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Application to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2, Using the Consolidated Line Item Improvement Process
	ML14195A172
Person / Time
Site:	Dresden, Byron, Braidwood, Clinton, Quad Cities, LaSalle
Issue date:	07/14/2014
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-14-192
	Download: ML14195A172 (217)
	v • d • e

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RS-14-192 10 CFR 50.90 July 14, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50- 456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 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 Facility Operating License Nos. NPF-1 1 and NPF-1 8 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 Revise Technical Specifications to Adopt TSTF- 523, "Generic Letter 2008-01, Managing Gas Accumulation," Revision 2, Using the Consolidated Line Item Improvement Process

References:

1. TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation,"

Revision 2, dated February 20, 2013

2. Notice of Availability of "TSTF-523, 'Generic Letter 2008 -01, Managing Gas Accumulation,' Using the Consolidated Line Item Improvement Process,"

dated January 15, 2014

July 14, 2014 U.S. Nuclear Regulatory Commission Page 2

3. Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U.S. NRC, "Nine-Month Response to Generic Letter 2008-01," dated October 14, 2008 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC), requests an amendment to Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2, Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2, Facility Operating License No. NPF-62 for Clinton Power Station, Unit 1, Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 2 and 3, Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station, Units 1 and 2, and Renewed Facility Operating License Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station, Units 1 and 2.

The proposed amendment would modify Technical Specifications (TS) requirements to address Reference 1. EGC committed in Reference 3 to evaluate the resolution of the TS issues with respect to the elements contained in the TSTF, and submit a license amendment request, if deemed necessary based on the evaluation, within 180 days following NRC approval of the TSTF (Reference 2). This submittal satisfies the commitments. provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the existing TS Bases pages marked up to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specifications Bases Control Program. They are provided in for information only.

The proposed change has been reviewed by the Plant Operations Review Committees at each station and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed change by July 14, 2015. Once approved, the amendment shall be implemented within 120 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

July 14, 2014 U.S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of July 2014.

Patrick R. Simpson Manager - Licensing Attachments:

1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-Up)

3. Proposed Technical Specifications Bases Changes (Mark -Up) (For Information Only) cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station 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 change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the model safety evaluation dated December 23, 2013 (i.e., ADAMS Accession No. ML13255A169), as part of the Federal Register Notice of Availability. This review included a review of the NRC's evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, EGC has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC are applicable to Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, 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 TS of the referenced plants.

The model safety evaluation discusses the applicable regulatory requirements and guidance, including applicable 10 CFR 50, Appendix A, General Design Criteria (GDC). DNPS, Units 2 and 3, and QCNPS, Units 1 and 2, were not licensed to the 10 CFR 50, Appendix A, GDC. The plants' Updated Final Safety Analysis Reports (UFSARs), Section 3.1, "Conformance with NRC General Design Criteria," provides an assessment against the draft GDC published in 1967; while there is not a direct correlation between the current and draft GDC published in 1967, a review has determined that the plant-specific requirements are sufficiently similar to the Appendix A GDC as related to the proposed change. Therefore, the proposed change is applicable to DNPS, Units 2 and 3, and QCNPS, Units 1 and 2.

2.2 Optional Changes and Variations EGC is not proposing any significant variations or deviations from the Technical Specifications (TS) changes described in TSTF-523, Revision 2, or the applicable parts of the NRC's model safety evaluation dated December 23, 2013 (i.e., ADAMS Accession No. ML13255A169). EGC is noting the following minor variations from the TS changes described in TSTF-523, Revision 2.

Page 1

ATTACHMENT 1 Description and Assessment

TSTF-523 is based on the Standard Technical Specification (STS). Braidwood Station, Byron Station, CPS, DNPS, LSCS, and QCNPS have adopted the STS. In the cases listed below, the STS Section number corresponds to a different plant TS Section number.

o BWR/4 STS Section 3.4.8, "RHR Shutdown Cooling System - Hot Shutdown,"

corresponds to DNPS TS Section 3.4.7, "SDC System - Hot Shutdown."

o BWR/4 STS Section 3.4.9, "RHR Shutdown Cooling System - Cold Shutdown,"

corresponds to DNPS TS Section 3.4.8, "SDC System - Cold Shutdown."

o BWR/4 STS Section 3.6.2.3, "RHR Suppression Pool Cooling," corresponds to DNPS TS Section 3.6.2.3, "Suppression Pool Cooling."

o BWR/4 STS Section 3.6.2.4, "RHR Suppression Pool Spray," corresponds to DNPS TS Section 3.6.2.4, "Suppression Pool Spray."

o BWR/4 STS Section 3.9.8, "RHR - High Water Level," corresponds to DNPS TS Section 3.9.8, "SDC - High Water Level."

o BWR/4 STS Section 3.9.9, "RHR - Low Water Level," corresponds to DNPS TS Section 3.9.9, "SDC - Low Water Level."

o BWR/4 STS Section 3.4.8, "RHR Shutdown Cooling System - Hot Shutdown,"

corresponds to QCNPS TS Section 3.4.7, "RHR Shutdown Cooling System - Hot Shutdown."

o BWR/4 STS Section 3.4.9, "RHR Shutdown Cooling System - Cold Shutdown,"

corresponds to QCNPS TS Section 3.4.8, "RHR Shutdown Cooling System - Cold Shutdown."

In some cases, the SR number for new SRs being added is different than the SR number identified in TSTF-523 and in the model application. This is due to EGC's desire to add the new SRs at the end of the existing SRs to minimize the impact on station documents due to SR renumbering.

EGC has reviewed these changes and determined that they are administrative and do not affect the applicability of TSTF-523 to the Braidwood Station, Byron Station, CPS, DNPS, LSCS, or QCNPS TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Exelon Generation Company, LLC (EGC) requests adoption of TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Clinton Power Station (CPS), Unit 1, Dresden Nuclear Power Station (DNPS), Units 2 Page 2

ATTACHMENT 1 Description and Assessment and 3, LaSalle County Station (LSCS), Units 1 and 2, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, Technical Specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments 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 revises or adds Surveillance Requirements (SRs) that require verification that the Emergency Core Cooling System (ECCS), the Decay Heat Removal (DHR) / Residual Heat Removal (RHR) / Shutdown Cooling (SDC) System, the Containment Spray (CS) System, and the Reactor Core Isolation Cooling (RCIC)

System, as applicable, are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

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 revises or adds SRs that require verification that the ECCS, the DHR/RHR/SDC System, the CS System, and the RCIC System, as applicable, are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

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

Page 3

ATTACHMENT 1 Description and Assessment

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

Response: No The proposed change revises or adds SRs that require verification that the ECCS, the DHR/RHR/SDC System, the CS System, and the RCIC System, as applicable, are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed change presents no 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 change 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 change.

Page 4

ATTACHMENT 2 Proposed Technical Specifications Changes (Mark-Up)

Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECIFICATIONS PAGES Braidwood Station, Byron Station, Clinton Power Station, Units 1 and 2 Units 1 and 2 Unit 1 3.4.6-3 3.4.6-3 3.4-24 3.4.7-3 3.4.7-3 3.4-26 3.4.8-2 3.4.8-2 3.5-4 3.5.2-3 3.5.2-3 3.5-8 3.6.6-2 3.6.6-2 3.5-11 3.6.6-3 3.6.6-3 3.6-25 3.9.5-2 3.9.5-2 3.6-33 3.9.6-2 3.9.6-2 3.9-12 3.9-15 Dresden Nuclear Power Station, LaSalle County Station, Quad Cities Nuclear Power Station, Units 2 and 3 Units 1 and 2 Units 1 and 2 3.4.7-3 3.4.9-3 3.4.7-3 3.4.8-2 3.4.10-2 3.4.8-2 3.5.1-4 3.5.1-4 3.5.1-4 3.5.2-3 3.5.2-3 3.5.2-3 3.6.2.3-2 3.5.3-2 3.5.3-2 3.6.2.4-2 3.6.2.3-2 3.6.2.3-2 3.9.8-3 3.6.2.4-2 3.6.2.4-2 3.9.9-3 3.9.8-3 3.9.8-3 3.9.9-3 3.9.9-3

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&RQWURO3URJUDP SR 3.9.6.3 Verify RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program

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RCS Loops-MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.6.3 Verify correct breaker alignment and In accordance indicated power are available to each with the required pump that is not in operation. Surveillance Frequency Control Program SR 3.4.6.4 -------------------------------NOTE------------------------------ In accordance Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after with the entering MODE 4. Surveillance

Frequency Control Verify required RHR loop locations susceptible to Program gas accumulation are sufficiently filled with water.

BYRON UNITS 1 & 2 3.4.6 3 Amendment 171/171

RCS Loops-MODE 5, Loops Filled 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two required RHR loops D.1 Suspend all Immediately inoperable. operations involving a reduction of RCS OR boron concentration.

Required RHR loop AND inoperable and one or both required SG D.2.1 Initiate action to Immediately secondary side water restore one RHR loop level(s) not within to OPERABLE status.

limits.

OR D.2.2 Initiate action to Immediately restore required SG secondary side water level(s) to within limits.

In accordance with the SR 3.4.7.4 Verify required RHR loop locations susceptible to Surveillance Frequency Control gas accumulation are sufficiently filled with water. Program SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side narrow range water In accordance level is 18% in required SGs. with the Surveillance Frequency Control Program SR 3.4.7.3 Verify correct breaker alignment and In accordance indicated power are available to each with the required RHR pump that is not in operation. Surveillance Frequency Control Program BYRON UNITS 1 & 2 3.4.7 3 Amendment 171/171

RCS Loops-MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Initiate action to Immediately inoperable. restore RHR loop to OPERABLE status.

C. Two required RHR loops C.1 Suspend all Immediately inoperable. operations involving reduction in RCS boron concentration.

AND C.2 Initiate action to Immediately restore one RHR loop to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and In accordance indicated power are available to each with the required RHR pump that is not in operation. Surveillance Frequency Control Program SR 3.4.8.3 Verify RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program BYRON UNITS 1 & 2 3.4.8 2 Amendment 171/171

ECCS-Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the In accordance listed position with power to the valve with the operator removed: Surveillance Frequency Number Position Function Control Program MOV SI8806 Open Suction to SI Pumps MOV SI8835 Open SI Pump Discharge to Reactor Coolant System (RCS) Cold Legs MOV SI8813 Open SI Pump Recirculation to the Refueling Water Storage Tank MOV SI8809A Open RHR Pump Discharge to RCS Cold Legs MOV SI8809B Open RHR Pump Discharge ---------------NOTE----------------

to RCS Cold Legs Not required to be met for system vent flow paths MOV SI8840 Closed RHR Pump Discharge opened under administrative to RCS Hot Legs control.

MOV SI8802A Closed SI Pump Discharge to RCS Hot Legs MOV SI8802B Closed SI Pump Discharge to RCS Hot Legs SR 3.5.2.2 Verify each ECCS manual, power operated, In accordance and automatic valve in the flow path, that with the is not locked, sealed, or otherwise secured Surveillance in position, is in the correct position. Frequency Control Program SR 3.5.2.3 Verify ECCS piping is full of water. In accordance with the Verify ECCS locations susceptible to gas Surveillance Frequency accumulation are sufficiently filled with water.

Control Program (continued)

BYRON UNITS 1 & 2 3.5.2 3 Amendment 171/171

Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C AND not met.

D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two containment spray E.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable. --------------NOTE-----------------

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power In accordance operated, and automatic valve in the flow with the path that is not locked, sealed, or Surveillance otherwise secured in position is in the Frequency correct position. Control Program SR 3.6.6.2 Operate each containment cooling train fan In accordance unit for 15 minutes. with the Surveillance Frequency Control Program SR 3.6.6.3 Verify each containment cooling train In accordance cooling water flow rate is 2660 gpm to with the each cooler. Surveillance Frequency Control Program (continued)

BYRON UNITS 1 & 2 3.6.6 2 Amendment 171/171

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.4 Verify each containment spray pump's In accordance developed head at the flow test point is with the greater than or equal to the required Inservice developed head. Testing Program SR 3.6.6.5 Verify each automatic containment spray In accordance valve in the flow path that is not locked, with the sealed, or otherwise secured in position, Surveillance actuates to the correct position on an Frequency actual or simulated actuation signal. Control Program SR 3.6.6.6 Verify each containment spray pump starts In accordance automatically on an actual or simulated with the actuation signal. Surveillance Frequency Control Program SR 3.6.6.7 Verify each containment cooling train In accordance starts automatically on an actual or with the simulated actuation signal. Surveillance Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed. Following maintenance that could result in nozzle blockage OR Following fluid flow through the nozzles SR 3.6.6.9 Verify containment spray locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program BYRON UNITS 1 & 2 3.6.6 3 Amendment 171/171

RHR and Coolant Circulation-High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and In accordance circulating reactor coolant at a flow rate with the of 1000 gpm. Surveillance Frequency Control Program SR 3.9.5.2 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program BYRON UNITS 1 & 2 3.9.5 2 Amendment 171/171

RHR and Coolant Circulation-Low Water Level 3.9.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR loop in B.1 Suspend operations Immediately operation. involving a reduction in reactor coolant boron concentration.

AND B.2 Initiate action to Immediately restore one RHR loop to operation.

AND B.3 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and In accordance circulating reactor coolant at a flow rate with the of 1000 gpm. Surveillance Frequency Control Program SR 3.9.6.2 Verify correct breaker alignment and In accordance indicated power available to the required with the RHR pump that is not in operation. Surveillance Frequency Control Program SR 3.9.6.3 Verify RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program BYRON UNITS 1 & 2 3.9.6 2 Amendment 171/171

RHR Shutdown Cooling System Hot Shutdown 3.4.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Initiate action to restore Immediately cooling subsystem in one RHR shutdown cooling operation. subsystem or one recirculation pump to AND operation.

No recirculation pump AND in operation.

B.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from circulation by an discovery of no alternate method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.3 Monitor reactor coolant Once per hour temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------NOTE-------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control program Insert 1 CLINTON 3.4-24 Amendment No. 192

Insert 1 SR 3.4.9.2 ----------------------------NOTE----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program

RHR Shutdown Cooling System Cold Shutdown 3.4.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulating discovery of no operation. by an alternate reactor coolant method. circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.10.2 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program CLINTON 3.4-26 Amendment No. 192

ECCS Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, the piping is filled with water with the from the pump discharge valve to the Surveillance injection valve. Frequency locations susceptible to gas accumulation are Control Program sufficiently filled with water.

S SR 3.5.1.2 -------------------NOTE--------------------

Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE

1. during alignment and operation for decay heat removal with reactor steam dome pressure less than the residual heat removal cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem In accordance

2. Not required to be met manual, power operated, and automatic valve with the for system vent flow in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency paths opened under is in the correct position. Control Program administrative control.

SR 3.5.1.3 Verify ADS accumulator supply pressure is In accordance 140 psig. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each ECCS pump develops the In accordance specified flow rate with the specified pump with the differential pressure. Inservice Testing Program PUMP DIFFERENTIAL SYSTEM FLOW RATE PRESSURE LPCS 5010 gpm 290 psid LPCI 5050 gpm 113 psid HPCS 5010 gpm 363 psid (continued)

CLINTON 3.5-4 Amendment No. 192

ECCS Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS In accordance injection/spray subsystem, the suppression with the pool water level is 12 ft 8 inches. Surveillance Frequency Control Program SR 3.5.2.2 Verify, for the required High Pressure Core In accordance Spray (HPCS) System, the: with the Surveillance

a. Suppression pool water level is Frequency 12 ft 8 inches; or Control Program

b. RCIC storage tank available water volume is 125,000 gal.

SR 3.5.2.3 Verify, for each required ECCS injection/ In accordance spray subsystem, the piping is filled with with the water from the pump discharge valve to the Surveillance locations susceptible to gas injection valve. Frequency accumulation are sufficiently Control Program filled with water.

S SR 3.5.2.4 -------------------NOTE--------------------

One low pressure coolant injection (LPCI)

1. subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS injection/spray In accordance

2. Not required to be met subsystem manual, power operated, and with the for system vent flow automatic valve in the flow path, that is Surveillance not locked, sealed, or otherwise secured in Frequency paths opened under Control Program position, is in the correct position.

administrative control.

(continued)

CLINTON 3.5-8 Amendment No. 192

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled In accordance with water from the pump discharge valve to with the the injection valve. Surveillance locations susceptible to gas Frequency accumulation are sufficiently Control Program filled with water.

SR 3.5.3.2 Verify each RCIC System manual, power In accordance operated, and automatic valve in the flow with the path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program SR 3.5.3.3 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure In accordance 1045 psig and 920 psig, the RCIC pump with the can develop a flow rate 600 gpm against a Surveillance system head corresponding to reactor Frequency pressure. Control Program SR 3.5.3.4 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with RCIC steam supply pressure In accordance 150 psig and 135 psig, the RCIC pump with the can develop a flow rate 600 gpm against a Surveillance system head corresponding to reactor Frequency pressure. Control Program (continued)

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

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

CLINTON 3.5-11 Amendment No. 192

RHR Containment Spray System 3.6.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY S

SR 3.6.1.7.1 ------------------NOTE-------------------

RHR containment spray subsystems may be

1. considered OPERABLE during alignment and operation for decay heat removal when below the RHR cut in permissive pressure in MODE 3 if capable of being manually realigned and not otherwise inoperable.

Verify each RHR containment spray In accordance

2. Not required to be met subsystem manual, power operated, and with the for system vent flow automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency paths opened under in position is in the correct position. Control Program administrative control.

SR 3.6.1.7.2 Verify each RHR pump develops a flow rate In accordance of 3800 gpm on recirculation flow with the through the associated heat exchanger to Inservice the suppression pool. Testing Program SR 3.6.1.7.3 Verify each RHR containment spray In accordance subsystem automatic valve in the flow with the path actuates to its correct position on Surveillance an actual or simulated automatic Frequency initiation signal. Control Program SR 3.6.1.7.4 Verify each spray nozzle is unobstructed. Following activities that could result in nozzle blockage SR 3.6.1.7.5 Verify RHR containment spray subsystem locations susceptible In accordance with to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program CLINTON 3.6-25 Amendment No. 192

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control Program can be aligned to the correct position.

SR 3.6.2.3.2 Verify each RHR pump develops a flow rate In accordance 4550 gpm through the associated heat with the exchanger to the suppression pool. Inservice Testing Program SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program CLINTON 3.6-33 Amendment No. 192

RHR High Water Level 3.9.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulation discovery of no operation. by an alternate method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND thereafter C.2 Monitor reactor coolant temperature. Once per hour SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program SR 3.9.8.2 Verify required RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program CLINTON 3.9-12 Amendment No. 192

RHR Low Water Level 3.9.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown C.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulation discovery of no operation. by an alternate reactor coolant method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2 Monitor reactor Once per hour coolant temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program SR 3.9.9.2 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program CLINTON 3.9-15 Amendment No. 192

SDC System Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 -------------------NOTE--------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor vessel coolant temperature is less than the SDC cut-in permissive temperature.

Verify one SDC subsystem or recirculation In accordance pump is operating. with the Surveillance Frequency Control Program SR 3.4.7.2 --------------------------------------NOTE-------------------------------------- In accordance with Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor the Surveillance vessel coolant temperature is less than the SDC cut-in Frequency Control permissive temperature. Program Verify SDC subsystem locations susceptible to gas accumulation are sufficiently filled with water.

Dresden 2 and 3 3.4.7-3 Amendment No. 237/230

SDC SystemCold Shutdown 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. No required SDC B.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from subsystem in coolant circulating discovery of no operation. by an alternate reactor coolant method. circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one SDC subsystem or recirculation In accordance pump is operating. with the Surveillance Frequency Control Program SR 3.4.8.2 Verify SDC subsystem locations susceptible to gas accumulation In accordance with the are sufficiently filled with water. Surveillance Frequency Control Program Dresden 2 and 3 3.4.8-2 Amendment No. 237/230

ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, the piping is filled with water with the from the pump discharge valve to the Surveillance injection valve. Frequency Control Program locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.1.2 Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1.3 Verify correct breaker alignment to the In accordance LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the Inservice closed position. Testing Program SR 3.5.1.5 Verify the following ECCS pumps develop the In accordance specified flow rate against a test line with the pressure corresponding to the specified Inservice reactor pressure. Testing Program TEST LINE PRESSURE NO. CORRESPONDING OF TO A REACTOR SYSTEM FLOW RATE PUMPS PRESSURE OF Core Spray 4500 gpm 1 90 psig LPCI 9000 gpm 2 20 psig (continued)

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

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

Dresden 2 and 3 3.5.1-4 Amendment No. 237/230

ECCS Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required ECCS injection/ In accordance spray subsystem, the: with the Surveillance

a. Suppression pool water level is Frequency 10 ft 4 inches; or Control Program

b. -----------------NOTE-----------------

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

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

SR 3.5.2.2 Verify, for each required ECCS injection/ In accordance spray subsystem, the piping is filled with with the water from the pump discharge valve to the Surveillance locations susceptible to gas injection valve. Frequency accumulation are sufficiently Control Program filled with water.

SR 3.5.2.3 Verify each required ECCS injection/spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path, that is Surveillance not locked, sealed, or otherwise secured in Frequency position, is in the correct position. Control Program (continued)

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

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

Dresden 2 and 3 3.5.2-3 Amendment No. 237/230

Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each suppression pool cooling In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.3.2 Verify each required LPCI pump develops a In accordance flow rate 5000 gpm through the with the associated heat exchanger while operating Inservice in the suppression pool cooling mode. Testing Program SR 3.6.2.3.3 Verify suppression pool cooling subsystem locations susceptible In accordance with to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Dresden 2 and 3 3.6.2.3-2 Amendment No. 237/230

Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each suppression pool spray In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.4.2 Verify each suppression pool spray nozzle In accordance is unobstructed. with the Surveillance Frequency Control Program SR 3.6.2.4.3 Verify suppression pool spray subsystem locations susceptible In accordance with to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Dresden 2 and 3 3.6.2.4-2 Amendment No. 237/230

SDCHigh Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one SDC subsystem is operating. In accordance with the Surveillance Frequency Control Program SR 3.9.8.2 Verify required SDC subsystem locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Dresden 2 and 3 3.9.8-3 Amendment No. 237/230

SDCLow Water Level 3.9.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one SDC subsystem is operating. In accordance with the Surveillance Frequency Control Program SR 3.9.9.2 Verify SDC subsystem locations susceptible to gas accumulation In accordance with are sufficiently filled with water. the Surveillance Frequency Control Program Dresden 2 and 3 3.9.9-3 Amendment No. 237/230

RHR Shutdown Cooling SystemHot Shutdown 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 -------------------NOTE--------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor vessel pressure is less than the RHR cut-in permissive pressure.

Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program Insert 1 LaSalle 1 and 2 3.4.9-3 Amendment No. 200/187

Insert 1 SR 3.4.9.2 ----------------------------NOTE----------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut in permissive pressure.

Verify RHR shutdown cooling subsystem In accordance locations susceptible to gas accumulation are with the sufficiently filled with water. Surveillance Frequency Control Program

RHR Shutdown Cooling SystemCold Shutdown 3.4.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from cooling subsystem in coolant circulating discovery of no operation. by an alternate reactor coolant method. circulation AND AND No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify one RHR shutdown cooling subsystem In accordance or recirculation pump is operating. with the Surveillance Frequency Control Program SR 3.4.10.2 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program LaSalle 1 and 2 3.4.10-2 Amendment No. 200/187

ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, the piping is filled with water with the from the pump discharge valve to the Surveillance injection valve. Frequency locations susceptible to gas accumulation are Control Program sufficiently filled with water.

SR 3.5.1.2 Verify each ECCS injection/spray subsystem In accordance manual, power operated, and automatic valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position. Control Program SR 3.5.1.3 Verify ADS accumulator supply header In accordance pressure is 150 psig. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify ADS accumulator backup compressed In accordance gas system bottle pressure is 500 psig. with the Surveillance OR Frequency Control Program Verify ADS accumulator reserve bottle pressure is 1100 psig.

SR 3.5.1.5 Verify each ECCS pump develops the In accordance specified flow rate against the specified with the test line pressure. Inservice Testing Program TEST LINE SYSTEM FLOW RATE PRESSURE LPCS 6350 gpm 290 psig LPCI 7200 gpm 130 psig HPCS (Unit 1) 6250 gpm 370 psig HPCS (Unit 2) 6200 gpm 330 psig (continued)

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

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

LaSalle 1 and 2 3.5.1-4 Amendment No. 200/187

ECCSShutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required low pressure ECCS In accordance injection/spray subsystem, the suppression with the pool water level is -12 ft 7 in. Surveillance Frequency Control Program SR 3.5.2.2 Verify, for the required High Pressure Core In accordance Spray (HPCS) System, the suppression pool with the water level is -12 ft 7 in. Surveillance Frequency Control Program SR 3.5.2.3 Verify, for each required ECCS injection/ In accordance spray subsystem, the piping is filled with with the water from the pump discharge valve to the Surveillance locations susceptible to gas injection valve. Frequency accumulation are sufficiently Control Program filled with water.

SR 3.5.2.4 Verify each required ECCS injection/spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path, that is Surveillance not locked, sealed, or otherwise secured in Frequency position, is in the correct position. Control Program SR 3.5.2.5 Verify each required ECCS pump develops the In accordance specified flow rate against the specified with the test line pressure. Inservice Testing Program TEST LINE SYSTEM FLOW RATE PRESSURE LPCS 6350 gpm 290 psig LPCI 7200 gpm 130 psig HPCS (Unit 1) 6250 gpm 370 psig HPCS (Unit 2) 6200 gpm 330 psig (continued)

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

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

LaSalle 1 and 2 3.5.2-3 Amendment No. 200/187

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled In accordance with water from the pump discharge valve to with the the injection valve. Surveillance locations susceptible to gas Frequency accumulation are sufficiently Control Program filled with water.

SR 3.5.3.2 Verify each RCIC System manual, power In accordance operated, and automatic valve in the flow with the path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program SR 3.5.3.3 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1020 psig In accordance and 920 psig, the RCIC pump can develop a with the flow rate 600 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program SR 3.5.3.4 -------------------NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 165 psig, In accordance the RCIC pump can develop a flow rate with the 600 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program (continued)

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

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

LaSalle 1 and 2 3.5.3-2 Amendment No. 200/187

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate 7200 gpm through the with the associated heat exchanger while operating Inservice in the suppression pool cooling mode. Testing Program SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program LaSalle 1 and 2 3.6.2.3-2 Amendment No. 200/187

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.4.2 Verify each required RHR pump develops a In accordance flow rate 450 gpm through the spray with the sparger while operating in the Inservice suppression pool spray mode. Testing Program SR 3.6.2.4.3 Verify RHR suppression pool spray subsystem locations susceptible In accordance with to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program LaSalle 1 and 2 3.6.2.4-2 Amendment No. 200/187

RHRHigh Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program SR 3.9.8.2 Verify required RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program LaSalle 1 and 2 3.9.8-3 Amendment No. 200/187

RHRLow Water Level 3.9.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Verify one RHR shutdown cooling subsystem In accordance is operating. with the Surveillance Frequency Control Program SR 3.9.9.2 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program LaSalle 1 and 2 3.9.9-3 Amendment No. 200/187

RHR Shutdown Cooling SystemHot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 -------------------NOTE--------------------

Not required to be met until 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after reactor steam dome pressure is less than the RHR cut-in permissive pressure.

Verify each RHR shutdown cooling subsystem In accordance manual and power operated valve in the flow with the path, that is not locked, sealed or Surveillance otherwise secured in position, is in the Frequency correct position or can be aligned to the Control Program correct position.

SR 3.4.7.2 --------------------------------------NOTE-------------------------------------- In accordance with Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor the Surveillance steam dome pressure is less than the RHR cut in permissive Frequency Control pressure. Program Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

Quad Cities 1 and 2 3.4.7-3 Amendment No. 248/243

RHR Shutdown Cooling SystemCold Shutdown 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 ---------NOTE--------

Only applicable if both RHR shutdown cooling subsystems are inoperable.

Verify reactor 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months coolant circulating by an alternate AND method.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND A.3 ---------NOTE--------

Only applicable if both RHR shutdown cooling subsystems are inoperable.

Monitor reactor Once per hour coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify each RHR shutdown cooling subsystem In accordance manual and power operated valve in the flow with the path, that is not locked, sealed or Surveillance otherwise secured in position, is in the Frequency correct position or can be aligned to the Control Program correct position.

SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program Quad Cities 1 and 2 3.4.8-2 Amendment No. 248/243

ECCSOperating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray In accordance subsystem, the piping is filled with water with the from the pump discharge valve to the Surveillance injection valve. Frequency Control Program locations susceptible to gas accumulation are sufficiently filled with water.

S SR 3.5.1.2 -------------------NOTE--------------------

Low pressure coolant injection (LPCI)

1. subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut-in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

Verify each ECCS injection/spray subsystem In accordance

2. Not required to be met manual, power operated, and automatic valve with the for system vent flow in the flow path, that is not locked, Surveillance paths opened under sealed, or otherwise secured in position, Frequency administrative control. is in the correct position. Control Program SR 3.5.1.3 Verify correct breaker alignment to the In accordance LPCI swing bus. with the Surveillance Frequency Control Program SR 3.5.1.4 Verify each recirculation pump discharge In accordance valve cycles through one complete cycle of with the full travel or is de-energized in the Inservice closed position. Testing Program (continued)

Quad Cities 1 and 2 3.5.1-4 Amendment No. 248/2435

ECCSShutdown 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify, for each required ECCS injection/ In accordance spray subsystem, the: with the Surveillance

a. Suppression pool water level is Frequency 8.5 ft; or Control Program

b. -----------------NOTE-----------------

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

Contaminated condensate storage tank(s) water volume is 140,000 available gallons.

SR 3.5.2.2 Verify, for each required ECCS injection/ In accordance spray subsystem, the piping is filled with with the water from the pump discharge valve to the Surveillance locations susceptible to gas injection valve. Frequency accumulation are sufficiently Control Program filled with water.

S SR 3.5.2.3 --------------------NOTE-------------------

One LPCI subsystem may be considered

1. OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

Verify each required ECCS injection/spray In accordance

2. Not required to be met subsystem manual, power operated, and with the for system vent flow automatic valve in the flow path, that is Surveillance paths opened under not locked, sealed, or otherwise secured in Frequency administrative control. position, is in the correct position. Control Program (continued)

Quad Cities 1 and 2 3.5.2-3 Amendment No. 248/243

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled In accordance with water from the pump discharge valve to with the the injection valve. Surveillance locations susceptible to gas Frequency accumulation are sufficiently Control Program filled with water.

SR 3.5.3.2 Verify each RCIC System manual, power In accordance operated, and automatic valve in the flow with the path, that is not locked, sealed, or Surveillance otherwise secured in position, is in the Frequency correct position. Control Program SR 3.5.3.3 --------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1005 psig In accordance and 920 psig, the RCIC pump can develop a with the flow rate 400 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program SR 3.5.3.4 --------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 180 psig, In accordance the RCIC pump can develop a flow rate with the 400 gpm against a system head Surveillance corresponding to reactor pressure. Frequency Control Program (continued)

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

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

Quad Cities 1 and 2 3.5.3-2 Amendment No. 248/243

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate 5000 gpm through the with the associated heat exchanger while operating Inservice in the suppression pool cooling mode. Testing Program SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Quad Cities 1 and 2 3.6.2.3-2 Amendment No. 248/243

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual and power operated valve with the in the flow path that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.6.2.4.2 Verify each suppression pool spray nozzle In accordance is unobstructed. with the Surveillance Frequency Control Program SR 3.6.2.4.3 Verify RHR suppression pool spray subsystem locations susceptible In accordance with to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Quad Cities 1 and 2 3.6.2.4-2 Amendment No. 248/243

RHRHigh Water Level 3.9.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Monitor reactor coolant temperature. In accordance with the Surveillance Frequency Control Program SR 3.9.8.2 Verify each required RHR shutdown cooling In accordance subsystem manual and power operated valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.9.8.3 Verify required RHR shutdown cooling subsystem locations In accordance with susceptible to gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Quad Cities 1 and 2 3.9.8-3 Amendment No. 248/2435

RHRLow Water Level 3.9.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.9.1 Monitor reactor coolant temperature. In accordance with the Surveillance Frequency Control Program SR 3.9.9.2 Verify each required RHR shutdown cooling In accordance subsystem manual and power operated valve with the in the flow path, that is not locked, Surveillance sealed, or otherwise secured in position, Frequency is in the correct position or can be Control Program aligned to the correct position.

SR 3.9.9.3 Verify RHR shutdown cooling subsystem locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Quad Cities 1 and 2 3.9.9-3 Amendment No. 248/2435

ATTACHMENT 3 Proposed Technical Specifications Bases Changes (Mark-Up)

(For Information Only)

Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECIFICATIONS BASES PAGES Braidwood Station, Byron Station, Clinton Power Station, Units 1 and 2 Units 1 and 2 Unit 1 B 3.4.6-3 B 3.4.6-3 B 3.4-44 B 3.4.6-5 B 3.4.6-5 B 3.4-47 B 3.4.7-3 B 3.4.7-3 B 3.4-49 B 3.4.7-6 B 3.4.7-6 B 3.4-52 B 3.4.8-2 B 3.4.8-2 B 3.5-5 B 3.4.8-4 B 3.4.8-4 B 3.5-10 B 3.5.2-6 B 3.5.2-6 B 3.5-15 B 3.5.2-9 B 3.5.2-9 B 3.5-20a B 3.5.2-10 B 3.5.2-10 B 3.5-22 B 3.5.3-2 B 3.5.3-2 B 3.5-24 B 3.6.6-6 B 3.6.6-6 B 3.6-40 B 3.6.6-9 B 3.6.6-9 B 3.6-42 B 3.6.6-11 B 3.6.6-11 B 3.6-43 B 3.9.5-2 B 3.9.5-2 B 3.6-57 B 3.9.5-4 B 3.9.5-4 B 3.6-58b B 3.9.6-2 B 3.9.6-2 B 3.9-26 B 3.9.6-4 B 3.9.6-4 B 3.9-28 B 3.9-29 B 3.9-32

ATTACHMENT 3 Proposed Technical Specifications Bases Changes (Mark-Up)

(For Information Only)

REVISED TECHNICAL SPECIFICATIONS BASES PAGES (continued)

Dresden Nuclear Power Station, LaSalle County Station, Quad Cities Nuclear Power Station, Units 2 and 3 Units 1 and 2 Units 1 and 2 B 3.4.7-2 B 3.4.9-2 B 3.4.7-2 B 3.4.7-5 B 3.4.9-5 B 3.4.7-5 B 3.4.8-2 B 3.4.10-2 B 3.4.8-2 B 3.4.8-5 B 3.4.10-5 B 3.4.8-5 B 3.5.1-5 B 3.5.1-5 B 3.5.1-5 B 3.5.1-11 B 3.5.1-10 B 3.5.1-12 B 3.5.1-12 B 3.5.2-1 B 3.5.1-13 B 3.5.2-1 B 3.5.2-5 B 3.5.2-1 B 3.5.2-5 B 3.5.3-2 B 3.5.2-6 B 3.6.2.3-2 B 3.5.3-4 B 3.5.3-2 B 3.6.2.3-5 B 3.5.3-5 B 3.5.3-4 B 3.6.2.4-2 B 3.6.2.3-2 B 3.5.3-5 B 3.6.2.4-4 B 3.6.2.3-4 B 3.6.2.3-2 B 3.9.8-2 B 3.6.2.4-2 B 3.6.2.3-5 B 3.9.8-4 B 3.6.2.4-4 B 3.6.2.4-2 B 3.9.9-1 B 3.9.8-2 B 3.6.2.4-4 B 3.9.9-4 B 3.9.8-4 B 3.9.8-2 B 3.9.9-1 B 3.9.8-5 B 3.9.9-4 B 3.9.9-1 B 3.9.9-5

RCS Loops-MODE 4 B 3.4.6 BASES LCO (continued)

Note 2 requires that the secondary side water temperature of each SG be < 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature 350°F. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG which has the minimum water level specified in SR 3.4.6.2.

Similarly for the RHR System, an OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE if they are capable of being powered and are able to provide forced flow if required.

APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of either RCS or RHR provides sufficient circulation for these purposes.

However, two loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to provide adequate redundancy for decay heat removal.

Management of Operation in other MODES is covered by: gas voids is important to RHR LCO 3.4.4, "RCS Loops-MODES 1 and 2"; System LCO 3.4.5, "RCS Loops-MODE 3"; OPERABILITY.

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

BRAIDWOOD UNITS 1 & 2 B 3.4.6 3 Revision 0

RCS Loops-MODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification that the required operating RCS or RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.2 SR 3.4.6.2 requires verification of required SG OPERABILITY.

SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 18% for each required RCS loop. If the SG secondary side narrow range water level is

< 18%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

Insert 1 BRAIDWOOD UNITS 1 & 2 B 3.4.6 5 Revision 85

Insert 1 SR 3.4.6.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RCS Loops-MODE 5, Loops Filled B 3.4.7 BASES LCO (continued)

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by procedures:

a. No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop when such testing is safe and possible.

Note 3 requires that the secondary side water temperature of each SG be < 50°F above each of the RCS cold leg temperatures before the start of a Reactor Coolant Pump (RCP) with an RCS cold leg temperature 350°F. This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG via natural circulation has greater than or equal to the minimum water level specified in SR 3.4.7.2 and is otherwise capable of providing the necessary heat sink via natural circulation.

Management of gas voids is important to RHR System OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.4.7 3 Revision 0

RCS Loops-MODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.7.3 Verification that a second RHR pump is OPERABLE, when required, ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the RHR pump. If secondary side water level is 18% in at least two SGs, this surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation," August 28, 1995.

Insert 2 BRAIDWOOD UNITS 1 & 2 B 3.4.7 6 Revision 85

Insert 2 SR 3.4.7.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BASES LCO The purpose of this LCO is to require that at least two RHR loops be OPERABLE and one of these loops be in operation.

An OPERABLE loop is one that has the capability of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the RHR System unless forced flow is used. A minimum of one running RHR pump meets the LCO requirement for one loop in operation. An additional RHR loop is required to be OPERABLE to meet single failure considerations.

Note 1 permits all RHR pumps to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by procedures:

a. No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality. Boron reduction is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation;

b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction; and

c. No draining operations are permitted that would further reduce the RCS water volume.

Note 2 allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

Management of gas voids is important to RHR System OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.4.8 2 Revision 0

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BASES ACTIONS (continued)

C.1 and C.2 If no required RHR loops are OPERABLE, all operations involving a reduction of RCS boron concentration must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status. Boron dilution requires forced circulation to provide proper mixing and preserve the margin to criticality. The immediate Completion Times reflect the importance of maintaining the capability for heat removal.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification that the required operating RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.

Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

Insert 3 BRAIDWOOD UNITS 1 & 2 B 3.4.8 4 Revision 85

Insert 3 SR 3.4.8.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS-Operating B 3.5.2 BASES LCO (continued)

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term, this flow path may be switched to take its supply from the containment sump and to supply its flow to the RCS hot and cold legs.

Management of gas voids is important to ECCS OPERABILITY.

The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains.

The LCO is modified by two Notes that allow isolation of both SI pump flow paths and a portion of both RHR flow paths for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 3.4.14.1 during MODE 3. Isolation of the discharge flow paths of both SI pumps may be accomplished by closing valve SI8835. Isolation of a portion of the discharge flow paths of both RHR pumps may be accomplished by closing either valve SI8809A or SI8809B. With a portion of both RHR flow paths isolated, an alternate means of cold leg injection must be available for each isolated flow path.

An alternate means may include: 1) OPERABLE accumulators with their isolation valves either closed, but energized, or open; 2) cold leg injection via the Safety Injection pumps, and the SI8821A/B and the SI8835 valves; or 3) cold leg injection via the Centrifugal Charging pumps and the SI8801A/B valves.

APPLICABILITY In MODES 1, 2, and 3, the ECCS OPERABILITY requirements for the limiting Design Basis Accident, a large break LOCA, are based on full power operation. Although reduced power would not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The centrifugal charging pump performance is based on a small break LOCA, which establishes the pump performance curve and has less dependence on power. The SI pump performance requirements are based on a small break LOCA. MODE 2 and MODE 3 requirements are bounded by the MODE 1 analysis.

BRAIDWOOD UNITS 1 & 2 B 3.5.2 6 Revision 0

ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 REQUIREMENTS Verification of proper motor operated valve position ensures that the injection flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removal of power ensures that they cannot change position as a result of an active failure or be inadvertently misaligned. These valves are of the type, described in Reference 8, that can disable the function of both ECCS trains and invalidate the accident analyses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position (e.g., the valves listed in SR 3.5.2.1 and SR 3.5.2.7), since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will automatically reposition within the proper stroke time. This Surveillance does not require any testing or valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

BRAIDWOOD UNITS 1 & 2 B 3.5.2 9 Revision 85

ECCS-Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.2.3 With the exception of the operating centrifugal charging pump, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. The system will perform properly, injecting its full capacity into the RCS upon demand, by maintaining the piping from the ECCS pumps to the RCS full of water. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SI signal or during shutdown cooling.

As described in Reference 9, voided lines are prevented by proper vent location and filling and venting procedures.

Therefore, verification that the ECCS piping is maintained full of water is accomplished by venting certain portions of the ECCS and by performing ultrasonic examinations of other portions of the ECCS lacking vents. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The ECCS piping is maintained full of water by venting the non-operating ECCS pump casings and the discharge piping high points (applicable to idle RH and SI systems only) outside containment. This venting surveillance does not apply to subsystems in communication with operating systems because the flows in these systems are sufficient to provide confidence that water hammer which could occur from voiding would not result in unacceptable dynamic loads. During shutdown cooling operation, the exclusion would apply to the operating RH pump, in addition to the ECCS piping in communication with the operating pump.

For selected portions of piping (i.e., portions involving the idle CV pump discharge piping up to the first check valve on the pump discharge and miniflow lines, the stagnant portion of the piping upstream of the SI8801A/B adjacent to the vent valve SI045, and the piping at the 1CV207 or 2CV206 valve if the B CV pump is idle) the verification that the piping is filled with water will be performed by ultrasonic examination. This examination will provide added assurance that the piping is maintained water solid. These methods are consistent with Reference 10.

Insert 4 BRAIDWOOD UNITS 1 & 2 B 3.5.2 10 Revision 85

Insert 4 SR 3.5.2.3 ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e.,

the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

ECCS-Shutdown B 3.5.3 BASES LCO In MODE 4, one of the two independent (and redundant) ECCS trains is required to be OPERABLE to ensure that sufficient ECCS flow is available to the core following a DBA.

In MODE 4, an ECCS train consists of a centrifugal charging subsystem and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST and transferring suction to the containment sump.

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term, this flow path may be switched to take its supply from the containment sump and to deliver its flow to the RCS hot and cold legs.

The LCO is modified by a Note that allows an RHR train to be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned (remote or local) to the ECCS mode of operation and not otherwise inoperable. This allows operation in the RHR mode during MODE 4. However, due to the potential for steam binding of the RHR pump suction piping to occur when the RCS hot leg temperature is greater than 260°F and the RHR train is realigned to the RWST, one RHR train must remain aligned for the ECCS mode of operation to satisfy LCO 3.5.3 when RCS hot leg temperature is greater than 260°F.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In MODE 4 with RCS temperature below 350°F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity of the reactor and the limited core cooling requirements.

In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled,"

and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled."

MODE 6 core cooling requirements are addressed by LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

Management of gas voids is important to ECCS OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.5.3 2 Revision 76

Containment Spray and Cooling Systems B 3.6.6 BASES APPLICABLE SAFETY ANALYSES (continued)

Containment cooling train performance for post accident conditions is given in Reference 6. The result of the analysis is that each train can provide 100% of the required peak cooling capacity during the post accident condition.

The train post accident cooling capacity under varying containment ambient conditions, required to perform the accident analyses, is also shown in Reference 7.

The modeled Containment Cooling System actuation from the containment analysis is based upon a response time associated with exceeding the containment High-3 pressure setpoint to achieving full Containment Cooling System air and safety grade cooling water flow. The Containment Cooling System total response time of 65 seconds, includes signal delay, DG startup (for loss of offsite power), and service water pump startup times (Ref. 5).

The Containment Spray System and the Containment Cooling System satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO During a DBA, a minimum of one containment cooling train and one containment spray train are required to maintain the containment peak pressure and temperature below the design limits (Ref. 7). Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis. To ensure that these requirements are met, two containment spray trains and two containment cooling trains must be OPERABLE. The chemical aspects of iodine removal capability are addressed in LCO 3.6.7.

Therefore, in the event of an accident, at least one train in each system operates, assuming the worst case single active failure occurs.

Each Containment Spray System includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST upon an ESF actuation signal and manually transferring suction to the containment sump.

Management of gas voids is important to Containment Spray System OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.6.6 6 Revision 23

Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS (continued)

D.1 and D.2 If the Required Action and associated Completion Time of Condition C of this LCO are not met, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

E.1 With two containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation.

Rather, it involves verification, through a system walkdown, that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

BRAIDWOOD UNITS 1 & 2 B 3.6.6 9 Revision 85

Containment Spray and Cooling Systems B 3.6.6 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High-3 pressure signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

SR 3.6.6.7 This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through test connections. This SR ensures that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Due to the passive design of the nozzle, a test following maintenance that could result in nozzle blockage or following fluid flow through the nozzles is considered adequate to detect obstruction of the nozzles.

Insert 5 BRAIDWOOD UNITS 1 & 2 B 3.6.6 11 Revision 85

Insert 5 SR 3.6.6.9 Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water.

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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR and Coolant Circulation-High Water Level B 3.9.5 BASES LCO Only one RHR loop is required for decay heat removal in MODE 6, with the water level 23 ft above the top of the reactor vessel flange because the volume of water above the reactor vessel flange provides backup decay heat removal capability. One RHR loop is required to be in operation and OPERABLE to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE RHR loop includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

The LCO is modified by a Note that allows the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause a reduction of the RCS boron concentration. Boron concentration reduction is prohibited because uniform concentration distribution cannot be ensured without forced circulation. This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of water in the refueling cavity.

Management of gas voids is important to RHR System OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.9.5 2 Revision 0

RHR and Coolant Circulation-High Water Level B 3.9.5 BASES ACTIONS (continued)

With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Therefore, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boiling in that time.

SURVEILLANCE SR 3.9.5.1 REQUIREMENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide mixing of the borated coolant to prevent thermal and boron stratification in the core. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 5.4.7. Insert 6 BRAIDWOOD UNITS 1 & 2 B 3.9.5 4 Revision 85

Insert 6 SR 3.9.5.2 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RHR and Coolant Circulation-Low Water Level B 3.9.6 BASES LCO Both RHR loops must be OPERABLE in MODE 6, with the water level < 23 ft above the top of the reactor vessel flange.

In addition, one RHR loop must be in operation in order to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE RHR loop consists of an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

However, the LCO is modified by a Note that permits the required RHR loop to be removed from operation and considered OPERABLE when aligned to, or during transitioning to or from, the Refueling Water Storage Tank (RWST) to support filling or draining the refueling cavity, or to support required testing, if capable of being realigned to the RCS.

APPLICABILITY Two RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MODE 6, with the water level < 23 ft above the top of the reactor vessel flange, to provide decay heat removal and mixing of the borated coolant.

Requirements for the RHR System in MODES 1, 2, 3, 4, and 5 are covered by LCO 3.4.6, "RCS Loops-MODE 4," LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled," LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled," LCO 3.5.2, "ECCS-Operating," and LCO 3.5.3, "ECCS-Shutdown." RHR loop requirements in MODE 6 with the water level 23 ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level."

Management of gas voids is important to RHR System OPERABILITY.

BRAIDWOOD UNITS 1 & 2 B 3.9.6 2 Revision 0

RHR and Coolant Circulation-Low Water Level B 3.9.6 BASES ACTIONS (continued)

With no RHR loop in operation, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Therefore, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Closing containment penetrations that are open to the outside atmosphere ensures that dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boiling in that time.

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide mixing of the borated coolant to prevent thermal and boron stratification in the core. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.6.2 Verification that the required pump is OPERABLE ensures a RHR pump can be placed in operation, if needed, to maintain decay heat removal and borated coolant circulation.

Verification is performed by verifying proper breaker alignment and power available to the pump. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 5.4.7. Insert 7 BRAIDWOOD UNITS 1 & 2 B 3.9.6 4 Revision 85

Insert 7 SR 3.9.6.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. 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 criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Surveillance Frequency may vary by location susceptible to gas accumulation.

RCS Loops-MODE 4 B 3.4.6 BASES LCO (continued)

Note 2 requires that the secondary side water temperature of each SG be < 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature 350°F. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

An OPERABLE RCS loop comprises an OPERABLE RCP and an OPERABLE SG which has the minimum water level specified in SR 3.4.6.2.

Similarly for the RHR System, an OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE if they are capable of being powered and are able to provide forced flow if required.

APPLICABILITY In MODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of either RCS or RHR provides sufficient circulation for these purposes.

However, two loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to provide adequate redundancy for decay heat removal.

Management of Operation in other MODES is covered by: gas voids is important to RHR LCO 3.4.4, "RCS Loops-MODES 1 and 2"; System LCO 3.4.5, "RCS Loops-MODE 3"; OPERABILITY.

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level" (MODE 6).

BYRON UNITS 1 & 2 B 3.4.6 3 Revision 0

RCS Loops-MODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification that the required operating RCS or RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which helps ensure that forced flow is providing heat removal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.2 SR 3.4.6.2 requires verification of required SG OPERABILITY.

SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is 18% for each required RCS loop. If the SG secondary side narrow range water level is

< 18%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pump.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

Insert 1 BYRON UNITS 1 & 2 B 3.4.6 5 Revision 75