Text

Application to Adopt TSTF-372, Addition of LCO 3.0.8, Inoperability of Snubbers
	ML18116A133
Person / Time
Site:	Dresden, Clinton, Quad Cities, LaSalle
Issue date:	04/25/2018
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-18-032
	Download: ML18116A133 (53)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-18-032 10 CFR 50.90 April 25, 2018 ATTN: Document Control Desk U.S. Nuclear Regular Commission Washington, D.C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Application to Adopt TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers"

References:

1. TSTF-372, Revision 4, "Addition of LCO 3.0.8, lnoperability of Snubbers,"

dated April 23, 2004

2. Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of Limiting Condition for Operation 3.0.8 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process, dated May 4, 2005 (70 FR 23252)

In accordance with the provisions of 10 CFR 50.90 "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to: Facility Operating License (FOL) No. NPF-62 for Clinton Power Station, Unit 1; Renewed FOL Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3; Renewed FOL Nos. NPF-11 and NPF-18 for LaSalle County Station, Units 1 and 2; and Renewed FOL Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2.

April 25, 2018 U.S. Nuclear Regulatory Commission Page 2 The proposed amendment requests would modify the Technical Specifications (TS) requirements for inoperable dynamic restraints (snubbers) by adding a new Limiting Condition for Operation (LCO) 3.0.8. The change is consistent with the Nuclear Regulatory Commission (NRC) approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers,"

(i.e., Reference 1). The availability of this TS improvement was announced in the Federal Register on May 4, 2005 (70 FR 23252), as part of the consolidated line item improvement process (i.e., Reference 2).

The proposed changes have been reviewed and recommended for approval by the affected Plant Operations Review Committees in accordance with the EGC Quality Assurance Program. provides a description of the proposed changes, the requested confirmation of applicability, assessment, regulatory analysis, and environmental consideration of the proposed changes. Attachment 2 provides the insert text for the TS and TS Bases markups.

Attachments 3a through 3d provide the existing TS pages marked up to show the proposed changes. Attachments 4a through 4d provide revised (clean) TS pages. Attachment 5 provides a summary of the regulatory commitments made in this submittal. Attachments 6a through 6d provide the existing TS Bases pages marked up to show the proposed change (for information only).

EGC requests approval of the proposed License Amendment by April 25, 2019, with the amendment being implemented within 60 days of issuance.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials.

If you should have any questions regarding this submittal, please contact Mr. Mitchel Mathews at (630) 657-2819.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 25th day of April 2018.

Patrick Simpson Manager - Licensing Exelon Generation Company, LLC

April 25, 2018 U.S. Nuclear Regulatory Commission Page 3 Attachments: 1. Description and Assessment

2. Technical Specifications (TS) and TS Bases Inserts 3a. Proposed Technical Specifications Changes (Mark-Ups) for Clinton Power Station, Unit 1 3b. Proposed Technical Specifications Changes (Mark-Ups) for Dresden Nuclear Power Station, Units 2 and 3 3c. Proposed Technical Specifications Changes (Mark-Ups) for LaSalle County Station, Units 1 and 2 3d. Proposed Technical Specifications Changes (Mark-Ups) for Quad Cities Nuclear Power Station, Units 1 and 2 4a. Revised (Clean) Technical Specifications Pages for Clinton Power Station, Unit 1 4b. Revised (Clean) Technical Specifications Pages for Dresden Nuclear Power Station, Units 2 and 3 4c. Revised (Clean) Technical Specifications Pages for LaSalle County Station, Units 1 and 2 4d. Revised (Clean) Technical Specifications Pages for Quad Cities Nuclear Power Station, Units 1 and 2

5. Summary of Regulatory Commitments 6a. Proposed Technical Specifications Bases Changes (Mark-Ups) for Clinton Power Station, Unit 1 (For Information Only) 6b. Proposed Technical Specifications Bases Changes (Mark-Ups) for Dresden Nuclear Power Station, Units 2 and 3 (For Information Only) 6c. Proposed Technical Specifications Bases Changes (Mark-Ups) for LaSalle County Station, Units 1 and 2 (For Information Only) 6d. Proposed Technical Specifications Bases Changes (Mark-Ups) for Quad Cities Nuclear Power Station, Units 1 and 2 (For Information Only) cc: NRC Regional Administrator - Region III NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding a new Limiting Condition for Operation (LCO) 3.0.8.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-372, "Addition of LCO 3.0.8, Inoperability of Snubbers," Revision 4. The availability of this TS improvement was published in the Federal Register on May 4, 2005, as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the Model Safety Evaluation (SE) dated May 4, 2005, as part of the CLIIP. This review included a review of the NRCs evaluation, as well as the supporting information provided to support TSTF-372. EGC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC are applicable to Clinton Power Station (CPS), Unit 1; Dresden Nuclear Power Station (DNPS),

Units 2 and 3; LaSalle County Station (LSCS), Units 1 and 2; and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, and justify this amendment for the incorporation of the changes to the CPS, Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2 TS.

2.2 Optional Changes and Variations EGC is proposing the following variations from the TS changes described in the TSTF-372 Revision 4 and the NRCs model safety evaluation dated May 4, 2005:

2.2.1 The DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2 TS already contain an LCO 3.0.8 that pertains to the applicability of Actions throughout the TS for these dual-unit facilities. Specifically, that Actions apply to each unit individually.

Whenever the LCO refers to a system or component that is shared by both units, the Actions apply to both units simultaneously. This LCO is renumbered as LCO 3.0.9 to align with TSTF-372 for the affected plants. An example of this proposed change (i.e., for DNPS, Units 2 and 3) is shown in Figure 1 below:

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ATTACHMENT 1 DESCRIPTION AND ASSESSMENT LCO 3. 0 . 8 lvhen one or more required snubbers are unable to perform their as soc i ated support function ( s ) , any affected supported LCO ( sJ are not required to be declared not met solely for th i s reason if ris k is assessed and managed, and

a. the s nubber s not able to perform their ass ociated support function ( s ) are associated with only one train or subsystem of a multiple train or subsystem supported sy stem or are as sociated fvith a s ingle train or subsy stem supported system and are able to perform their ass ociated s upport function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support function( s) are associated with more than one train or subsys tem of a multiple train or s ub sys tem supported system and are able to perform their ass ociated support function within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s .

At the end of the specified period, the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO ( s ) shall be declared not met .

LCD 3 . 0. 9g LCOs, includ i ng associated ACTIO NS, shal l apply to each unit individua l ly, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units , the ACTIONS will apply to both units simultaneously .

Figure 1: Example of Renumbering of Existing LCO 3.0.8 for DNPS, Units 2 and 3 This variation is administrative in nature and does not affect the applicability of TSTF-372 to the DNPS, Units 2 and 3, LSCS, Units 1 and 2, or QCNPS, Units 1 and 2 TS.

2.2.2 EGC proposes the following minor variations from the TS Bases changes described in the TSTF-372, Revision 4:

The Model SE, Section 3.1.2 provided in the Notice of Availability published in the Federal Register on May 4, 2005, contains restrictions, applicable to Boiling Water Reactor (BWR) plants, to prevent potentially high-risk configurations. The specific configuration restrictions identified in the Model SE are being added to the proposed TS Bases for LCO 3.0.8.

Since the submittal is being made on behalf of CPS, Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2, the TS Bases insert included as Attachment 2, Insert 2 was written generically with bracketed information included to indicate that the specific systems required for the Tier 2 configuration restriction Page 2 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT options associated with the use of LCO 3.0.8.a as discussed in the Model SE will be specific to each plant's design. The purpose of this variation is to simplify the presentation of the information to accommodate this multi-station submittal. It does not represent a technical variation from the intent of TSTF-372. The specific systems that will be replace the generic systems included in Attachment 2, Insert 2 for each configuration restriction upon implement of the proposed changes once approved are as follows:

o CPS, Unit 1 1.a - High Pressure Core Spray (HPCS) or Reactor Core Isolation Cooling (RCIC) 1.b - Low Pressure Coolant Injection (LPCI) or Low Pressure Core Spray (LPCS) o DNPS, Units 2 and 3 1.a - High Pressure Coolant Injection (HPCI) or Isolation Condenser (IC) 1.b -LPCI or Core Spray (CS) o LSCS, Units 1 and 2 1.a - HPCS or RCIC 1.b - LPCI or LPCS o QCNPS, Units 1 and 2 1.a - HPCI or RCIC 1.b - LPCI or CS

The Model SE, Section 3.2, Item 1 (e) provided in the Notice of Availability published in the Federal Register on May 4, 2005, contains the statement "LCO 3.0.8 does not apply to nonseismic snubbers." This does not appear to be captured in the implementation process of the approved TSTF-372, Revision 4.

Therefore, EGC proposes to include this statement in the LCO 3.0.8 Bases (i.e., Attachment 2, Insert 2). Further guidance associated with the intent of this statement, as discussed in Section 3.0 of the Model SE and in TSTF-IG-05-03, "Implementation Guidance for TSTF-372, Revision 4, 'Addition of LCO 3.0.8, lnoperability of Snubbers,'" is also included in the proposed TS Bases insert for LCO 3.0.8.

These variations are insignificant regarding ensuring the proper application of the intent of TSTF-372, Revision 4.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Exelon Generation Company, LLC (EGC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for Clinton Power Station (CPS), Unit 1; Dresden Nuclear Power Station (DNPS), Units 2 and 3; LaSalle County Station (LSCS), Units 1 Page 3 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT and 2; and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2 by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change allows a delay time before declaring supported Technical Specification (TS) systems inoperable when the associated snubber(s) cannot perform its required safety function. Entrance into Actions or delaying entrance into Actions is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident while relying on the delay time allowed before declaring a TS supported system inoperable and taking its Conditions and Required Actions are no different than the consequences of an accident under the same plant conditions while relying on the existing TS supported system Conditions and Required Actions. Therefore, the consequences of an accident previously evaluated are not significantly increased by this change. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function. The proposed change restores an allowance in the pre-Improved Standard Technical Specifications (ISTS) conversion TS that was unintentionally eliminated by the conversion.

The pre-ISTS TS were considered to provide an adequate margin of safety for plant operation, as does the post-ISTS conversion TS. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

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

3.2 Verification and Commitments As discussed in the Model Application, Section 3.2, provided in the Notice of Availability published in the Federal Register on May 4, 2005, for this TS improvement, plant-specific verifications were performed as follows:

EGC proposes in these amendment requests for CPS, Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2, TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements (see Attachment 2, Insert 2).

LCO 3.0.8 will require that risk be managed and assessed. The proposed TS Bases state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. EGC will revise the TS Bases as proposed above with implementation of the amendment.

CPS, Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2 have TS Bases Control Programs consistent with Section 5.5 of the STS.

In addition, as discussed in the Model SE, Section 3.1.2 provided in the Notice of Availability published in the Federal Register on May 4, 2005, the following restrictions, applicable to BWR plants, are provided to prevent potentially high-risk configurations (hereafter referred to as the Tier 2 restrictions). The specific information which describes how EGC proposes to ensure that operations at CPS, Unit 1; DNPS, Units 2 and 3; LSCS, Units 1 and 2; and QCNPS, Units 1 and 2 will be in accordance with the Tier 2 requirements is provided below:

1. For BWR plants, one of the following two means of heat removal must be available when LCO 3.0.8.a is used:

a. At least one high pressure makeup path (e.g., using high pressure coolant injection (HPCI) or reactor core isolation cooling (RCIC) or equivalent) and heat removal capability (e.g., suppression pool cooling), including a minimum set of supporting equipment, not associated with the inoperable snubber(s), or

b. At least one low pressure makeup path (e.g., low pressure coolant injection (LPCI) or core spray (CS)) and heat removal capability (e.g., suppression pool cooling or Page 5 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT shutdown cooling), including a minimum set of supporting equipment, not associated with the inoperable snubber(s).

2. When LCO 3.0.8.b is used at BWR plants, it must be verified that at least one success path exists, using equipment not associated with the inoperable snubber(s), to provide makeup and core cooling needed to mitigate Loss of Offsite Power (LOOP) accident sequences (i.e., initiated by a seismically-induced LOOP event with concurrent loss of all safety system trains supported by the out-of-service snubbers).

EGC has provided a regulatory commitment to satisfy the above requirements by ensuring the appropriate plant procedures and administrative controls will be revised with implementation of the amendment (i.e., Attachment 5, Commitment 1). Additionally, these requirements are documented in the proposed TS Bases (i.e., Attachment 2, Insert 2 and Attachments 6a through 6d).

In addition to the Tier 2 restrictions, discussed above, Section 3.2, Item 1 (e), of the Model SE requires that appropriate plant procedures and administrative controls be used to implement the following restriction, described, and responded to by EGC below:

Every time the provisions of LCO 3.0.8 are used licensees will be required to confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs.

nonseismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis for staff inspection.

EGC has provided a regulatory commitment to satisfy the above requirement by ensuring the appropriate plant procedures and administrative controls will be revised with implementation of the amendment (i.e., Attachment 5, Commitment 2). Additionally, this requirement is documented in the proposed TS Bases (i.e., Attachment 2, Insert 2 and Attachments 6a through 6d). The inclusion of these configuration restrictions in the TS Bases will ensure that they are retained and controlled in accordance with the TS Bases Control Program as defined in Administrative Controls TS Section 5.5, "Programs and Manuals."

4.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

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Exelon Generation Company, LLC Application to Adopt TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" ATTACHMENT 2 -

TECHNICAL SPECIFICATIONS (TS) AND TS BASES INSERTS

ATTACHMENT 2 TECHNICAL SPECIFICATIONS (TS) AND TS BASES INSERTS INSERT 1 LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period, the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

INSERT 2 LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. LCO 3.0.8 applies to snubbers that only have seismic function. It does not apply to snubbers that also have design functions to mitigate steam/water hammer or other transient loads.

The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.

Page 1 of 4

ATTACHMENT 2 TECHNICAL SPECIFICATIONS (TS) AND TS BASES INSERTS INSERT 2 (continued)

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the conditions and Required Actions entered in accordance with LCO 3.0.2.

LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the snubber(s) before declaring the supported system inoperable. The 12-hour Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

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ATTACHMENT 2 TECHNICAL SPECIFICATIONS (TS) AND TS BASES INSERTS INSERT 2 (continued)

The following configuration restrictions shall be applied to the use of LCO 3.0.8:

(1) LCO 3.0.8.a can only be used if one of the following two means of heat removal is available:

a. At least one high pressure makeup path (e.g., using

[High Pressure Core Spray (HPCS) or Reactor Core Isolation Cooling (RCIC) or its equivalent]) and heat removal capability (e.g., suppression pool cooling),

including a minimum set of supporting equipment required for success, not associated with the inoperable snubber(s),

OR

b. At least one low pressure makeup path (e.g., [Low Pressure Coolant Injection (LPCI) or Low Pressure Core Spray (LPCS)]) and heat removal capability (e.g., suppression pool cooling or shutdown cooling),

including a minimum set of supporting equipment required for success, not associated with the inoperable snubber(s).

(2) LCO 3.0.8.b can only be used following verification that at least one success path exists, using equipment not associated with the inoperable snubber(s), to provide makeup and core cooling needed to mitigate Loss of Offsite Power (LOOP) accident sequences (i.e., initiated by a seismically-induced LOOP event with concurrent loss of all safety system trains supported by the out-of-service snubbers).

Each use of LCO 3.0.8 requires confirmation that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers.

In addition, a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic), implementation and compliance with the configuration restrictions defined above, and the associated plant configuration shall be available on a recoverable basis for NRC inspection.

Page 3 of 4

ATTACHMENT 2 TECHNICAL SPECIFICATIONS (TS) AND TS BASES INSERTS INSERT 2 (continued)

LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4)

(i.e., the Maintenance Rule) does not address seismic risk.

However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.

LCO 3.0.8 does not apply to non-seismic functions of snubbers.

The provisions of LCO 3.0.8 apply to seismic snubbers that may also have non-seismic functions provided the supported systems would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. Non-seismic snubber issues will be addressed in the corrective action program.

Page 4 of 4

Exelon Generation Company, LLC Application to Adopt TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" ATTACHMENT 3a -

PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UPS) FOR CLINTON POWER STATION, UNIT 1 3.0-1 3.0-3

LCO Applicability 3.0

, LCO 3.0.7, and LCO 3.0.8.

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

CLINTON 3.0-1 Amendment No. 163

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

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LCO Applicability 3.0

, LCO 3.0.7, and LCO 3.0.8 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

b. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of (continued)

Dresden 2 and 3 3.0-1 Amendment No. 212/204

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

INSERT 1 LCO 3.0.8 LCOs, including associated ACTIONS, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both 3.0.9 units, the ACTIONS will apply to both units simultaneously.

Dresden 2 and 3 3.0-3 Amendment No. 212/204

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