Text

License Amendment Request - Application to Adopt Technical Specification Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR/4 TS 3.6.2 .5 and TS 3.6 .3.2, Using the Consolidated Line Item Improvement Process
	ML20121A274
Person / Time
Site:	Dresden, Peach Bottom, Nine Mile Point, Limerick, Quad Cities, LaSalle
Issue date:	04/30/2020
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-20-031
	Download: ML20121A274 (67)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 657 2000 Office RS-20-031 10 CFR 50.90 April 30, 2020 U.S . Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 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:

License Amendment Request - Application to Adopt Technical Specification Task Force (TSTF) Traveler TSTF-568, Revision 2, "Revise Applicability of BWR/4 TS 3.6.2 .5 and TS 3.6 .3.2", Using the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License (FOL) Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3; Renewed FOL Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2; Renewed FOL Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2; Renewed FOL No. NPF-69 for Nine Mile Point (NMP), Unit 2; Subsequent Renewed FOL

April 30, 2020 U.S . Nuclear Regulatory Commission Page 2 Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3; and Renewed FOL Nos. DPR-29 and DPR-30 for Quad Cities Nuclear Power Station (QCNPS),

Units 1 and 2.

EGC requests adoption of TSTF-568, "Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," and TS 3.6.3.2, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content. provides a description and assessment of the proposed change.

Attachments 2a through 2f provide the existing TS pages marked to show the proposed change. Attachments 3a through 3f provide the existing TS Bases pages marked to show revised text associated with the proposed TS changes and are provided for information only. Attachments 4a through 4f provide revised (i.e., clean) TS pages for the affected stations.

EGC requests review of this amendment request under the Consolidated Line Item Improvement Process (CLllP). Approval of the proposed amendments is requested by April 30 , 2021 . Once approved , the amendments shall be implemented within 90 days.

EGC has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the Plant Operations Review Committees for the affected units in accordance with the requirements of the Exelon Quality Assurance Program.

In accordance with 10 CFR 50 .91, "Notice for public comment; State consultation ," paragraph (b), Exelon is notifying the States of Illinois, Pennsylvania, and New York of this application for license amendments by transmitting a copy of this letter and its attachments to the designated State Officials.

There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Phillip Henderson at (630) 657-4727.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30 1h day of April 2020.

Respectfully, P~R~ ---~

Patrick R. Simpson Sr. Manager - Licensing Exelon Generation Company, LLC

April 30, 2020 U.S . Nuclear Regulatory Commission Page 3 Attachments: 1. Evaluation of Proposed Changes 2a. Markup of Proposed Technical Specifications Pages - Dresden Nuclear Power Station, Units 2 and 3 2b. Markup of Proposed Technical Specifications Pages - LaSalle County Station , Units 1 and 2 2c. Markup of Proposed Technical Specifications Pages - Limerick Generating Station , Units 1 and 2 2d. Markup of Proposed Technical Specifications Pages - Nine Mile Point, Unit 2 2e. Markup of Proposed Technical Specifications Pages - Peach Bottom Atomic Power Station, Units 2 and 3 2f. Markup of Proposed Technical Specifications Pages - Quad Cities Nuclear Power Station, Units 1 and 2 3a. Markup of Proposed Technical Specifications Bases Pages and Inserts -

Dresden Nuclear Power Station, Units 2 and 3 (For Information Only) 3a.

3b. Markup of Proposed Technical Specifications Bases Pages and Inserts -

LaSalle County Station, Units 1 and 2 (For Information Only) 3c. Markup of Proposed Technical Specifications Bases Pages and Inserts -

Limerick Generating Station, Units 1 and 2 (For Information Only) 3d . Markup of Proposed Technical Specifications Bases Pages and Inserts -

Nine Mile Point, Unit 2 (For Information Only) 3e. Markup of Proposed Technical Specifications Bases Pages and Inserts -

Peach Bottom Atomic Power Station, Units 2 and 3 (For Information Only) 3f. Markup of Proposed Technical Specifications Bases Pages and Inserts -

Quad Cities Nuclear Power Station, Units 1 and 2 (For Information Only) 4a . Revised (Clean) Technical Specifications Pages - Dresden Nuclear Power Station , Units 2 and 3 4b. Revised (Clean) Technical Specifications Pages - LaSalle County Station, Units 1 and 2 4c. Revised (Clean) Techn ical Specifications Pages - Limerick Generating Station, Units 1 and 2 4d. Revised (Clean) Technical Specifications Pages - Nine Mile Point, Unit 2 4e. Revised (Clean) Technical Specifications Pages - Peach Bottom Atomic Power Station, Units 2 and 3 4f. Revised (Clean) Technical Specifications Pages - Quad Cities Nuclear Power Station, Units 1 and 2 cc: Regional Administrators - NRC Regions I and Ill w/ attachments NRC Senior Resident Inspectors - DNPS , LSCS, LGS, NMP2 ,

PBAPS, QCNPS II NRC Project Manager, NRR - DNPS, LSCS, LGS, NMP2, PBAPS, II QCNPS Illinois Emergency Management Agency - Division of Nuclear Safety II A. L. Peterson - NYSERDA II Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection II

ATTACHMENT 1 Exelon Generation Company, LLC Request to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-568, "Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2" Evaluation of Proposed Changes

Attachment 1 Evaluation of Proposed Changes Page 1of6

Subject:

License Amendment Request - to Adopt TSTF-568, Rev 2

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4.0 ENVIRONMENTAL CONSIDERATION

Attachment 1 Evaluation of Proposed Changes Page 2 of 6

1.0 DESCRIPTION

Exelon Generation Company, LLC (EGC) requests to adopt Technical Specification Task Force (TSTF) Traveler TSTF-568, "Revise the Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2," in the Technical Specifications (TS) for Dresden Nuclear Power Station (DNPS), Units 2 and 3; LaSalle County Station (LSCS), Units 1 and 2; Limerick Generating Station (LGS), Units 1 and 2; Nine Mile Point (NMP), Unit 2; Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3; and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. TSTF-568 revises the Applicability and Actions of TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," and 3.6 .3.1, "Primary Containment Oxygen Concentration," for DNPS, Units 2 and 3 and QCNPS , Units 1 and

2. The remaining units that are included in this request do not have a Technical Specification for Drywell-to-Suppression Chamber Differential Pressure; therefore, the requested changes for these units is limited to Technical Specification 3.6.3.2, "Primary Containment Oxygen Concentration," for LSCS, Units 1 and 2, NMP, Unit 2, and PBAPS, Units 2 and 3, and Technical Specification 3.6.6.3, "Drywell and Suppression Chamber Oxygen Concentration," for LGS , Units 1 and 2. The proposed changes present the associated requirements in a manner that is more consistent with the Standard Technical Specifications (STS) format and content.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation EGC has reviewed the Safety Evaluation for TSTF-568 provided to the TSTF in a letter dated December 17, 2019. This review also included a review of the NRC's evaluation, as well as the information provided in TSTF-568. EGC has concluded that the justifications presented in TSTF-568 and the safety evaluation prepared by the NRC are applicable to the stations listed in Section 1.0 above and justify the requested amendments for the incorporation of the changes to the DNPS, Units 2 and 3; LSCS ,

Units 1 and 2; LGS, Units 1 and 2; NMP, Unit 2; PBAPS, Units 2 and 3; and QCNPS, Units 1 and 2 TS.

2.2 Optional Changes and Variations In some instances, EGC operating units have different TS numbering or titles than the Standard Technical Specifications on which TSTF-568 was based . Specifically, the numbering and title differences are as follows:

1. The DNPS, Units 2 and 3 and QCNPS, Units 1 and 2 TS utilize different numbering than the Standard Technical Specifications on which TSTF-568 was based.

Specifically, Technical Specification 3.6.3.2, "Primary Containment Oxygen Concentration," corresponds to Technical Specification 3.6 .3.1 for DNPS, Units 2 and 3 and QCNPS , Units 1 and 2. Additionally, TSTF-568, Technical Specification 3.6.3.2, corresponds to Technical Specification 3.6.6.3, "Drywell and Suppression Chamber Oxygen Concentration ," for LGS, Units 1 and 2. These

Attachment 1 Evaluation of Proposed Changes Page 3 of 6 differences are administrative in nature and do not affect the applicability of TSTF-568 to the DNPS , LGS and QCNPS TS.

2. The proposed change to TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," in TSTF-568 is not applicable to LSCS, Units 1 and 2; LGS, Units 1 and 2; NMP, Unit 2; and PBAPS, Units 2 and 3, since these units do not have such a Technical Specification.

3. The LGS, Units 1 and 2 TS are based on the previous version of the NRC's STS (i.e., NUREG-0123, "Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/5)", Revision 2); therefore, the wording and format varies slightly from the NRC Improved STS (i.e., NUREG-1433, "Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4 )") shown in TSTF-568, and the applicable parts of the NRC's safety evaluation. This minor variation is administrative in nature and does not affect the applicability of TSTF-568 to the LGS TS.

The DNPS, Units 2 and 3 and QCNPS, Units 1 and 2 TS 3.6.2.5 "Drywell-to-Suppression Chamber Differential Pressure," include a note that allows for the TS to not be met for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during the performance of required surveillances. This note is being removed to be consistent with the revised applicability. This difference does not affect the applicability of the proposed change and is consistent with the STS in format and content.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Exelon Generation Company, LLC (EGC) requests to adopt Technical Specifications Task Force (TSTF) traveler TSTF-568, "Revise Applicability of BWR/4 Technical Specifications (TS) 3.6.2.5 and TS 3.6.3.2, "in the TS for Dresden Nuclear Power Station (DNPS), Units 2 and 3, LaSalle County Station (LSCS), Units 1 and 2, Limerick Generating Station (LGS), Units 1 and 2, Nine Mile Point (NMP), Unit 2, Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. TSTF-568 revises the Applicability and Actions of TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," and 3.6 .3.1, "Primary Containment Oxygen Concentration," for DNPS, Units 2 and 3 and QCNPS, Units 1 and 2. The remaining units that are included in this request do not have a Technical Specification for Drywell-to-Suppression Chamber Differential Pressure; therefore the requested changes for these units is limited to Technical Specification 3.6.3.2, "Primary Containment Oxygen Concentration," for LSCS, Units 1 and 2; NMP, Unit 2; and PBAPS, Units 2 and 3, and Technical Specification 3.6.6.3, "Drywell and Suppression Chamber Oxygen Concentration," for LGS, Units 1 and 2. The adoption of TSTF-568 as proposed would result in the presentation of the associated requirements in a manner that is more consistent with the Standard Technical Specifications (STS) in format and content.

Attachment 1 Evaluation of Proposed Changes Page 4 of 6 EGC has evaluated if 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 amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response : No.

The proposed change revises the Applicability and Actions of the TS for drywell-to-suppression chamber differential pressure, and Primary Containment oxygen concentration, and presents the requirements in a manner more consistent with the STS in format and content. Drywell-to-suppression chamber differential pressure and primary containment oxygen concentration (i.e., Drywell and Suppression Chamber Oxygen Concentration for LGS, Units 1 and 2) are not initiators to any accident previously evaluated . As a result, the probability of any accident previously evaluated is not affected by the proposed change.

Drywell-to-Suppression Chamber Differential Pressure and Primary Containment Oxygen Concentration are assumptions in the mitigation of some accidents previously evaluated. The Applicability of the TS related to oxygen concentration is changed from Mode 1 (i.e., Operational Condition 1 for LGS , Units 1 and 2) when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident. The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The consequences of an event that could affect the drywell-to-suppression chamber differential pressure and Primary Containment (i.e., Drywell and Suppression Chamber Oxygen Concentration for LGS , Units 1 and 2) oxygen concentration are no different during the proposed Completion Time than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response : No.

The proposed change revises the Applicability and Actions of the TS for Drywell-to-Suppression Chamber Differential Pressure, and Primary Containment Oxygen Concentration (i.e., Drywell and Suppression Chamber Oxygen Concentration for LGS, Units 1 and 2) and presents the requirements in a manner that is more

Attachment 1 Evaluation of Proposed Changes Page 5 of 6 consistent with the STS in format and content. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the Updated Final Safety Analysis Report (UFSAR) are created because the NRC has determined that hydrogen generation is not risk significant for design basis accidents.

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

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

Response: No.

The proposed change revises the Applicability and Actions of the TS for Drywell-to-Suppression Chamber Differential Pressure, and Primary Containment Oxygen Concentration (i.e., Drywell and Suppression Chamber Oxygen Concentration for LGS , Units 1 and 2) and presents the requirements in a manner that is more consistent with the STS in format and content. No safety limits are affected. No LCOs or Surveillance limits are affected. The Drywell-to-Suppression Chamber Differential Pressure and Primary Containment Oxygen Concentration (i.e., Drywell and Suppression Chamber Oxygen Concentration for LGS, Units 1 and 2) TS requirements assure sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such , there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.

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

Based upon 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.

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

Attachment 1 Evaluation of Proposed Changes Page 6 of 6

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change does not 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 do not change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents 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 .

ATTACHMENT 2a DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS . 50-237 AND 50-249 RENEWED FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Dresden Proposed Technical Specifications Changes MARKED-UP TS PAGES 3.6.2.5-1 3.6.3.1-1

Drywell-to-Suppression Chamber Differential Pressure 3.6.2.5 3.6 CONTAINMENT SYSTEMS 3.6.2.5 Drywell-to-Suppression Chamber Differential Pressure LCO 3.6.2.5 The drywell pressure shall be maintained~ 1.0 psid above the pressure of the suppression chamber.

~et required to be met for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during performance of required Surveillances.

APPLICABILITY: MODE 1 with THERMAL POWER> 15% RTP. during the time period:

a. F"rom 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after rnERMi\L P0 1...1ER is ) 15?& RTP foll 0 .Ji ng 1 startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERM/\L POWER to c 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywel 1-to-suppressi on A.1 --------NOTE--------

chamber differential LCD 3.0.4.c is pressure not within applicable limit. --- - - - - - - - - - - - - - - - - -

Restore differential 72-24 hours pressure to within limit.

B. Required Action and 8.1 Reduce THERMAL POWER 12.g hours associated Completion to ~ 15% RTP.

Time not met.

Dresden 2 and 3 3.6.2.5-1 Amendment No. 185/180

Primary Containment Oxygen Concentration 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Oxygen Concentration LCO 3.6.3.1 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY: MODE S 1 and 2. during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is> 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to c 15% RTP prior to the next scheduled reactor shutdo .m. 1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 --------NOTE--------

oxygen concentration LCO 3.0.4.c is not within limit. applicable Restore oxygen 72-24 hours concentration to within limit.

B. Required Action and B.1 Be in MODE 3Reduce 12S hours associated Completion TM ERM!', L P0 1t.1ER to Time not met. .:::; 15?& RTP .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1.1 Verify primary containment oxygen In accordance concentration is within limits. with the Survei 11 ance Frequency Control Program Dresden 2 and 3 3.6.3.1-1 Amendment No. 237/230

ATTACHMENT 2b LASALLE COUNTY STATION, UNITS 1AND2 DOCKET NOS . 50-373 AND 50-374 RENEWED FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 LaSalle Proposed Technical Specifications Changes MARKED-UP TS PAGES 3.6.3.2-1

Primary Containment Oxygen Concentration 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY: MODE S 1 and 2. during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is> 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdo .m. 1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 --------NOTE--------

oxygen concentration LCO 3.0.4.c is not within limit. applicable Restore oxygen 72-24 hours concentration to within limit.

B. Required Action and B.l Be in MODE 3Reduce 12g. hours associated Completion TM ERM!', L P0 11.'E R to Time not met. < l 5?b RTP .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify primary containment oxygen In accordance concentration is within limits. with the Survei 11 ance Frequency Control Program LaSalle 1 and 2 3.6.3.2-1 Amendment No. 200/187

ATTACHMENT 2c LIMERICK GENERATING STATION, UNITS 1AND2 DOCKET NOS . 50-352 AND 50-353 RENEWED FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Limerick Proposed Technical Specifications Changes MARKED-UP TS PAGES 3/4 6-59 (Unit 1) 3/4 6-59 (Unit 2)

CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER OXYGEN CONCENTRATION LIMITING CONDITION FOR OPERATION 3.6.6.3 The drywell and suppression chamber atmosphere oxygen concentration shall be less than 4% by volume.

APPLICABILITY: OPERATIONAL CONDITIONS 1* and 2., during the time period:

a. Within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s** after THERMAL POWER is greater than 15% of RATED THERMAL POWER, following startup, to

b. Within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s** prior to reducing THERMAL POWER to less than 15% of RATED THERMAL POWER, preliminary to a scheduled reactor shutdown.

ACTION:

With the drywell and/or suppression chamber oxygen concentration exceeding the limit, restore the oxygen concentration to within the limit within --72 hours or be in at least STARTUP HOT SHUTDOWN within the next &-12 hours. The provision of Specification 3.0.4.c is applicable.

SURVEILLANCE REQUIREMENTS 4.6.6.3 The drywell and suppression chamber oxygen concentration shall be verified to be within the limit 11ithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is greater than 15% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter .

See Special Test Exception 3.10.5.

- Specification 3.6.1.8 is applicable during this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

LIMERICK - UNIT 1 3/4 6-59 Amendment No. -+/-.ge

CONTAINMENT SYSTEMS DRYWELL AND SUPPRESSION CHAMBER OXYGEN CONCENTRATION LIMITING CONDITION FOR OPERATION 3.6.6.3 The drywell and suppression chamber atmosphere oxygen concentration shall be less than 4% by volume.

APPLICABILITY: OPERATIONAL CONDITIONS l* and 2., during the time period:

a. Within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s** after THERMAL POWER is greater than 15% of RATED THERMAL POWER, following startup, to

b. Within 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s** prior to reducing THERMAL POWER to less than 15% of RATED THERMAL POWER, preliminary to a scheduled reactor shutdo\1n.

ACTION:

With the drywell and/or suppression chamber oxygen concentration exceeding the limit, restore the oxygen concentration to within the limit within -72 hours or be in at least STARTUP HOT SHUTDOWN within the next .g.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The provision of Specification 3.0.4.c is applicable.

SURVEILLANCE REQUIREMENTS 4.6.6.3 The drywell and suppression chamber oxygen concentration shall be verified to be within the limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is greater than 15% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter .

See Special Test Exception 3.10.5.

- Specification 3.6.1.8 is applicable during this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

LIMERICK - UNIT 2 3/4 6-59 Amendment No. -+/-4+

ATTACHMENT 2d NINE MILE POINT, UNIT2 DOCKET NO. 50-410 RENEWED FACILITY OPERATING LICENSE NO. NPF-69 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Nine Mile Point Proposed Technical Specifications Changes MARKED-UP TS PAGES 3.6.3.2-1

Primary Containment Oxygen Concentration 3.6 .3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6 .3.2 The primary containment oxygen concentration shall be

< 4.0 volume percent.

APPLICABILITY: MODES 1 and 2. 1 during the time period :

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POVVER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 ------------N 0 TE------------

oxygen concentration LCO 3.0.4.c is not within limit. applicable Restore oxygen 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months concentration to within limit.

B. Required Action and B.1 Be in MODE 3. Reduce 12f> hours associated Completion THERMAL POVVER to Time not met. < 15% RTP .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2 .1 Verify primary containment oxygen In accordance with concentration is within limits. the Surveillance Frequency Control Program NMP2 3.6 .3.2-1 Amendment 91, 152

ATTACHMENT 2e PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Peach Bottom Proposed Technical Specifications Changes MARKED-UP TS PAGES X.Y-Z

Pr i mary Conta i nment Oxygen Concentrat i on 3.6 . 3.2 3.6 CON TAI NM ENT SYS TE MS 3.6.3.2 Pr i mary Containment Oxygen Concentration LCO 3. 6.3 . 2 Th e pr i mary con t ai nment oxygen concentrat i on s hall be

< 4.0 volume percent.

APPLI CAB ILIT Y: MO DES 1 and 2.during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is> 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior to a reactor shutdown.

AC TI ONS COND ITIO N REQUI RED AC TI ON COM PLETIO N TI ME A. Pr i mary conta i nment A. 1 --------NOTE---------

oxygen concentrat i on LCO 3.0.4.c is not wi t hi n l i mi t. applicable.

Restore oxyge n 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months co nce ntrat i on to with in limit.

B. Requ i red Act i on and B. 1 Be in MODE 3. Reduce lzg hours assoc i ated Comple ti on THERMAL POWER to Time not met. .::; l 5?b RTP.

SURV EILLANC E REQUI REMENTS SURV EILLANC E FREQUE NCY SR 3. 6.3 . 2. 1 Ver ify pr i mary conta i nment oxygen I n accordance concentrat i on i s wi t hi n l i mi ts. wi t h t he Surve i llance Frequency Control Program.

PBA PS UNIT 2 3.6-33 Amendmen t No. f..g

Pr i mary Conta i nment Oxygen Concentrat i on 3.6 . 3.2 3.6 CON TAI NM ENT SYS TE MS 3.6.3.2 Pr i mary Containment Oxygen Concentration LCO 3. 6.3 . 2 Th e pr i mary con t ai nment oxygen concentrat i on s hall be

< 4.0 volume percent.

APPLI CAB ILIT Y: MO DES 1 and 2.during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is> 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to < 15% RTP prior to a reactor shutdown.

AC TI ONS COND ITIO N REQUI RED AC TI ON COM PLETIO N TI ME A. Pr i mary conta i nment A. 1 --------NOTE---------

oxygen concentrat i on LCO 3.0.4.c is not wi t hi n l i mi t. applicable.

Restore oxyge n 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months co nce ntrat i on to with in limit.

B. Requ i red Act i on and B. 1 Be in MODE 3. Reduce lzg hours assoc i ated Comple ti on THERMAL POWER to Time not met. .::; l 5?b RTP.

SURV EILLANC E REQUI REMENTS SURV EILLANC E FREQUE NCY SR 3. 6.3 . 2. 1 Ver ify pr i mary conta i nment oxygen I n accordance concentrat i on i s wi t hi n l i mi ts. wi t h t he Surve i llance Frequency Control Program.

PBA PS UNIT 3 3.6-33 Amendmen t No. &+/--

ATTACHMENT 2f QUAD CITIES NUCLEAR STATION, UNITS 1AND2 DOCKET NOS. 50-254 AND 50-265 RENEWED FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Quad Cities Proposed Technical Specifications Changes MARKED-UP TS PAGES 3.6.2 .5-1 3.6.3.1-1

Drywe ll - t o-Suppress i on Chamber Diff eren ti al Pressure 3.6.2. 5 3.6 CON TAI NM ENT SYS TE MS 3.6.2. 5 Drywe ll - t o-Suppress i on Chamber Di fferen ti al Pressure LCO 3.6.2. 5 The drywe ll pressure sha ll be ma i n t a i ned~ 1 .0 ps i d above t he pressure of t he suppress i on chamber .

~ot required to be met for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during performance of required Surveillances.

APPLI CAB ILIT Y: MO DE 1 with THERMAL POWER> 15% RTP.during the time period:

a. F"rom 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after rnERMi\L PQl;,'ER is > 15?b RTP foll 0 .Ji ng 1

startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERM/\L POWER to < 15% RTP prior to the next scheduled reactor shutdown.

AC TI ONS CON DITIO N REQUIRED AC TI ON COM PLETIO N TI ME A. Drywe l 1- t o-suppress i on A.1 --------NOTE--------

chamber di fferen ti al LCD 3.0.4.c is pressure no t withi n applicable li mit. - - - - - - - - - - - - - - - - - - - -

Res t ore di ff ere nt ial 72-24 hours pressure t o withi n l i mit .

B. Requ i red Ac ti on and 8.1 Reduce THERMA L POW ER 12.g. hours assoc i at ed Comp l et i on t o :::; 15% RTP.

Ti me no t me t.

Quad Citi es 1 and 2 3.6.2.5 -1 Amendmen t No . 199/195

Pr i mary Con t ai nmen t Oxygen Concen t ra ti on 3 . 6 . 3 .1 3 . 6 CON TAI NM ENT SYS TE MS

3. 6. 3. 1 Pr i mary Con t ai nmen t Oxygen Concentra ti on LCO 3 . 6 . 3 .1 The pr i mary con t ai nmen t oxygen concen t rat i on shall be

< 4 . 0 vo l ume percent .

APP LI CAB ILIT Y: MOD ES 1 and 2. during the time period:

a. F"rorn 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after Tl=IE"RMAL POWE"R is > 15?b RTP foll o*,.*i ng startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing Tl=IE"RMAL POWE"R to < 15% RTP pr i or to the next sch e du l ed reactor shut do '>m

AC TI ONS COND IT ION REQUIR ED AC TI ON COM PLETIO N TI ME A. Pr i mary con t ai nment A. 1 --------NOTE--------

oxygen concentration LCO 3.0.4.c is no t wit hi n li mi t . applicable Restore oxygen 72-2-4 hours concen t rat i on t o wit hi n li mit.

B. Requ i red Act i on and B. 1 Be in MODE 3Reduce 12g. hours associated Comp l eti on Tl=I t RM/l, L PQI:,' t R to Time not met . < l 5?b RTP .

SURV EILL ANC E REQUI REMENTS SURV EILL ANC E FREQU ENCY SR 3.6.3. 1.1 Ver i fy pr i mary con t ai nmen t oxygen I n accordance concen t rat i on i s wi t hi n li mi ts . wi th t he Surve i 11 ance Frequency Con t rol Program Quad Citi es 1 and 2 3.6.3. 1-1 Amendmen t No . 248/243

ATTACHMENT 3a DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS . 50-237 AND 50-249 RENEWED FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Dresden Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.6.2.5-2 B 3.6 .2.5-3 B 3.6.3.1-2 B 3.6 .3.1-3

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.5 BASES LCO drywell-to-suppression chamber differential pressure of (continued) < 1.0 psid corresponds to a downcomer water leg of

> 1.68 ft. Failure to maintain the required differential pressure could result in excessive forces on the suppression chamber due to higher water clearing loads from downcomer vents and higher pressure buildup in the drywell.

A Note is provided to allow for periods of up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months o1hen the LCO is not required to be met during the 1

performance of required Surveillances that reduce the differential pressure. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time is acceptable since the probability of a DBA LOCA occurring during this time is

+B-w.-

APPLICABILITY Drywell-to-suppression chamber differential pressure must be controlled when the primary containment is inert. The primary containment must be inert in MODE 1 with THERMAL POWER > 15% RTP , since this is the condition with the highest probability for an event that could produce hydrogen. It is also the condition 11ith the highest probability of an event that could impose large loads on the primary containment.

Inerting primary containment is an operational problem because it prevents primary containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the unit startup and is de inerted as soon as possible in the unit shutdo .m. As long as reactor po o1er is < 15?& RTP, the 1 1 probability of an event that generates hydrogen or excessive loads on primary containment occurring o1ithin the 1

first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following a startup or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a shutdo .m is l 0 .1 enough that these 1 1

t. indows, 11 1 1 1

' with the primary containment not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting.

ACTIONS If drywell-to-suppression chamber differential pressure is not within the limit, the conditions assumed in the safety analyses are not met and the differential pressure must be restored to within the limit within 72-&4 hours. The 72-&4 hour Completion Time provides sufficient time to restore (continued)

Dresden 2 and 3 B 3.6.2.5-2 Revision w

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.5 BASES ACTIONS A......l (continued) differential pressure to .Jithin limit and takes into 1

account the low probability of an event that would create excessive suppression chamber loads occurring during this time period.

A Note permits the use of the prov1s1ons of LCO 3.0.4.c.

This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Mode 1 with THERMAL POWER> 15% RTP, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If the differential pressure cannot be restored to within limits within the associated Completion Time, the plant must be placed in a MODE in which the LCO does not apply.

This is done by reducing power to~ 15% RTP within 12S hours. The 12S hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.5.1 REQUIREMENTS The drywell-to-suppression chamber differential pressure is regularly monitored to ensure that the required limits are satisfied. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

Dresden 2 and 3 B 3.6.2.5-3 Revision 9-

Primary Containment Oxygen Concentration B 3.6.3.1 BASES APPLICABLE combustible gas mixtures in the primary containment.

SAFETY ANALYSES Oxygen, which is subsequently generated by radiolytic (continued) decomposition of water, will not result in the primary containment becoming de-inerted within the first 30 days following an accident.

Primary containment oxygen concentration satisfies 10 CFR 50.36(c)(2)(ii).

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allo .Jed by the relaxations during startup and 1

shutdown addressed below . The primary containment must be inert in MODES 1 and 2 , since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.

Inerting the primary containment is an operational problem because it prevents containment access .Ji thout an 1

appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de inerted as soon as possible in the plant shutdo .m. /\s long as reactor po .Jer is < 15?& RTP, the 1 1 potential for an event that generates significant hydrogen and oxygen is l 0 .J and the primary containment need not be 1

inert. Furthermore, the probability of an event that generates hydrogen occurring .Ji thin the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a 1

startup, or .Jithin the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdo .m, is 1 1 low enough that these windO't*.'S, when the primary 11 11 containment is not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting.

ACTIONS If oxygen concentration is ~ 4.0 v/o at any time while operating in MODE 1 or 2 , with the exception of the relaxations allo .Jed during startup and shutdo .m, oxygen 1 1 concentration (continued)

Dresden 2 and 3 B 3.6.3.1-2 Revision .Q.

Primary Containment Oxygen Concentration B 3.6.3.1 BASES ACTIONS A......l (continued) must be restored to < 4.0 v/o within 72~ hours. The 72~ hour Completion Time is allowed when oxygen concentration is~ 4.0 v/o because of the availability of other hydrogen and oxygen mitigating systems (e.g., post-accident nitrogen purge) and the low probability and long duration of an event that would generate significant amounts of hydrogen and oxygen occurring during this period.

A Note permits the use of the provisions of LCO 3.0.4.c.

This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Modes 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To a chi eve this status, po .Jer the plant must be reduced to 1

< 15% RTPplaced in MODE 3 within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.1.1 REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is< 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. Generic Letter 84-09, May 1984.

2. UFSAR, Section 6.2.5.

Dresden 2 and 3 B 3.6.3.1-3 Revision 9-

ATTACHMENT 3b LASALLE COUNTY STATION, UNITS 1AND2 DOCKET NOS . 50-373 AND 50-374 RENEWED FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 LaSalle Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.6.3.2-1 B 3.6 .3.2-2 B 3.6.3.2-3

Primary Containment Oxygen Concentration B 3.6.3.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 Primary Containment Oxygen Concentration BASES BACKGROUND The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inerted, that is, oxygen concentration< 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. An event that rapidly generates hydrogen from zirconium metal water reaction will result in excessive hydrogen in primary containment, but oxygen concentration will remain< 4.0 v/o and no combustion can occur. This LCO ensures that oxygen concentration does not exceed 4.0 v/o during operation in the applicable conditions.

APPLICABLE The Reference 1 calculations assume that the primary SAFETY ANALYSES containment is inerted when a Design Basis Accident loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.

Primary containment oxygen concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii ).

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdo .m addressed bel 0 .J . The primary containment must be 1 1 inert in MODE S 1 and 2 , since this is the condition with the highest probability of an event that could produce hydrogen.

(continued)

LaSalle 1 and 2 B 3.6.3.2-1 Revision -+/-

Primary Containment Oxygen Concentration B 3.6.3.2 BASES (continued)

/\PPLIC/'dn LIT¥ (continued) Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de inerted as soon as possible in the plant shutdo .m. /\s long as reactor po o1er is < 15?6 RTP, the 1 1 potential for an event that generates significant hydrogen is 10 .J and the primary containment need not be inert.

1 Furthermore, the probability of an event that generates hydrogen occurring .Ji thin the first 2~ hours of a start up, 1

or .Ji thin the last 2~ hours before a shutdo .m, is l 0 .J 1 1 1 enough that these 'indows, when the primary containment 111 1

is not inerted, are also justified. The 2~ hour time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting.

ACTIONS If oxygen concentration is ~ 4.0 v/o at any time while operating in MODE 1 or 2 , .Ji th the exception of the 1

relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 72-24 hours. The 72-24 hour Completion Time is allowed when oxygen concentration is~ 4.0 v/o because the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

A Note permits the use of the provisions of LCO 3.0.4.c.

This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability. Similarly, intentional entry into Required Action A.1 during startup conditions is acceptable per Technical Specification 3.0.4.c.

(continued)

LaSalle 1 and 2 B 3.6.3.2-2 Revision -+/-

Primary Containment Oxygen Concentration B 3.6.3.2 BASES ACTIONS (continued)

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, power the plant must be reduced to

< 15% RTPplaced in MODE 3 within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.2.l REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is< 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 6.2.5.

LaSalle 1 and 2 B 3.6.3.2-3 Revision M

ATTACHMENT 3c LIMERICK GENERATING STATION, UNITS 1AND2 DOCKET NOS . 50-352 AND 50-353 RENEWED FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Limerick Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3/4 6-7 (Unit 1)

B 3/4 6-7 (Unit 2)

CONTAINMENT SYSTEMS 314.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL (Continued)

If oxygen concentration is~ 4.0 via while operating in OPERATIONAL CONDITION 1 or 2, oxygen concentration must be restored to< 4.0 via within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is allowed when oxygen concentration is~ 4.0 via because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

The provision of Specification 3.0.4.c is applicable. This allowance permits entry into the applicable OPERATIONAL CONDITION(S) while relying on the Actions. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering OPERATIONAL CONDITIONS 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter the Action prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within the limit within the required Completion Time, the plant must be brought to an OPERATIONAL CONDITION in which the LCD does not apply. To achieve this status, the plant must be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

LIMERICK - UNIT 1 B 314 6-7 Amendment No.

CONTAINMENT SYSTEMS BA E 3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL The primary containment atmospheric mixing system is provided to ensure adequate mixing of the containment atmosphere to prevent localized accumulations of hydrogen and oxygen from exceeding the lower flammability limit during post-LOCA conditions.

All nuclear reactors must be designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration <4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. The capability to inert the primary containment and maintain oxygen <4.0 v/o works together with Drywell Hydrogen Mixing System to provide redundant and diverse methods to mitigate events that produce hydrogen.

If oxygen concentration is~ 4.0 vlo while operating in OPERATIONAL CONDITION 1 or 2, oxygen concentration must be restored to< 4.0 vlo within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is allowed when oxygen concentration is~ 4.0 vlo because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

The provision of Specification 3.0.4.c is applicable. This allowance permits entry into the applicable OPERATIONAL CONDITION(S) while relying on the Actions. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering OPERATIONAL CONDITIONS 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter the Action prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within the limit within the required Completion Time, the plant must be brought to an OPERATIONAL CONDITION in which the LCD does not apply. To achieve this status, the plant must be placed in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

LIMERICK - UNIT 2 8 3/4 6-7 Amendment No.

ECR 00 00132, ~

ATTACHMENT 3d NINE MILE POINT, UNIT2 DOCKET NO. 50-410 RENEWED FACILITY OPERATING LICENSE NO. NPF-69 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Nine Mile Point Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.6.3.2-2 B 3.6 .3.2-3

Primary Containment Oxygen Concentration B 3.6.3.2 BASES (continued)

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODES 1 and 2, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.

lnerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de inerted as soon as possible in the plant shutdown . As long as reactor power is< 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting.

ACTIONS A.1 If oxygen concentration is z 4.0 v/o at any time while operating in MODE 1 or 2, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 72~ hours. The 72~ hour Completion Time is allowed when oxygen concentration is z 4.0 v/o because of the low probability and long duration of an event that would generate significant amounts of hydrogen and oxygen occurring during this period.

(continued)

NMP2 B 3.6 .3.2-2 Revision 0, 25 (A124)

Primary Containment Oxygen Concentration B 3.6.3.2 BASES ACTIONS A.1 (continued)

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Modes 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A. 1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plantf3GWef must be placed inreduced to MODE 3< 15% RTP within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS The primary containment must be determined to be inerted by verifying that oxygen concentration is < 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program .

REFERENCES 1. USAR, Section 6.2.5.

2. 10 CFR 50.36(c)(2)(ii).

NMP2 B 3.6 .3.2-3 Revision 0, 44 (A152)

ATTACHMENT 3e PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NOS. DPR-44 AND DPR-56 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Peach Bottom Proposed Technical Specifications Bases Changes (for information only}

MARKED-UP TS BASES PAGES X.Y-Z

Primary Containment Oxygen Concentration 8 3.6.3.2 BASES (continued)

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, .

The primary containment must be inert in MODES 1 and 2 , since this is the condition with the highest probability of an event that could produce hydrogen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de inerted as soon as possible in the plant shutdown. As long as reactor power is< 15% RTP, the potential for an event that generates significant hydrogen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting .

ACTIONS If oxygen concentration is ~ 4.0 v/o at any time while operating in MODE 1 or 2 , with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months . The 7224 hour0.0836 days 2.007 hours 0.0119 weeks 0.00275 months Completion Time is allowed when oxygen concentration is~ 4.0 v/o because of the availability of other hydrogen mitigating systems (e.g., the CAD System) and the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

continued PBAPS UN IT 2 8 3.6-71 Revision No . .Q.

Primary Containment Oxygen Concentration B 3.6.3.2 BASES ACTIONS A.l (continued)

A Note permits the use of the prov1s1ons of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.l prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plantfJ-8-W-e-f- must be placed inreduced to MODE 3

< 15% RTP within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS The primary containment (drywell and suppression chamber) must be determined to be inert by verifying that oxygen concentration is< 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 5.2.3.9.5.

PBAPS UN IT 2 B 3.6-72 Revision No. oo

Primary Containment Oxygen Concentration 8 3.6.3.2 BASES (continued)

LCO The primary containment oxygen concentration is maintained

< 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below . The primary containment must be inert in MODES 1 and 2 , since this is the condition with the highest probability of an event that could produce hydrogen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de inerted as soon as possible in the plant shutdown. As long as reactor power is< 15% RTP, the potential for an event that generates significant hydrogen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting .

ACTIONS If oxygen concentration is ~ 4.0 v/o at any time while operating in MODE 1 or 2 , with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months . The 7224 hour0.0836 days 2.007 hours 0.0119 weeks 0.00275 months Completion Time is allowed when oxygen concentration is~ 4.0 v/o because of the availability of other hydrogen mitigating systems (e.g., the CAD System) and the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

(continued)

PBAPS UN IT 3 8 3.6-71 Revision No . .Q.

Primary Containment Oxygen Concentration 8 3.6.3.2 BASES ACTIONS A.1 (continued)

A Note permits the use of the prov1s1ons of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.l prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plantfJ-8-W-e-f- must be placed inreduced to MODE 3

< 15% RTP within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.2.1 REQUIREMENTS The primary containment (drywell and suppression chamber) must be determined to be inert by verifying that oxygen concentration is< 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. UFSAR, Section 5.2.3.9.5.

PBAPS UN IT 3 8 3.6-72 Revision No . .g.+

ATTACHMENT 3f QUAD CITIES NUCLEAR STATION, UNITS 1AND2 DOCKET NOS. 50-254 AND 50-265 RENEWED FACILITY OPERATING LICENSE NOS. DPR-29 AND DPR-30 REQUEST FOR TECHNICAL SPECIFICATION CHANGE RELATED TO THE ADOPTION OF TSTF-568 Quad Cities Proposed Technical Specifications Bases Changes (for information only)

MARKED-UP TS BASES PAGES B 3.6 .2.5-2 B 3.6 .2.5-3 B 3.6 .3.1-2 B 3.6 .3.1-3

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.5 BASES LCO drywell-to-suppression chamber differential pressure of (continued) < 1.0 psid corresponds to a downcomer water leg of approximately 1 ft. Failure to maintain the required differential pressure could result in excessive forces on the suppression chamber due to higher water clearing loads from downcomer vents and higher pressure buildup in the d rywe 11 .

A Note is provided to allow for periods of up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when the LCO is not required to be met during the performance of required Surveillances that reduce the differential pressure. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time is acceptable since the probability of a DBA LOCA occurring during this time is

+B-w.-

APPLICABILITY Drywell-to-suppression chamber differential pressure must be controlled when the primary containment is inert. The primary containment must be inert in MODE 1 with THERMAL POWER> 15% RTP , since this is the condition with the highest probability for an event that could produce hydrogen. It is also the condition with the highest probability of an event that could impose large loads on the primary containment.

Inerting primary containment is an operational problem because it prevents primary containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the unit startup and is de inerted as soon as possible in the unit shutdo .m. As long as reactor po o1er is E 15?b RTP, the 1 1 probability of an event that generates hydrogen or excessive loads on primary containment occurring .Jithin the 1

first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following a startup or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a shutdo .m is l 0 .J enough that these 1 1

t. indows, 111 1 1

' with the primary containment not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de inerting.

ACTIONS If drywell-to-suppression chamber differential pressure is not within the limit, the conditions assumed in the safety analyses are not met and the differential pressure must be restored to within the limit within 72~ hours. The 72~ hour Completion Time provides sufficient time to restore (continued)

Quad Cities 1 and 2 B 3.6.2.5-2 Revision .Q.

Drywell-to-Suppression Chamber Differential Pressure B 3.6.2.5 BASES ACTIONS A......l (continued) differential pressure to .Jithin limit and takes into 1

account the low probability of an event that would create excessive suppression chamber loads occurring during this time period.

A Note permits the use of the provisions of LCD 3.0.4.c.

This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS. This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Mode 1 with THERMAL POWER> 15% RTP, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

If the differential pressure cannot be restored to within limits within the associated Completion Time, the plant must be placed in a MODE in which the LCO does not apply.

This is done by reducing power to~ 15% RTP within 12g hours. The 12g hour Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.2.5.l REQUIREMENTS The drywell-to-suppression chamber differential pressure is regularly monitored to ensure that the required limits are satisfied. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES None.

Quad Cities 1 and 2 B 3.6.2.5-3 Revision 4-J