.4 above lists the numerous OPDRVs references proposed for deletion. The proposed changes would replace the existing specifications related to OPDRVs with revised specifications for RPV WIC. For example, the proposed change removes; "operations with a potential for draining the reactor vessel," "OPDRVs," related concepts such as "Shutdown Cooling System integrity maintained," and Required Actions to "suspend OPDRVs." The term OPDRVs is not specifically defined in the TSs and historically has been subject to inconsistent application by licensees. The changes discussed in this SE are intended to resolve any ambiguity by creating a new RPV WIC TS with attendant equipment operability requirements, required actions and SRs and deleting references to OPDRVs throughout the TS.

The existing DNPS TSs contain instrumentation requirements related to OPDRVs in four separate TS. The proposed TS 3.3.5.2 consolidates the instrumentation requirements into a single location to simplify the presentation and provide requirements consistent with TS 3.5.2.

The remaining TSs with OPDRVs requirements are for containment, containment isolation valves, SGT system, control room habitability, temperature control, and electrical sources.

Each of these systems' requirements during OPDRVs were proposed for consolidation into new TS 3.5.2 for RPV WIC, based on the appropriate plant conditions and calculated DRAIN TIME.

The NRC staff has determined that deletion of OPDRVs references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a greatly clarified and simplified alternative set of controls for ensuring water level is maintained above the TAF and is therefore acceptable.

3.7 TS 3.1 O. Special Operations and TSTF 484, "Use of TS 3.10.1 for Scram Time Testing activities" The current DNPS TSs describe TS LCO 3.10.8, "lnservice Leak and Hydrostatic Testing Operations," allowed performance of an inservice leak or hydrostatic test with the average reactor coolant temperature greater than 212 °F, while considering operational conditions to still be in Mode 4, provided certain secondary containment and standby gas treatment system LCOs were met.

DNPS adoption of TSTF-484 (Reference 11) revised this LCO to expand its scope to include operations where RCS temperature exceeds 212 °F: (1) as a consequence of maintaining adequate reactor pressure for an inservice leak or hydrostatic test, or (2) as a consequence of maintaining adequate reactor pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test.

When the NRC approved LCO 3.10.8 and TSTF-484 for DNPS the NRC stated that, ... "two low pressure ECCS [Emergency Core Cooling Systems] injection/spray (i.e., core spray or LPCI) subsystems are required to be operable in Mode 4 at DNPS ... per TS 3.5.2, ECCS-Shutdown;"

however, per the new LCO 3.5.2 adopted as part of TSTF-542 only one low pressure ECCS injection/spray subsystem would be required to be operable in Mode 4.

The NRC staff determined that changing from two ECCS injection/spray subsystems to one ECCS injection/spray subsystem is satisfactory because this level of redundancy is not required, even during application of LCO 3.10.8. When the licensee applies LCO 3.10.8 at the end of a refueling outage, an exceptionally large volume of water is present in the reactor vessel

since the vessel is nearly water solid. There is much more water in the reactor vessel than that present during power operation and more than that present during most of an outage. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurred. In the event of a large RCS leak, the RPV would rapidly depressurize and allow operation of the low pressure ECCS. At low decay heat values, and near Mode 4 conditions, the stored energy in the reactor core will be very low. Therefore, the reasoning that operators would have time to respond with manual actions to start any ECCS pumps and properly align valves for injection from the control room remains true.

As previously stated in Section 3.3 of this SE, with one ECCS injection/spray subsystem and non-safety related injection sources, defense-in-depth will be maintained. The defense-in-depth measure is consistent with other events considered during shutdown with no additional single failure assumed. The DRAIN TIME controls, in addition to the required ECCS injection/spray subsystem, provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

Using the reasoning presented elsewhere in this SE for TSTF-542 and after additional review of the SE for DNPS TS 3.10.8 and TSTF-484, the NRC staff determined that the LCOs 3.3.5.2.1 and 3.5.2 adopted as part of TSTF-542 are satisfactory and will therefore be acceptable even during application of LCO 3.10.8.

3.8 Technical Conclusion Safety Limit 2.1.1.3 requires that reactor vessel water level shall be greater than the top of active irradiated fuel. Maintaining water level above the TAF ensures that the fuel cladding fission product barrier is protected during shutdown conditions. The TS changes evaluated within this SE establish new LCO requirements that address the preventive and mitigative equipment and associated instrumentation that provide an alternative means to support Safety Limit 2.1.1.3 during Modes 4 and 5 operations.

The reactor coolant system is at a low operating temperature ($.212 °F) and is depressurized during Modes 4 and 5 conditions (except during Special Operations per TS 3.10.8, "Leak and Hydrostatic Testing Operation," when allowed to be> 212 °F). An event involving a loss of inventory while in the shutdown condition is judged to not exceed the capacity of one low pressure ECCS injection/spray subsystem. The accidents that are postulated to occur during shutdown conditions, the fuel handling accident (UFSAR 15.7.3) and the gas waste system leak or failure (UFSAR 15.7.1), do not involve a loss of RPV inventory. The equipment and instrumentation associated with the RPV WIC TSs do not provide detection or mitigation related to these design basis accidents.

The proposed TS LCO 3.5.2 contains requirements for operability of one low pressure ECCS injection/spray subsystem along with requirements to maintain a sufficiently long DRAIN TIME that plant operators would have time to diagnose and mitigate an unplanned draining event.

The NRC staff has determined that the LCO 3.5.2 and LCO 3.3.5.2 provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility, and therefore, meet the LCO requirements of 10 CFR 50.36(c)(2)(i).

Additionally, the revised TS LCOs 3.5.2 and 3.3.5.2 provide remedial actions to be taken in the event the LCO is not satisfied, therefore, meeting the requirements of 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed Action statements provide reasonable assurance that an unexpected draining event can be prevented or mitigated before the RPV water level would be lowered to the TAF.

The NRC staff evaluated the proposed DRAIN TIME definition, TS 3.5.2, which contains the requirements for RPV WIC, and TS 3.3.5.2, which contains the requirements for instrumentation necessary to support TS 3.5.2. Based on the considerations discussed above, the NRC staff concludes that the proposed revisions are acceptable because they consolidate and clarify the RPV WIC requirements, which meet 10 CFR 50.36(c)(2)(ii), Criterion 4, to establish LCOs for structures, systems, or components significant to public health and safety as evidenced by operating experience.

The licensee proposed to delete phrases used for controls during OPDRVs from the TS Applicability, Condition, Required Actions, and Footnotes. The NRC staff has reviewed the proposed changes and determined that deletion of OPDRVs references, along with the corresponding editorial changes, are appropriate because the proposed TSs governing RPV WIC and the associated instrumentation, TSs 3.5.2 and 3.3.5.2, respectively, are a greatly clarified and simplified alternative set of controls for ensuring water level is maintained above the TAF.

The NRC staff reviewed the SRs associated with the new LCOs 3.5.2 and 3.3.5.2. The NRC staff finds that the proposed TS SRs 3.5.2 are acceptable since they support TS 3.5.2 DRAIN TIME requirements, assure that water inventory is available for low pressure ECCS injection/spray subsystem RPV injection and pump performance, low pressure ECCS injection/spray subsystem are adequately filled (mitigates effects of gas accumulation or voiding), the subsystems have verified valve positions to support RPV injection, verified pumps provide adequate flow to support DRAIN TIME and RPV injection, verification of automatic isolation, and low pressure ECCS injection/spray subsystems can be manually operated to inject. The NRC staff finds that the two SRs proposed for TS 3.3.5.2 are sufficient and adequate, because they are essential to ensure that the Functions are capable of performing their specified safety functions in support of TS 3.5.2, DRAIN TIME, and the protection from a potential drain down of the RPV in Modes 4 and 5. Therefore, the NRC staff concludes that the proposed SRs satisfy 10 CFR 50.36(c)(2)(ii) and 10 CFR 50.36(c)(3).

The NRC staff evaluated the proposed DNPS changes against each of the unit applicable design requirements per the UFSAR as detailed in Section 2.3 1 (Unit 3) and Section 2.3.2 (Unit

2) (Reference 10) of this SE. The NRC staff finds that the proposed changes for Mode 4 and 5 operations, as they relate to the proposed TS changes for the new DRAIN TIME definition and the removal of OPDRVs references, remain consistent with the GDCs in that the DNPS design requirements for instrumentation, reactor coolant leakage detection, the reactor coolant pressure boundary, and reactor coolant makeup are unaffected.

The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. In accordance with the 10 CFR 50.36(a)(1) requirement, the licensee provided TS Bases changes in the proposed license amendment request (Reference 1). The NRC staff acknowledges that the TS Bases changes provided describe the basis for the affected TS and follow the Final Policy Statement on TSs Improvements for Nuclear Power Reactors (58 Federal Register39132).

Additionally, the proposed TS changes were reviewed for technical clarity and consistency with the existing DNPS requirements for customary terminology and formatting. The NRC staff found that the proposed changes were consistent with Traveler TSTF-542, Revision 2 (Reference 5) and Chapter 16 of the SRP (Reference 9).

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the appropriate official for the State of Illinois was notified of the NRC's proposed issuance of the amendment on October 18, 2017. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration (Federal Register 82 FR 17457, dated April 11, 2017), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b}, no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principle Contributors: Diana Woodyatt, NRR/DSS/SRXB Khadijah West, NRR/DE/EICB Larry Wheeler, NRR/DSS/STSB Date of issuance: January 8, 2018

7.0 REFERENCES

1. Letter from Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3, Application to Revise Technical Specifications to Adopt Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," (RS-17-029), dated February 10, 2017, ADAMS Accession No. ML17045A006.

2. Letter from Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3, Supplement to Application to Revise Technical Specifications to Adopt Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," (RS-17-086),

dated July 13, 2017, ADAMS Accession No. ML17194B069.

3. Letter from Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3 to NRC, "Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"' dated December 20, 2017, ADAMS Accession No. ML17354B196

4. Letter from Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3 to NRC, "Supplement to Dresden Nuclear Power Station, Units 2 and 3 Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,"' dated December 21, 2017, ADAMS Accession No. ML17356A134.

5. Enclosure to Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," dated March 14, 2016, ADAMS Accession No. ML16074A448.

6. Final Safety Evaluation for Technical Specifications Task Force Traveler TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control," (TAC NO. MF3487),

dated December 20, 2016, ADAMS Accession No. ML16343B008.

7. U.S. Nuclear Regulatory Commission (USNRC), "Standard Technical Specifications, General Electric BWR/4 Plants," NUREG-1433, Vol. 1, "Specifications," Rev. 4.0, dated April 2012, ADAMS Accession No. ML12104A192.

8. U.S. Nuclear Regulatory Commission (USNRC), "Standard Technical Specifications, General Electric BWR/4 Plants," NUREG-1433, Vol. 2, "Bases," Rev. 4.0, dated April 2012, ADAMS Accession No. ML12104A193.

9. NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), Section 16, "Technical Specifications,"

dated March 2010, ADAMS Accession No. ML100351425.

10. Dresden Nuclear Power Station, Units 2 and 3, Updated Final Safety Analysis Report (UFSAR), Sections 3.1.1. & 3.1.2.

11. Letter from US NRC to Exelon Generation Company, LLC, "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 - Issuance of Amendments to Add Technical Specification 3.10.8, "lnservice Leak and Hydrostatic Testing Operations" (CAC Nos. MF5471-MF5476)," dated December 17, 2015, ADAMS Accession No. ML15324A439.

LIST OF ACRONYMS AC Air conditioning ADAMS Agencywide Documents Access and Management System BWR Boiling-Water Reactor CCST Contaminated Condensate Storage Tank CFR [Title 10 of the] Code of Federal Regulations GREV Control Room Emergency Ventilation cs Core Spray DC Direct Current OHR Decay Heat Removal DID Defense in Depth DNPS Dresden Nuclear Power Station ECCS Emergency Core Cooling System ESF Engineered Safety Feature a F degree Fahrenheit GDC General Design Criteria gpm gallons per minute IC Isolation Condenser LAR License Amendment Request LCO Limiting Condition for Operation LOCA Loss-Of-Coolant Accident LPCI Low Pressure Coolant Injection OPDRVs operations with potential for draining the reactor vessel NRG Nuclear Regulatory Commission psig pounds per square inch gauge PCIV Primary Containment Isolation Valve RCPB Reactor Coolant Pressure Boundary RHR Residual Heat Removal RPV Reactor Pressure Vessel RWCU Reactor Water Clean Up SCIV Secondary Containment Isolation Valve soc Shutdown Cooling SE Safety Evaluation SFCP Surveillance Frequency Control Program SGT Standby Gas Treatment SR Surveillance Requirement SRP Standard Review Plan STS Standard Technical Specification

TAF top of active fuel TS Technical Specification TSTF Technical Specification Task Force UFSAR Updated Final Safety Analysis Report USNRC United States Nuclear Regulatory Commission WIC Water Inventory Control

8. Hanson

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNIT NOS. 2 AND 3 - ISSUANCE OF AMENDMENTS TO RENEWED FACILITY OPERATING LICENSE NOS.

DPR-19 AND DPR-25 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TRAVELER FORCE 542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NOS. MF9295 AND MF9296; EPID L-2017-LLA-0176) DATED JANUARY 8, 2018 DISTRIBUTION:

PUBLIC RidsRgn3Mai1Center Resource RidsNrrDorlDpr Resource RecordsAmend Resource RidsNrrPMDresden Resource RidsNrrLASRohrer Resource RidsAcrs_MailCTR Resource RidsNrrDssSrxb Resource RidsNrrDssStsb Resource RidsNrrDeEicb Resource LWheeler, NRR MChernoff, NRR DWoodyatt, NRR KWest, NRR MHoncharik, NRR ADAMS Access1on No. ML17272A783

b1v memo dated OFFICE DORULPLIII/PM DORULPLIII/LA DSS/SRXB/BC DSS/STSB/BC NAME RHaskell SRohrer EOesterle* JWhitman*

DATE 10/03/2017 10/03/2017 09/27/2017 09/27/2017 OFFICE DE/EICB OGC-NLO DORULPLIII/BC DORULPLI 11/PM NAME MWaters* DRoth DWrona RHaskell DATE 09/27/2017 10/16/2017 01/08/2018 01/08/2018 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
CAC:MF9295, (Approved, Closed) CAC:MF9296, (Approved, Closed) EPID:L-2017-LLA-0176, TSTF-542 (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement, Supplement Administration Questions 11 July 2017 Answers Results Approval Other:
MONTHYEAR2017-03-16 [Table View]

ML17272A783

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

SUBJECT:

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