Text

Units 1 and 2 - 10 CFR 50.59 Summary Report and Commitment Change Summary Report
	ML14042A335
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/11/2014
From:	Pyle S; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	0CAN021403
	Download: ML14042A335 (94)
	v • d • e

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One 0CAN021403 February 11, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

10 CFR 50.59 Summary Report and Commitment Change Summary Report Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

Dear Sir or Madam:

In accordance with 10 CFR 50.59(d)(2), enclosed is the Arkansas Nuclear One, Unit 1 (ANO-1) 10 CFR 50.59 summary report for the time period ending February 11, 2014. This report contains a brief description of changes in procedures, the facility as described in the ANO-1 Safety Analysis Report (SAR), changes in the ANO-1 Technical Requirements Manual, and changes in the ANO-1 Technical Specification Bases, where a 10 CFR 50.59 evaluation was conducted. The report also contains a description of tests and experiments conducted, if any, which were not described in the SAR, and other changes to the SAR for which a 10 CFR 50.59 evaluation was conducted. A copy of each 10 CFR 50.59 evaluation, both ANO-1 specific and those evaluations common between ANO-1 and ANO, Unit 2 (ANO-2), as applicable, is included in Attachment 1.

Included in Attachment 2 is the Commitment Change Summary Report for ANO-1 and ANO-2.

These changes are submitted in accordance with the guidance provided in NEI 99-04, Guidelines for Managing NRC Commitment Changes. The report lists each commitment changed since submittal of the previous report and provides a basis for each change.

If you have any questions or require additional information, please contact me.

Sincerely, Original Signed by Stephenie L. Pyle SLP/mkh Attachments:

1. 10 CFR 50.59 Summary Report

2. ANO-1 and ANO-2 Commitment Change Summary Report

0CAN021403 Page 2 of 2 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Michael Orenak MS O-8G9A One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Attn: Mr. Alan Wang MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 to 0CAN021403 10 CFR 50.59 Summary Report to 0CAN021403 Page 1 of 58 ANO 10 CFR 50.59 Summary Report 50.59 # 50.59 Summary 13-001 Engineering Change EC-41466, "Modification of Electrical Equipment Room Exhaust Fans"13-002 Engineering Change EC-43686, "Install Temporary Offsite Power to Engineered Safeguards Bus A3 and/or A4"13-002 Engineering Change EC-43686, "Install Temporary Offsite Power to Engineered Rev. 1 Safeguards Bus A3 and/or A4"13-003 Vendor Procedure 03-9002583-001, "Steam Generator Tube Preload Determination (Frequency Response Test)"13-004 Engineering Change EC-43758, "Install Temporary Offsite Power to Engineered Safeguards Buses A3/A4 from Startup Transformer #2"13-006 Work Plan 1408.778, "Main Generator Stator Ventilation Flow Test"13-007 Engineering Change EC-45808, "Update Operator Action Based on Revised Electrical Equipment Room Free Convection Model"

ANO 50.59 Evaluation Number 13-001

10 CFR 50.59 EVALUATION FORM Sheet 1 of 4 I. OVERVIEW / SIGNATURES1 Facility: ANO Evaluation # 13-001 / Rev. #: 0 Proposed Change / Document: EC-41466 Description of Change:

The Emergency Cooling System is not currently included in the Technical Specifications, and by default the electrical equipment TS 3.8.4 and 3.8.9 LCOs are applied, which have very short time clocks. Since Emergency Chillers VCH-4A/B have no LCO, a single failure of the operable train is assumed in a postulated event during the maintenance period. Due to limitations with currently employed compensatory measures, outside ambient temperature limits are imposed to maintain equipment within design temperature limits. These temperature limits are lower than the summer design condition of 100 °F outside ambient, and taking equipment out of service in the summer might therefore require a plant shutdown.

This design change implements the following physical changes to remove the outside ambient temperature limit associated with maintaining Corridor 98, Charger Room 98, switchgear room 99 and charger room 109 below their 120 °F design temperature. Note battery rooms 95 and 110 are qualified for 150 °F.

Room 109: Exhaust Fan VEF-33 is replaced with a safety related fan and spark resistant motor. Crediting this fan post-accident will allow makeup air from the Turbine Building to remove heat in Room 109 through open doors 480 and 56.

Room 99: A new safety related exhaust fan, VEF-35, will be installed. This fan will discharge air back to the Turbine Building, inducing makeup air from the Turbine Building through open doors 46 and 56.

The wall opening between Room 99 and the Turbine Building will be equipped with new Fire (FD-99-89) and gravity (BDD-7810) dampers.

The following aspect of this activity has been deemed adverse and is evaluated herein:

This activity adds to the compensatory actions necessary to maintain electrical equipment rooms within their design temperatures as discussed in UFSAR Section 9.7.2.1. The addition of necessary steps is considered an adverse change.

The equipment to be manipulated by new operator actions is accessible, actions taken are relatively simple, and actions can be accomplished in a short time. New manual actions will be included in Procedure OP-1104.027.

These new manual actions do not take the place of existing automatic actions. Operators will be trained on these changes via routine training methods. Dedicated operators are maintained on shift to perform post event manual actions related to a VCH-4 chiller that is out of service. This change does not impact existing information displays. Actions are taken several hours after an event and adequate time is available to perform these operator actions. Adequate environmental conditions will be present at the manual action locations post accident for operator actions. Equipment required to perform these actions is identified and labeled in the field per this EC and child ECs.

Dose effects in areas where these manual actions are taken have been performed consistent with NUREG 0737. Per NUREG 0737, the dose rate for areas requiring infrequent access is per GDC 19, i.e. dose to personnel shall not exceed 5 rem whole body or its equivalent for the duration of the accident. Post LOCA doses from manipulation of doors and equipment in Corridor 98 and adjacent areas have been previously evaluated in CR-ANO-C-2007-0289, CA-13. Doses received from starting VEF-35 in room 99 and closing damper HVD-235 in room 109 are bounded from doses previously evaluated since these new actions are expected to take less time than those actions previously evaluated in the same areas (Room 99 and 109). The action to close fire damper FD-128-16 takes place in an area (above room 109) which has more shielding from the same point sources as 109 and resultant dose will be lower. It is concluded that GDC 19 dose limits of 5 rem whole body to individual operators will not be exceeded with these actions. In post-accident conditions, the Emergency Response Organization is staffed and available to manage dose and provide local dose rate information to the individuals in the field.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 4 In conclusion, equipment to be manipulated by these actions is accessible, actions taken are relatively simple and can be accomplished in a short time, and dose consequences are expected to be within allowable limits.

These new actions are thus considered acceptable.

Summary of Evaluation:

New operator actions are implemented to require starting exhaust fan VEF-35 and aligning dampers following an accident coincident with equipment out of service and equipment single failures. Additional fan failures or operator action errors are not postulated that could create new accident or equipment malfunction scenarios.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: David MacPhee / See AS / Entergy Operations, Inc. / 4/28/13 Name (print) / Signature / Company / Department / Date Reviewer: Jerry Howell / See AS / Entergy Operations, Inc. / 4/28/13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / See AS for signature / 5/02/13 Chairmans Name (print) / Signature / Date 13-008 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 4 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

The new operator actions ensure electrical equipment is available to mitigate accidents. The new actions require manually starting an exhaust fan and closing dampers to ensure the battery and switchgear rooms do not exceed their equipment design temperatures. Operator errors which may occur to mitigate events will not increase the probability or frequency of an accident. The fans and dampers are not initiators of any accident evaluated in the UFSAR and therefore do not result in an increase in the frequency of an accident.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the UFSAR? No BASIS:

Equipment in these electrical rooms is subject to malfunction if temperature in the room exceeds qualified limits. Current analyses show that qualified temperatures would be exceeded assuming a combination of equipment maintenance outages, single failures, and elevated ambient temperatures approaching the design basis of 100°F ambient. New operator actions to start VEF-35 and close dampers HVD-235 and FD-128-16 will maintain room temperatures below qualified equipment limits for the design basis ambient temperature. New Manual actions meet EN-OP-104 guidelines for crediting operator manual action.

These fans are only placed into service following cooling equipment in one train (red/green) being found degraded and a single failure of equipment in the other train. An additional failure of VEF-33 or VEF-35, or incorrect operator action, is not postulated and does not increase the likelihood that temperatures in these rooms will exceed qualified limits. These actions act to enhance operation of SSCs important to safety and, therefore, do not increase the likelihood of occurrence of a malfunction of a subject SSC.

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

Actions taken per this activity ensure that the electrical equipment cooled by these new fans will be adequately cooled in the event of an accident. Since this electrical equipment will continue to adequately mitigate accident events, these actions do not affect the dose consequences of an accident previously evaluated.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the UFSAR? No BASIS:

New operator actions to start VEF-35 and close dampers HVD-235 and FD-128-16 will maintain room temperatures below qualified equipment limits for the design basis ambient temperature. These fans are only placed into service following cooling equipment in one train (red/green) being found degraded and a single failure of equipment in the other train. An additional failure of VEF-33 or VEF-35 is not postulated, so additional equipment malfunctions in these rooms are not postulated either.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 4

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes UFSAR? No BASIS:

The new operator actions mitigate the consequences of an accident by ensuring adequate cooling is provided for electrical equipment used to mitigate accidents. Manual action steps have been evaluated against appropriate EN-OP-104 procedural criteria for operator response. The fans are not initiators of any accident.

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the UFSAR? No BASIS:

New operator actions to start VEF-35 and close dampers HVD-235 and FD-128-16 will maintain room temperatures below qualified equipment limits for the design basis ambient temperature. These fans are only placed into service following cooling equipment in one train (red/green) being found degraded and a single failure of equipment in the other train. An additional failure of VEF-33 or VEF-35 is not postulated.

The new operator actions do not introduce the possibility for a malfunction of an SSC with a different result because it does not introduce a new failure mode.

7. Result in a design basis limit for a fission product barrier as described in the UFSAR being Yes exceeded or altered? No BASIS:

This change makes no physical changes to fission product barriers. New operator actions support proper operation of SSC that maintain fission product barriers. Therefore, this activity does not result in a DBLFPB as described in the UFSAR being exceeded or altered.

8. Result in a departure from a method of evaluation described in the UFSAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

This 50.59 evaluation is concerned with changes to how design functions are performed or controlled.

There are no changes to evaluation methodologies used in establishing the design bases or in the safety analyses.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-002

10 CFR 50.59 EVALUATION FORM Sheet 1 of 6 I. OVERVIEW / SIGNATURES1 Facility: ANO-1 Evaluation # / Rev. #: 13-002 / 0 Proposed Change / Document: EC 43686 Install Temporary Offsite Power to ES Bus A3 and/or A4 Description of Change:

A Process Applicability Determination (PAD) was performed for the subject Engineering Change (EC) which determined no adverse affect on design functions as described in the Arkansas Nuclear One, Unit 1 (ANO-1)

Safety Analysis Report (SAR). The PAD also concluded the activity associated with EC 43686 did not involve a test or experiment not described in the SAR. In accordance with the NRC-endorsed guidance contained in NEI 97-06, Revision 1, Guidelines for 10 CFR 50.59 Implementation, a 10 CFR 50.59 (5059) evaluation is not required unless a change to the facility involves either a test or experiment not described in the SAR or if an adverse affect results in relation to a design function credited in the SAR. Based on the above, the change supported by the subject EC does not require evaluation under 5059. However, due to the off-normal plant circumstances leading to the need to supply power to ANO-1 vital bus(es) A3 (A4) via temporary means and the underlying complexity of these circumstances, this 5059 evaluation is being performed as a conservative measure.

The PAD and 5059 processes are required to determine impact on design functions credited in the SAR.

Design functions are not equal to SAR descriptions of how structures, systems, or components (SSCs) are designed, but are those functions necessary to maintain the validity of the accident analyses assumptions (as described in the SAR) or other regulatory requirements (reference NEI 96-07 and EN-LI-100, Process Applicability Determination). In addition, the PAD and 5059 processes are not intended to address all details associated with a facility change. Such detail is contained in the various documents contained in the subject EC. However, many of these details will be described below to support a clearer understanding of the various aspects associated with this temporary change to the facility.

The subject EC restores offsite power to red train 4160 V bus A3 (A4), which is normally fed from Startup Transformer #1 (SU1) via non-vital 4160 V bus A1 (A2) during shutdown conditions. Temporary cabling is routed from SU1 directly to bus A3 (A4) via the one of the A3/A4 crosstie breakers A310 (A410). A temporary breaker with protective relaying is installed near SU1 to provide protection for the temporary cables. At SU1, the flex links between 4160 V bushings and bus bars are removed to isolate the 4160 V non-segregated bus and the flex links between 6900 V bushings and bus bars are removed to isolate the 6900 V non-segregated bus. Temporary cables are connected between SU1s 4160 V bushings and the line side of the new temporary breaker. Temporary cables are installed from the load side of the new temporary breaker to the vicinity of the A3 switchgear. These temporary cables are spliced into existing cables connected to A310 from the Alternate AC bus 2A9.

The main differences in existing offsite feeder breaker A309 (A409) from bus A1 (A2) to A3 (A4) and A310 (A410) are the use of A3 (A4) bus lockout relays, directional overcurrent relays (phase and ground), and degraded voltage relays.

BUS LOCKOUT RELAY - The bus A3 (A4) lockout relay is used to trip (or prevent closing) the breakers that are feeding the respective bus upon actuation of various protective relays, including the phase and ground overcurrent relays for breaker A309 (A409). Actuation of the lockout relay on a breaker A309 (A409) phase or ground overcurrent relay actuation prevents another source from closing in on a potentially faulted bus. Since the phase and ground overcurrent relays for breaker A310 (A410) only trip the A310 (A410) breaker and do not trip the bus lockout relay, the proposed configuration would not prevent closing the respective EDG output breaker A308 (A408), which could lead to loss of the EDG if the A3 (A4) bus is truly faulted. To accommodate this change in protective features, the A308 (A408) is maintained in Pull-to-Lock (PTL) both by procedure (reference OP-1104.036 Sections 47 through 52) and by a caution card installed on the respective hand switch.

Likewise, the EDG start handswitch is maintained in the Lockout position to preclude EDG auto start which could result in undesired idle EDG operation for an extended period of time. Administrative controls require verification that bus A3 (A4) is not faulted or is otherwise de-energized A310 (A410) opened and divorced from EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 6 offsite power) prior to starting the EDG and closing the EDG output breaker (reference OP-1107.002). The acceptability of maintaining the EDG in Lockout and A308 (A408) in PTL is determined based on the design function of the EDG and vital bus A3 (A4) while operating in Modes 5 and 6, including during the movement of fuel assemblies in these modes, which is discussed later in this evaluation.

DIRECTIONAL OVERCURRENT RELAYS - The existing offsite power connections to bus A3 (A4 ) via A309 (A409) is equipped with directional phase overcurrent and directional ground overcurrent protection. This is intended to isolate a fault on the non-vital bus(es) in the event a fault occurs when an EDG is used to back-feed the non-vital bus(es). However, this feature is not needed in this configuration because administrative controls prevent restoration of A3 (A4) power from A1 (A2) while this temporary modification is utilized to power A3 (A4).

Procedure controls are in place which require breaker A309 (A409) to remain racked down (reference OP-1107.002, Sections 47 and 50). This feature will not exist while SU1 is connected to A310 (A410). However the feature is not required because administrative controls prevent connection of the EDG while power is being provided to A3 (A4) through A310 (A410).

DEGRADED VOLTAGE RELAY - The degraded voltage relay senses low voltage on the incoming power supply and opens the normal feeder breaker from A1 (A2) to vital bus A3 (A4) to prevent damage to the vital bus electrical loads. The function of the degraded voltage relays is only required in Modes 1-4 (reference Technical Specification (TS) 3.3.8). This is further amplified by TS Surveillance Requirement (SR) 3.8.2.1 (associated with operability requirements for vital AC power in Modes 5 and 6, including during the movement of fuel in these modes), which does not require performance of TS SR 3.8.1.8 (EDG undervoltage test) or SR 3.8.1.9 (EDG Engineered Safeguards ESF) test). Auto-start of the EDG occurs on either low voltage or ESF signal. Assuming the EDG reaches rated speed and voltage, auto-closure of A308 (A408) will occur if a low voltage signal is present. With installation of the subject temporary modification, procedure instructions have been established to verify A310 (A410) is open, remove the EDG from Lockout, and remove EDG output breaker A308 (A408) from PTL, which will permit the EDG to energize A3 (A4). Therefore, the EDG output breaker A308 (A408) maintains the Mode 5 and 6 operability requirements for maintaining an emergency power supply to the respective vital bus, including during the movement of fuel in Modes 5 and 6.

With regard to EDG auto start capability beyond that discussed above, only one TS system requires auto start capability if moving fuel. TS 3.7.9, Control Room Emergency Ventilation System (CREVS), (and referred to in TS 3.8.10, Distribution Systems - Shutdown) requires CREVS operability to minimize Control Room Operator dose following a fuel handling accident. CREVS TS operability requires one train to be capable of automatic start (if not operating in the Emergency Ventilation Mode). This is met by ANO-2 powered 2VSF-9 when the ANO-1 powered fan VSF-9 is not capable of auto start. OP-2104.007, Control Room Emergency Air Condition and Ventilation, provides the administrative controls to ensure CREVS operability is maintained in light of the interrelations between the two ANO units. Therefore, EDG auto start is only required for the CREVS train being relied upon for auto start capability. Even if both CREVS trains were incapable of auto start, TS Actions simply require the Control Rooms to be placed in the Emergency Ventilation Mode of operation.

As detailed in the EC PAD, this temporary configuration does not match the SAR descriptions with regard to above protective features or the physical path in which power is transported from SU1 to the vital 4160 V buses.

In addition to the above, remote-manual or automatic transfer capability to SU2 is currently unavailable and will remain unavailable in this temporary configuration. Likewise, the Alternate AC Diesel Generator (AACDG) will also remain unavailable under the temporary configuration. However, the TSs require only one offsite power source in the aforementioned modes of operation and do not require operability of the AACDG. Therefore, these features are not required.

The TSs require a qualified offsite power source to be operable. The respective Bases (TS 3.8.2) states:

An offsite circuit includes the necessary breakers and equipment to properly align the circuit from the transmission line sources to the required 4160 V ES bus(es).

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 6 This temporary modification does not affect the capability of the offsite power source (SU1 transformer), and includes the necessary physical breakers, cabling, and administrative controls to maintain a qualified source of power to the vital 4160 V bus(es). In addition, this temporary modification is electrically sized (temporary breakers, cables) to meet the aforementioned applicable (Mode 5 and 6) safety analyses and TS requirements.

In addition to the EC process and other administrative controls utilized to safety support this temporary modification, plant pre-heatup checklists (reference OP-1102.001 Step 7.5.1, OP 1107.001 Supplement 10) prevent Mode 4 entry, further ensuring the temporary configuration is limited to the modes for which it has been evaluated. Prior to transitioning to Mode 4, the checklist requires verification of offsite power sources and bus alignments via the SAR-described normal configuration (via the non-vital 4160 V buses). Because this cannot be met until the aforementioned A3 (A4) breakers are aligned normally, advancing to Mode 4 is prohibited.

The EC PAD determined that no adverse impact has been created by implementation of this temporary modification on any design function, method of controlling or performing a design function, or method of evaluation of a design function. Because a method of evaluation of a design function is associated with approved calculational methods or codes utilized in the accident analyses, it is clear this activity is unrelated to this criteria. In addition, the EC PAD determined that this activity did not involve a test or experiment not described in the SAR (or otherwise). To address the first two items, the design function (and method of controlling the design function) of AC power sources must be understood.

The design function of AC power with respect to TSs is discussed above and is met with respect to the temporary modification. The design function, as it relates to the accident analyses assumptions in the SAR, is further discussed here. For Modes 5 and 6, the only accident assumed in the SAR is a fuel handling accident (reference SAR Section 14.2.2.3). Fuel handling equipment is not powered via the 4160 V vital buses. In addition, the temporary power configuration implemented by this EC has no affect on current non-vital power capabilities. Mitigation of a fuel handling accident includes establishing containment closure and placing the fuel, where possible, in a safe configuration. The non-vital powered fuel handling equipment is designed for manual operation (such as hand-cranks) should power be lost (reference System Training Manuals STM 51-1 and STM 51-2) which enables placing the fuel in a safe condition. The accident analysis does not credit containment closure to ensure offsite dose consequences remain within 10 CFR 50.67 limits. Nevertheless, containment breaches are tracked and require a method of closure be available should a fuel accident occur.

Closure methods may include remote manual operation of a valve from the control room, but can be achieved locally if needed. Note that the methods of establishing containment closure and the controlling administrative controls associated with containment breaches are not affected or changed as a result of this temporary modification (response remains unchanged whether power is lost while utilizing the temporary cable or whether lost when aligned normally via A1 (A2)). Based on the above, this temporary modification has no impact on the fuel handling accident.

The SAR describes Mode 5 and 6 events that are considered beyond that of the fuel handling accident. With regard to a boron dilution event, the large volume of highly borated water maintained in the refueling canal precludes any significant loss of shutdown margin given the length of time available for Operators to recognize a boron dilution event and stop the dilution. This remains true even in lowered inventory due to the high concentration of boron. The SAR considers this event in conjunction with a refueling accident. AC power availability has no impact on the capability to secure a dilution source or to detect the dilution via physical observation or DC-backed level instrumentation or neutron flux indication. In addition, because AC power source operability is maintained, no difference in boron dilution mitigation has been created due to a loss of offsite power while this temporary modification is installed. Therefore, this temporary modification has no impact on the considerations given to a boron dilution event as described in the SAR (reference SAR Section 14.1.2.4).

The DHR system utilizes vital AC power to function and is described in SAR Section 9.5. This temporary modification provides a qualified offsite power source and maintains an operable EDG as required by TSs.

Therefore, the consequences of a loss of offsite power or the loss of the EDG remain unchanged with respect to this temporary modification. Note that single failure is not assumed in Modes 5 and 6. In addition, the recovery actions for a loss of DHR contained in the respective abnormal operating procedure (OP-1203.028) are unchanged by this temporary modification.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 6 With regard to Spent Fuel Pool (SFP) cooling is likewise not adversely affected by this temporary modification.

Loss of power response remains unchanged. Emergency makeup to the SFP can be made utilizing a multitude of sources based on availability, including the vital powered Service Water system, boric acid makeup systems, etc. (reference OP-1203.050).

Summary of Evaluation:

As described in the EC PAD and as established above, this activity does not result in an adverse impact to a design function, method of controlling or performing a design function, or method of evaluation of a design function. In addition, this activity does not involve a test or experiment not described in the SAR or otherwise.

Nevertheless, this activity is evaluated under 10 CFR 50.59 by response to the eight questions below. This evaluation concludes that the activity meets the necessary requirements for implementation without further NRC approval.

Note that the EC PAD and the following evaluation consider operation in Modes 5 and 6, and when moving fuel in these modes. Operation in Modes 1-4 has not been evaluated and, as described previously, administrative controls prevent entry into Mode 4 under the configuration established by this temporary modification.

In addition to the above, the EC PAD and the following evaluation does not assess the acceptability of entering a lowered RCS inventory condition, since no new failure modes are introduced and the probability of malfunctions or accidents are not changed by this temporary modification. Other operations, such as lowered inventory, must be assessed separately with consideration of applicable TSs and the restrictions contained with the Shutdown Operations Protection Plan.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: David Bice / See LAR 2103-0117 / EOI / Licensing / 04-19-13 Name (print) / Signature / Company / Department / Date Reviewer: Glenn Dobbs / See LAR 2013-0117 / EOI / DESIC / 04-19-13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / See LAR 2013-0117 / 04-19-13 Chairmans Name (print) / Signature / Date 13-011 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 5 of 6 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

As discussed in the description section above, this activity has no impact on the fuel handling accident because it does not affect non-vital power sources which support fuel handling equipment. In addition, a loss of power to fuel handling equipment is not expected to result in a fuel handling accident due to physical design of the equipment.

This activity is also unrelated to any initiating feature of a boron dilution event. In addition, this activity does not change the probability of a loss of DHR event. Likewise, supplying power to vital 4160 V buses via the established temporary configuration does not create conditions that would result in more than a minimal increase in the frequency of a loss of AC power event, because the modification establishes a qualified source of power as detailed in the EC.

Therefore, this activity does not result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the SAR.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the UFSAR? No BASIS:

As discussed in the description section above, this activity maintains the operability of the required offsite and onsite power source for operation in Modes 5 and 6, including during the movement of fuel while operating in these modes. The administrative controls established ensure that the likelihood of a loss of a vital 4160 V bus or supporting AC power sources has not changed since procedures previously permitted manual means of energizing the bus(es) (for example, use of the AACDG as the TS required onsite power source, which has no automatic start and connect features). The consequences of a loss of AC power are no different than a loss of AC power occurring when offsite power is aligned via the A1 (A2) non-vital 4160 V bus. Therefore, this activity does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the SAR.

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

As discussed in the description section above, the fuel handling accident and other Mode 5 and 6 events are not adversely affected by this activity. The response to these events considering a loss of power remains unchanged when compared to a loss of power when normally aligned via the non-vital A1 (A2) bus. CREVS operability is maintained in support of minimizing Control Room Operator dose should a fuel handling accident occur. In addition, the safety analysis does not credit containment closure in meeting offsite dose limits following a fuel handling accident. Therefore, this activity does not result in more than a minimal increase in the consequences of an accident previously evaluated in the SAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 6 of 6

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the UFSAR? No BASIS:

As discussed in the description section above, the probability or type of malfunction associated with equipment important to safety are not adversely affected by this activity. The response to these events remains unchanged when compared to a loss of power under normal configurations. No additional malfunctions or equipment loss is created by this activity. Therefore, this activity does not result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the SAR.

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes UFSAR? No BASIS:

Because the temporary method of restoring offsite power to vital 4160 V buses maintains required qualifications of power sources (with regard to operation in Modes 5 and 6, and during the movement of fuel in these modes), a new accident type is not created due to implementation of this modification.

Reference the above description section for further detail of the modification.

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the UFSAR? No BASIS:

As discussed previously, the effects of a loss of power, which is considered by the safety analyses, remain unchanged. In addition, the consequences of a loss of power event remains unchanged with respect to this activity. Therefore, this activity does not create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the SAR.

7. Result in a design basis limit for a fission product barrier as described in the UFSAR being Yes exceeded or altered? No BASIS:

Because this activity does not increase the probability of a loss of power event or change the consequences of a loss of power event, this activity can not decrease the margin to fission product barrier limits for loss of power events in Modes 5 and 6.

8. Result in a departure from a method of evaluation described in the UFSAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

As discussed previously, this activity is unrelated to any method of evaluation described in the SAR used in establishing the design bases or in the safety analyses.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-002, Rev. 2

10 CFR 50.59 EVALUATION FORM Sheet 1 of 16 I. OVERVIEW / SIGNATURES1 Facility: ANO-1 Evaluation # / Rev. #: 13-002 / 1 Proposed Change / Document: EC 43686 Install Temporary Offsite Power to ES Bus A3 and/or A4 Description of Change:

Revision 1 of this 10 CFR 50.59 (5059) evaluation incorporates more detail from the parent EC (above) which will aid in a better understanding of the overall temporary configuration while minimizing the need to refer to the engineering evaluations contained in EC 43686. Likewise, an expanded discussion of the affects, if any, of this temporary modification on the frequency and consequences of accidents is included. This revision simply incorporates additional detail and does not result in a change to any conclusions approved in Revision 0.

A Process Applicability Determination (PAD) was performed for the subject Engineering Change (EC) which determined no adverse affect on design functions as described in the Arkansas Nuclear One, Unit 1 (ANO-1)

Safety Analysis Report (SAR). The PAD also concluded the activity associated with EC 43686 did not involve a test or experiment not described in the SAR. In accordance with the NRC-endorsed guidance contained in NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Implementation, a 10 CFR 50.59 (5059) evaluation is not required unless a change to the facility involves either a test or experiment not described in the SAR or if an adverse affect results in relation to a design function credited in the SAR. Based on the above, the change supported by the subject EC does not require evaluation under 5059. However, due to the off-normal plant circumstances leading to the need to supply power to ANO-1 vital bus(es) A3 (A4) via temporary means and the underlying complexity of these circumstances, this 5059 evaluation is being performed as a conservative measure.

Of importance is the differentiation between a design feature and a design function. The SAR describes many design features, including features of non-safety related or insignificant (from a nuclear safety perspective) structures, systems, or components (SSCs). Because the SAR describes the design of an SSC does not mean the SSC has a related design function. In general, the NEI 96-07 process focuses on design functions credited in the SAR. This is because the TSs are derived from the SAR. Nevertheless, the screening process thoroughly reviews regulatory and licensing bases, in relation to the SSC being changed, to determine if an adverse affect on a design function has resulted.

The inadvertent drop of the ANO-1 Main Generator stator on March 31, 2013, resulted in significant damage to the ANO-1 non-vital 4160 V buses A1 and A2. The buses receive power from a TS-required offsite power source via Startup Transformer #1 (SU1) or Startup Transformer #2 (SU2), and connect the offsite power source to respective vital 4160 V buses A3 and A4. This event occurred with ANO-1 operating in Mode 6. The damaged non-vital 4160 V buses are not recoverable and must be replaced.

The subject EC restores offsite power to red train 4160 V bus A3 (A4), which is normally fed from Startup Transformer #1 (SU1) via non-vital 4160 V bus A1 (A2) during shutdown conditions. Temporary cabling is routed from SU1 directly to bus A3 (A4) via the one of the A3/A4 crosstie breakers A310 (A410). A temporary breaker with protective relaying is installed near SU1 to provide protection for the temporary cables. Temporary cables are connected between SU1s 4160 V bushings and the line side of the new temporary breaker.

Temporary cables are installed from the load side of the new temporary breaker to the vicinity of the A3 switchgear. These temporary cables are spliced into the existing cables which are connected to the line side of A310 (A410) from the Alternate AC bus 2A9.

To enhance understanding of both the normal and temporary configuration of offsite power, the following simplified drawing is included. The temporary configuration is shown using dashed lines.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 16 500 KV 161 KV OFFSITE OFFSITE POWER POWER AUTO TRANSFORMER 500/161-22 KV SU#2 SU#1 TRANSFORMER TRANSFORMER 22-4.16 KV 161-4.16 KV 4.16 KV BUS A1 4.16 KV BUS A2 EDG1 EDG2 Temporary Breaker A309 A308 A408 A409 A310 A410 4.16 KV BUS A3 4.16 KV BUS A4 Proceduralized administrative controls prevent racking-up or closing the normal A3 and A4 bus supplies from A1 and A2, respectively (breakers A309 and A409).

Qualified Offsite Power Source The temporary modification does not affect the capability of the offsite power source (SU1) and includes the necessary physical breakers, cabling, and administrative controls to maintain a qualified source of power to the vital 4160 V bus(es). In addition, this temporary modification is electrically sized (temporary breakers, cables) to meet the aforementioned applicable (Mode 5 and 6) safety analyses and TS requirements. Entergy and/or industry standards were utilized to ensure the temporary cabling, breaker, and associated electrical connects meet or exceed the original design configuration with respect to providing offsite power to the vital 4160 V buses.

The following provides the details of this qualification.

The temporary cabling is routed from SU1 east to a temporary breaker, then routed west and south until reaching a window located at the ANO-1 heater deck, Column 1, Row H. After routing through the window, the cable then proceeds south until reaching the southern end of ANO-1. The cable continues west along the southern end of ANO-1 and then proceeds north past the E-1 feedwater heaters to fire door 48 (DR-48). The cable proceeds through DR 48 into Room 100, the A3 switchgear room. The cable is 350 MCM cable, two cables per phase between SU1 and the A3/A4 cross-connect. An additional 250 MCM conductor is provided as a ground return cable. In total, 6 runs of 350 MCM and one run of 250 MCM is utilized for the temporary modification. The overall cable run includes softeners, as appropriate, to prevent unnecessary damage to the temporary cables and all cabling is environmentally qualified. Exposure of the cabling to potential missile hazards does not create an appreciable change in risk because 1) the temporary modification is limited to Modes 5 and 6, such that proximity to high energy systems is eliminated, 2) susceptibility of the cable located outside the turbine building to missile hazards is insignificant when compared to the cable extending from the SU1 transformer to the switchyard, which is also non-safety related, no more robust than the temporary cabling, and exposed to missile hazards, and 3) the non-safety related SU1 transformer, associated voltage regulator, and 22 KV Breaker are exposed to missile hazards.

The seven cables are routed in a bundle within the safety-related A3 room such that the majority of the weight is on the floor. An approximate 15' length of the cable route extends from the floor to the cable tray. The majority of the weight for this portion will be supported by an existing 4" rigid conduit, to which the cables are secured EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 16 using tyraps. The estimated weight is 168# (1.6 #/ft X 15 ft X 7 cables). Considering a conservative seismic acceleration for this location of 1.9 (based on peak G and 1.5 multi-modal factor per ANO Doc. No. AP&LC-502),

the postulated seismic load on the conduit is 320#. The rigid conduit is adequate and has a significant load carrying capacity due to the relatively short span of 7' between supports and because the cables are attached approximately 1' from the conduit's fixed-end at the wall penetration. Two tyraps per cable are used, providing a total capacity of over 200#, which exceeds a seismic load per cable of (1.6 #/ft)(15 ft)(1.9 G) = 46#. An insignificant portion of the cable load will be imposed on the cable tray, which is judged to be structurally adequate since it is currently lightly loaded and well supported. This vertical portion of the new cable bundle is restrained laterally by bolting a temporary Unistrut channel frame to the wall and securing the cables to the frame with tyraps. Based on field walk-down, the only sensitive safety-related component in the vicinity is TS-7857, VUC-2B (A3 room cooler) High Temp Alarm Switch. This portion of the cables are routed and secured such that there is no credible seismic 2 over 1 interaction. The portion of the cable located outside the A3 room is in a non-safety related / non-seismic area and there are no structural concerns based on review of the routing given the rugged equipment and structures in the vicinity. Thermography is also performed at the cable connections every other day to ensure continued connection integrity.

Evaluation of the cable bends of the 350 MCM wire is based upon OP-6030.109, Section 9.16. Using the calculation for bend radius in the procedure, along with the vendor specification sheet for the 350 MCM wire (CatID: 0032010181), the minimum bend radius is 13.92 inches. This is calculated based upon the 1.16 inches diameter wire and the multiplier factor of 12 from OP-6030.109, Attachment 6. The 250 MCM wire bend radius, having a diameter of 1.07 inches, results in a minimum bend radius of 12.84 inches.

Entergy Arkansas T&D breaker provided for temporary breaker protection of the routed cables utilizing an R-Mag Vacuum Circuit Breaker. This breaker is a 50/60 Hz, rated continuous at 1200 A, rated max at 38 kV, rated short-circuit at 31.5 kA, and 3000 lbs. The ABB temporary breaker includes DC and AC inputs. The AC input is used to feed a receptacle, space heaters, and an undervoltage loss of heater AC relay. This breaker will be continuously energized and the heat generated by the breaker will be adequate to keep moisture from developing inside the enclosure. Therefore the AC power input is not required for this application. The DC input is used for the breaker control logic. The DC input is required and will be powered from DC power located at the SU1 control cabinet. The DC power used at SU1 is supplied from D-1117 (red train vital battery). Breaker opening and closing energy is supplied by capacitors that are charged by the DC power supply. The battery-backed DC power source is sized for Mode 1 station blackout and Loss of Coolant Accident (LOCA) scenarios.

Because this temporary modification is limited to operations in Modes 5 and 6, the use of this DC source in support of the temporary breaker functions is bounded by the accident-related installed capacity of the battery.

In addition, combustible loading, separation from other cables / cable trays, and A3 room heat loads have been evaluated and found acceptable. Normal station compensatory measures are used with respect to DR-48 with regard to fire or security.

The temporary modification utilizes the 4160 V winding from SU1 to supply busses A3 and A4 and retains use of the SU1 voltage regulator to maintain adequate voltage to the busses. No voltage regulator setpoint changes were required. Normal SU1 phase differential protective relaying is defeated by this temporary modification; however, this is acceptable because this relaying is for commercial protection only. The temporary breaker will still provide phase over-current protection for the transformer.

Ratings for A310/A410 are not impacted by this temporary modification as the A3/A4 bus loads are not affected.

The main differences in existing offsite feeder breaker A309 (A409) from bus A1 (A2) to A3 (A4) and A310 (A410) are the use of A3 (A4) bus lockout relays, directional overcurrent relays (phase and ground), and degraded voltage relays.

DEGRADED VOLTAGE RELAY - The temporary modification results in a change to the normal degraded voltage protection. The degraded voltage relay on 480 V vital bus B5 (B6) are required in Modes 1-4 to be capable of detecting a degraded voltage condition to open the normal A3 (A4) feeder breaker A309 (A409) and start the respective EDG, if the degraded voltage lasts longer than eight seconds. When the EDG rated speed and voltage is achieved, the EDG output breaker A308 (A408) will close and re-energize A3 (A4). Since the EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 16 degraded voltage relays only trip A309 (A409), the relays provide no function with the temporary modification installed since the normal feeder breaker A309 is procedurally racked down and danger tagged (to protect the damaged A1 bus). In addition, these relays are normally bypassed in Modes 5 and 6 (reference OP-1107.002, Section 42.0).

The loss of voltage relays associated with A3 (A4) are not physically affected by this temporary modification.

The relays continue to send an open signal to A309 (A409) and cross-tie breaker A310 (A410), although not needed as described above. In addition, as is the case with the undervoltage relays, the loss of voltage relays are required to be operable only in Modes 1-4 (reference TS 3.3.8, Diesel Generator (DG) Loss of Power Start (LOPS)).

DIRECTIONAL OVERCURRENT RELAYS - The existing offsite power connections to bus A3 (A4) via A309 (A409) is equipped with directional phase overcurrent and directional ground overcurrent protection. This is intended to isolate a fault on the non-vital bus(es) in the event a fault occurs when an EDG is used to back-feed the non-vital bus(es). However, this feature is not needed when the breakers connecting A1/A3 (A2/A4) are racked down. These breakers (A309 and A409) are required to be maintained in this position by procedure while the subject temporary modification (i.e., SU1 connected to A310 (A410)) is being utilized (reference OP-1107.002, Sections 47 and 50). In addition, administrative controls prevent connection of the EDG while providing power to A3 (A4) through A310 (A410). Note that design functions (and TS requirements) do not apply to equipment removed from service and the temporary modification does not permit parallel operation of the EDG with the offsite source. Based on this information, these relays are not needed to protect the EDGs and respective vital4160 V bus for possible faults which can occur on the related offsite power source or non-vital 4160 V bus.

BUS LOCKOUT RELAY - The A3 (A4) bus lockout relays, when actuated, open (or prevent closing) all potential 4160 V power supplies to the buses (for A3, breakers A308, A309, and A310). However, the phase and ground overcurrent relays for breaker A310 (A410) only opens the A310 (A410) breaker and does not actuate the bus lockout relay. Because the temporary electrical configuration supplies bus power through A310 (A410), a bus lockout may not occur upon fault detection, potentially permitting the respective EDG to automatically start and connect to a faulted bus. While the bus lockout relay aids in reducing the potential for electrical equipment damage, it does not have a design function. If the bus locks out, then the loads designed to be powered by an offsite source or the EDG are lost, regardless of the operable status of these power sources. Therefore, any loss of the EDG (should the EDG be connected to the bus) becomes moot with respect to the accident analysis.

However, when long term recovery of equipment is considered, limiting damage when faults occur can have significant value.

Due to the current plant configuration resulting from the dropped stator event, the importance of protecting the EDGs is elevated. Therefore, the EDG Control Room hand switch is procedurally maintained in Lockout and the EDG output breaker A308 (A408) is maintained in Pull-to-Lock (PTL) (reference OP-1104.036 and OP-1107.002). A caution card is also installed on the respective hand switch. This prevents automatic start of the EDG, which could result in undesired idle EDG operation for an extended period of time. Automatic connection to the bus is also administratively prevented since the A3 (A4) bus lockout feature (described above) will not actuate as designed while the temporary modification is being utilized. Instead, procedures require Operators to assess the status of the bus (i.e., divorced from other power sources and not faulted) prior to starting and connecting the EDG to the bus. These are the same conditions verified electrically before the EDG can automatically connect to the bus when respective hand switches are in the normal positions. Administrative controls require verification that bus A3 (A4) is not faulted or is otherwise de-energized (i.e., A310 (A410) opened and divorced from offsite power) prior to starting the EDG and closing the EDG output breaker (reference OP-1107.002). The acceptability of maintaining the EDG in Lockout and A308 (A408) in PTL is determined based on the design function of the EDG and vital bus A3 (A4) while operating in Modes 5 and 6, including during the movement of fuel assemblies in these modes, which is discussed later in this evaluation.

The above bus lockout and EDG configuration results in the bus lockout Control Room alarm being unavailable.

However, Control Room indications of bus status and indication of the loads powered by the bus remain available. Therefore, Operators will promptly determine a loss of bus has occurred. Whether the bus loss is determined via the lockout alarm or via other Control Room indications does not change the required Operator EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 5 of 16 response to verify the bus condition before energizing the bus by starting and connecting the respective EDG.

This verification is performed locally by determining which breakers indicate a fault (dropped-flag relay indication), visual inspection of the bus for obvious damage, and any unusual electrical odor detected. The time needed for this verification (assuming importance if both trains of DHR have been lost) is approximately 20 minutes based on reasonable judgment, well less than the time to boil (TTB) for the refueling canal or Spent Fuel Pool (SFP). With 23 of water over the fuel (normal level), the TTB is currently more than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months (and increasing, assuming no change in water level). The TTB is reduced when water level is lowered. However, ANO, through industry commitment, has adopted NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," as an industry initiative to manage shutdown tasks and associated electrical support to maintain risk at an acceptable low level. Such management (administered via the ANO Safe Shutdown Protection Plan (SOPP)), fully considers vulnerabilities and high-risk scenarios before permitting a reduction in margin (which could result when lowering RCS level, depending on available equipment). In addition, the TSs require two operable DHR trains when RCS level is lowered (less than 23 above the fuel) and the likelihood of a fault on both A3 and A4 simultaneously is not credible since the A310/A410 trip features remain active under this temporary modification. Therefore, it may be assumed that at least one 4160 V vital bus can be made available without significant delay, powered from its respective EDG, should a loss of offsite power occur. The SOPP also requires EDG auto loading when in reduced inventory.

In addition to the above, remote-manual or automatic transfer capability to SU2 is currently unavailable and will remain unavailable in this temporary configuration. Likewise, the Alternate AC Diesel Generator (AACDG) will also remain unavailable under the temporary configuration. However, the TSs require only one offsite power source in the aforementioned modes of operation and do not require operability of the AACDG. Therefore, these features are not required.

The TSs require a qualified offsite power source to be operable. TS 3.8.2 states:

The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

The ANO-1 Safety Analysis Report (SAR) and the associated TS 3.8.2 Bases do not directly define a qualified offsite power source. The TS Bases for this specification, as approved by the NRC in Amendment 215, state, in part:

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safeguards (ES) bus(es). Qualified offsite circuits are those that are described in the SAR and are part of the licensing basis for the unit.

An offsite circuit includes the necessary breakers and equipment to properly align the circuit from the transmission line sources to the required 4160 V ES bus(es). Only one of the possible offsite circuits is required provided it can supply the required Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. If a single offsite circuit cannot provide all the required distribution subsystem(s), a second offsite circuit is also required.

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply the required equipment.

The above Bases information is consistent with correspondence reviewed relative to qualified offsite power sources and the standard TSs (NUREG 1430, Revision 4).

In light of the above, the SAR (and TS Bases) describes the normal electrical path from SU1 to the vital 4160 V buses as originally designed. However, the design function of the offsite power source assumes an electrical path is available from the switchyard to the ES buses (A3 and A4) that maintains the necessary voltage and EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 6 of 16 frequency for important station loads. The A1 and A2 buses were designed to use this offsite power source for non-vital loads while maintaining the SAR and TS required connection to the ES buses. However, A1 and A2 are not credited in the SAR accident analyses associated with Modes 5 and 6, or during the movement of irradiated fuel, for accident prevention or mitigation. Therefore, although the design of A1 and A2, including the normal power path associated with these buses, is detailed in the SAR and TS Bases, these buses serve no design function in Modes 5 and 6, or during the movement of irradiated fuel in these modes. The installed temporary modification, which routes offsite power directly to the ES buses, meets the TS and SAR intended design function of powering important loads (i.e., loads assumed to be available and relied upon in the accident analyses) under both normal or accident conditions.

TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1 requires specific TS 3.8.1, AC Sources - Operating, SRs to be either met or performed, or both. Other TS 3.8.1 SRs are not required to be met or performed. As applicable to the qualified offsite power source:

1. SR 3.8.1.1 must be performed and met, (offsite power breaker check)

This SR is intended to ensure proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. This check must be performed every 7 days; however, under this temporary modification, Operations is verifying the correct alignment of the temporary power configuration at least once per day. In addition, the temporary breaker and installed connecting breakers are visually checked at this same frequency. Therefore, this SR continues to be met and performed.

2. SR 3.8.1.7 does not have to be performed or met, (transfer between SU1 & SU2)

The reason transfer capability between SU1 and SU2 is not required to be performed or met is because only one qualified offsite power source is required to be operable in Modes 5 and 6, including during the movement of irradiated fuel in these modes.

As discussed previously, the temporary electrical configuration does not affect the capability of the offsite circuit to maintain rated frequency and voltage, or the ability of the vital A3 and A4 buses from accepting loads in support of Mode 5 and 6 normal and accident conditions (relevant accidents are discussed later). Proper alignment of offsite power to the necessary load in the plant is maintained. The SU1 source is capable of supplying all required loads; therefore, a second offsite power source is not required. While the temporary configuration does not match the SAR descriptions with regard to above protective features or the physical path in which power is transported from SU1 to the vital 4160 V buses, the necessary qualification of the circuit has been achieved. Because necessary standards have been met and the intended function of the offsite power source is maintained, the offsite power source is considered qualified for meeting both SAR and TS requirements.

Manual Start/Connection of EDG Auto-start of the EDG occurs on either low voltage or ESF signal. Assuming the EDG reaches rated speed and voltage, auto-closure of A308 (A408) will occur if a low voltage signal is present. With installation of the subject temporary modification, procedure instructions have been established to verify A310 (A410) is open, remove the EDG from Lockout, and remove EDG output breaker A308 (A408) from PTL, which will permit the EDG to energize A3 (A4). The EDG TS operability and surveillance requirements (SRs) for Modes 5 and 6, including the movement of irradiated fuel in these modes, have been reviewed.

1. TS 3.3.8, Diesel Generator (DG) Loss of Power Start (LOPS), is applicable in Modes 1-4 There are no TS requirements for LOPS in Modes 5 or 6 or during the movement of irradiated fuel.

Therefore, the B5 (B6) undervoltage and A3 (A4) loss of voltage relays are not required to be operable in these modes.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 7 of 16

2. TS 3.7.9, Control Room Emergency Ventilation System(CREVS), requires auto-start capability on either VSF-9 or 2VSF-9 (only applicable during movement of irradiated fuel)

This is the only TS system which requires auto start capability if moving fuel. TS 3.7.9 (and referred to in TS 3.8.10, Distribution Systems - Shutdown) requires CREVS operability to minimize Control Room Operator dose following a fuel handling accident. CREVS TS operability requires one train to be capable of automatic start (if not operating in the Emergency Ventilation Mode). This is met by ANO-2 powered 2VSF-9 when the ANO-1 powered fan VSF-9 is not capable of auto start. OP-2104.007, Control Room Emergency Air Condition and Ventilation, provides the necessary administrative controls to ensure CREVS operability is maintained in light of the interrelations between the two ANO units. Therefore, EDG auto start is only required for the CREVS train being relied upon for auto start capability. Even if both CREVS trains were incapable of auto start, TS Actions simply require the Control Rooms to be placed in the Emergency Ventilation Mode of operation.

3. TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1 requires specific TS 3.8.1, AC Sources - Operating, SRs to be either met or performed, or both. Other TS 3.8.1 SRs are not required to be met or performed. As applicable to the qualified offsite power source:

a. SR 3.8.1.2 must be performed and met (EDG start test, minus the 15-second timing)

This is the monthly manual start of the EDG, which will continue to be performed while this temporary modification is active. A Note states that verifying the EDG reaches rated speed in voltage within 15 seconds is not required in Modes 5 and 6, including during the movement of irradiated fuel in these modes, because there is sufficient time to manually start an EDG in the event the offsite power source is lost (reference the applicable TS Bases).

b. SR 3.8.1.3 must be met, but does not have to be performed (EDG load test...parallel to grid)

During normal operations, the EDG is connected in parallel with the offsite power source in order to verify operation at rated loading. Performance of this SR is not required in Modes 5 and 6, including during the movement of irradiated fuel in these modes, because with limited AC sources available, a single event could compromise both the required circuit and the EDG. However, the SR must be met.

This means the EDG must have successfully completed its last load surveillance and that no maintenance has occurred or other condition exists that may bring into question the EDGs capability to operate at rated load.

c. SR 3.8.1.4 does not have to be performed or met (EDG fuel oil day tank level)

This SR is not required since crediting manual start of the required DG provides sufficient opportunity to ensure that the fuel oil transfer system is operating properly (reference the applicable TS Bases).

d. SR 3.8.1.5 must be performed and met (EDG fuel oil day tank water accumulation)

This SR will continue to be performed at the specified frequency while this temporary modification remains active.

e. SR 3.8.1.6 must be performed and met (EDG fuel oil transfer system)

This SR will continue to be performed at the specified frequency while this temporary modification remains active.

f. SR 3.8.1.8 does not have to be performed or met (UV test)

See Item 1 above. SR 3.8.1.8 is not required because it provides for testing of undervoltage start of the EDG, which is not required to be operable except in Modes 1-4. Automatic actuation and loading of the EDGs is not assumed in Modes 5 and 6.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 8 of 16

g. SR 3.8.1.9 does not have to be performed or met (ESF test)

SR 3.8.1.9 is not required because it provides for testing of the ES actuation signal associated with auto-start of the EDG, which is not required to be operable in Modes 5 and 6. Automatic actuation and loading of the EDGs is not assumed in Modes 5 and 6.

4. TS 3.8.10, Distribution Systems - Shutdown, requires the necessary electrical buses to be operable to support the following equipment, when that equipment is required to be operable:

a. TS 3.3.9, Source Range Neutron Flux This monitor has no automatic function and instruments are battery-backed; therefore, EDG auto-start capability is not required.

b. TS 3.4.3, RCS Pressure and Temperature (P/T) Limits Necessary temperature/pressure instruments are battery-backed and have no automatic function in relation to P/T limits; therefore, EDG auto-start capability is not required.

c. TS 3.4.7, RCS Loops - Mode 5, Loops Filled and TS 3.4.8, RCS Loops - Mode 5, Loops Not Filled One or more means of RCS cooling is required in Mode 5, dependent on RCS water level, which also supports a homogenous boron concentration in the RCS. Offsite power is required if a Reactor Coolant Pump (RCP) is utilized for cooling. Vital AC power is required if a DHR pump is utilized. Loss of all power results in loss of normal RCS cooling. Actions include restoration of any cooling loop possible (including establishing necessary Steam Generator inventory for natural or reflux cooling) and suspending boron dilutions. Start or restart of a DHR pump following a loss of offsite power is a manual operation. No automatic features exist for RCP or DHR loop operation. Sufficient time is available to assess the condition of the electrical distribution system, manually start an EDG, power the respective bus, and start a DHR pump before RCS temperatures rise to a level of concern; therefore, EDG auto-start is not required.

d. TS 3.4.11, Low Temperature Overpressure Protection (LTOP) System This system functions to prevent overpressurization of the RCS. AC power is not required for LTOP operation; however, LTOP inoperability could require cessation of RCS heatup, which in turn would require an RCS or DHR cooling loop to be available. See Items 4.c and 4.h for discussion of loss of RCS/DHR cooling.

e. TS 3.7.9, Control Room Emergency Ventilation System (CREVS)

See Item 2 above.

f. TS 3.7.10, Control Room Emergency Air Conditioning System (CREACS)

This system has no automatic function; therefore, EDG auto-start capability is not required.

g. TS 3.9.2, Neutron Instrumentation (for one monitor)

This monitor has no automatic function and instruments are battery-backed; therefore, EDG auto-start capability is not required.

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10 CFR 50.59 EVALUATION FORM Sheet 9 of 16

h. TS 3.9.4, Decay Heat Removal (DHR) and Coolant Circulation - High Water Level and TS 3.9.5, Decay Heat Removal (DHR) and Coolant Circulation - Low Water Level One or more DHR cooling loops are required in Mode 6, dependent on RCS water level, which also supports a homogenous boron concentration in the RCS. AC power is required for a DHR pump to perform this function. Loss of power results in loss of normal RCS cooling. Actions include restoration of any cooling loop, closing containment, and suspending boron dilutions. Start or restart of a DHR pump following a loss of offsite power is a manual operation. No automatic features exist for RCP or DHR loop operation. Sufficient time is available to assess the condition of the electrical distribution system, manually start an EDG, power the respective bus, and start a DHR pump before RCS temperatures rise to a level of concern; therefore, EDG auto-start is not required.

The TS review concludes that undervoltage and ES start is not required in Modes 5 and 6, including during the movement of irradiated fuel in these modes. This is based on the requirements of TS 3.3.8 (applicable only in Modes 1-4) and further amplified by SR 3.8.2.1 (associated with operability requirements for vital AC power in Modes 5 and 6, including during the movement of fuel in these modes), which does not require performance of SR 3.8.1.8 (EDG undervoltage test) or SR 3.8.1.9 (EDG Engineered Safeguards ESF) test). The manual EDG start SR must be performed monthly (verification of the 15-second start time not required), but the EDG is not required to be tied to the grid and loaded (i.e., SR 3.8.1.3 is not required). This conclusion allows the EDG to remain in Lockout and the respective output breaker A308 (A408) in Pull-to-Lock to enhance EDG protection while the A3 (A4) bus is powered via this temporary modification.

Accident Analyses The EC PAD determined that no adverse impact has been created by implementation of this temporary modification on any design function, method of controlling or performing a design function, or method of evaluation of a design function. Because a method of evaluation of a design function is associated with approved calculational methods or codes utilized in the accident analyses, it is clear this activity is unrelated to this criteria. In addition, the EC PAD determined that this activity did not involve a test or experiment not described in the SAR (or otherwise). To address the first two items, the design function (and method of controlling the design function) of AC power sources must be understood.

The design function of AC power with respect to TSs is discussed above and is met with respect to the temporary modification. The design function, as it relates to the accident analyses assumptions in the SAR, is further discussed here. For Modes 5 and 6, the only accident assumed in the SAR is a fuel handling accident (reference SAR Section 14.2.2.3). Fuel handling equipment is not powered via the 4160 V vital buses. In addition, the temporary power configuration implemented by this EC has no affect on current non-vital power capabilities. Mitigation of a fuel handling accident includes establishing containment closure and placing the fuel, where possible, in a safe configuration. The non-vital powered fuel handling equipment is designed for manual operation (such as hand-cranks) should power be lost (reference System Training Manuals STM 51-1 and STM 51-2) which enables placing the fuel in a safe condition. The accident analysis does not credit containment closure to ensure offsite dose consequences remain within 10 CFR 50.67 limits. Nevertheless, containment breaches are tracked and require a method of closure be available should a fuel accident occur.

Closure methods may include remote manual operation of a valve from the control room, but can be achieved locally if needed. Note that the methods of establishing containment closure and the administrative controls associated with containment breaches are not affected or changed as a result of this temporary modification (response remains unchanged whether power is lost while utilizing the temporary cable or whether lost when aligned normally via A1 (A2)). Based on the above, this temporary modification has no impact on the fuel handling accident.

The SAR describes Mode 5 and 6 events that are considered beyond that of the fuel handling accident. With regard to a boron dilution event, the large volume of highly borated water maintained in the refueling canal precludes any significant loss of shutdown margin given the length of time available for Operators to recognize a boron dilution event and stop the dilution. This remains true even in lowered inventory due to the high concentration of boron. The SAR considers this event in conjunction with a refueling accident. AC power unavailability does not prevent securing a dilution source or detecting the dilution via physical observation or DC-backed level instrumentation or neutron flux indication (or by boron sample). In addition, because AC power EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 10 of 16 source operability is maintained, no difference in boron dilution mitigation has been created due to a loss of offsite power while this temporary modification is installed. Therefore, this temporary modification has no impact on the considerations given to a boron dilution event as described in the SAR (reference SAR Section 14.1.2.4).

The DHR system utilizes vital AC power to function and is described in SAR Section 9.5. This temporary modification provides a qualified offsite power source and maintains an operable EDG as required by TSs.

Neither the TSs or SAR assume auto-start capability of the EDG to mitigate this event. Therefore, the consequences of a loss of offsite power or the loss of the EDG remain unchanged with respect to this temporary modification. Note that single failure is not assumed in Modes 5 and 6. In addition, the recovery actions for a loss of DHR contained in the respective abnormal operating procedure (OP-1203.028) are unchanged by this temporary modification.

With regard to Spent Fuel Pool (SFP) cooling, a loss of SFP cooling event is likewise not adversely affected by this temporary modification. Like the DHR pumps, the SFP pumps are EDG-backed. The loss of power response remains unchanged. Emergency makeup to the SFP can be accomplished utilizing a multitude of sources based on availability, including the vital powered Service Water system, boric acid makeup systems, etc. (reference OP-1203.050).

Summary of Evaluation:

The EC 43686 PAD and this 5059 evaluation consider operation in Modes 5 and 6, and when moving fuel in these modes. Operation in Modes 1-4 has not been evaluated. In addition to the EC process and other administrative controls utilized to safely support this temporary modification, plant pre-heatup checklists (reference OP-1102.001 Step 7.5.1, OP 1107.001 Supplement 10) prevent Mode 4 entry, further ensuring the temporary configuration is limited to the modes for which it has been evaluated. Prior to transitioning to Mode 4, the checklist requires verification of offsite power sources and bus alignments via the SAR-described normal configuration (via the non-vital 4160 V buses). Because this cannot be met until the aforementioned A3 (A4) breakers are aligned normally, advancing to Mode 4 is prohibited. The requirements of TS 3.8.1, AC Sources -

Operating, must also be met when entering Mode 4. This specification requires auto start and auto connection capability of both EDGs. This and other regulatory controls (TSs) also prevent Mode 4 entry under the described temporary electrical configuration.

As described in the EC 43686 PAD and as established above, this activity does not result in an adverse impact to a design function, method of controlling or performing a design function, or method of evaluation of a design function. In addition, this activity does not involve a test or experiment not described in the SAR or otherwise.

Nevertheless, this activity is evaluated under 10 CFR 50.59 by response to the eight questions below. This evaluation concludes that the activity meets the necessary requirements for implementation without further NRC approval.

ANO has not yet developed a shutdown risk model that quantifies changes in core damage frequency (CDF) or large early release frequency (LERF). However, risk monitoring tools are available to qualitatively assess risk based on changes in plant configuration while shutdown. As concluded above, TS and SAR requirements for an offsite and onsite power source are maintained. In addition, the frequency of any Mode 5, 6, or fuel movement related accident is not changed, nor are the response and mitigation assumptions to accident conditions adversely impacted. Therefore, no appreciable change in CDF is evidenced due to implementation of this temporary electrical configuration. Also as stated previously, the SAR analysis concludes that 10 CFR 50.67 offsite dose limits will not be exceeded following a fuel handling accident, even without containment closure.

Therefore, no appreciable change in LERF is evidenced due to implementation of this temporary electrical configuration. Station risk will continue to be managed according to procedures with consideration of significant changes in plant configuration.

In addition to the above, the EC 43686 PAD and the following evaluation does not assess the acceptability of entering a lowered RCS inventory condition, since no new failure modes are introduced and the probability of malfunctions or accidents are not changed by this temporary modification. Other operations, such as lowered inventory, must be assessed separately with consideration of applicable TSs and the restrictions contained with the Shutdown Operations Protection Plan. The following provides a high-level summary of important factors related to the quality of the temporary electrical configuration and equipment:

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 11 of 16 Component Design Temporary - Tied directly to output bushing of SU1.

Breaker

- Outdoor rated breaker and sized for ES bus loads.

- Breaker relay settings entered and coordinated by Entergy Arkansas for proper coordination with ES buses and to protect cabling. Peer reviewed by ANO personnel.

- Breaker and connections to SU1 undergo thermography every other day.

Cables & - Cables are correctly sized for the load and are rated for outdoor service.

Connections

- Cables are routed on the floor away from recovery efforts and not in cable trays.

- Cables are protected from impacts/egress and flagged to minimize personnel exposure and shown as protected train.

- Cables are meggared. A walk-down of the cables is performed daily.

- Connection of cables to A310/A410 cables are spliced in accordance with approved maintenance practices. Splices undergo thermography every other day.

Bus Lockout - Used to trip (or prevent closing) breakers feeding the respective bus.

Relay

- Phase and ground overcurrent relays for A310 (A410) trip only that breaker and do not actuate the bus lockout relay.

- Failure to actuate bus lockout relay could result in damage to the EDG.

- Procedures require EDG to remain in Lockout and respective output breaker to remain in PTL to preclude EDG damage by preventing connection to the bus until bus is verified to not be faulted.

Directional - A309 (A409) has directional phase overcurrent and directional ground overcurrent Overcurrent protection intended to isolate a fault on non-vital bus A1 (A2) when back-feeding A1 (A2)

Relay using an EDG.

- This feature is not required since procedures maintain A309 (A409) to remain racked down while A3 (A4) is powered from temporary connection to SU1.

- Administrative controls prevent closing EDG output breaker A308 (A408) while SU1 is supplying the respective bus (i.e., A310 (A410) closed).

Undervoltage / - Relays sense low voltage and act to open incoming power supplies, start the respective Loss of Voltage EDG, and once at rated speed and voltage, connect the EDG to the respective bus.

Relays

- Undervoltage / Loss of Voltage relays and EDG auto-start / auto-connection are not required in Modes 5, 6, or during the movement of irradiated fuel.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 12 of 16 Preparer: David Bice / See LAR 2103-0117 / EOI / Licensing / 04-26-13 Name (print) / Signature / Company / Department / Date Reviewer: Glenn Dobbs / See LAR 2013-0117 / EOI / DESIC / 04-26-13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / See LAR 2013-0117 / 04-26-13 Chairmans Name (print) / Signature / Date 13-015 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 13 of 16 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the SAR? No BASIS:

Loss of Offsite Power (LOOP)

The temporary breaker and cabling meet the necessary environmental, electrical loading, and other standards that qualify this electrical configuration in such a way that offsite power continues to be delivered to the ES buses at rated frequency and voltage. Cabling is routed away from high traffic areas and avoids the areas of recovery from the March 31, 2013, stator drop event. The temporary electrical components are treated as protected equipment. The potential for damage caused by missiles in negligible since the modification is approved for Modes 5, 6, and the movement of irradiated fuel only, which eliminates high energy systems in the turbine building which could produce missiles of concern. In addition, missile hazard susceptibility of the cables from SU1 to the turbine building is insignificant when compared to the exposure of like-cabling connecting SU1 to the switchyard, as well as SU1 itself and its associated voltage regulator and 22 KV breaker, all of which are non-safety related components. The temporary breaker is equipped with necessary protective relaying. The functions of the bus lockout, directional overcurrent, and undervoltage relays associated with bus A3 (A4), as configured by this temporary modification, have no affect on the probability of a LOOP. The standby condition of the EDG is also unrelated to any LOOP initiator. Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a LOOP. Further detail of the physical quality of the temporary breaker and cabling is included in the Description section above and in EC 43686.

Fuel Handling Accident The temporary modification is associated with establishing a qualified offsite power source to vital 4160 V buses. All fuel handling equipment is non-vital powered and, therefore, cannot be impacted by this temporary modification. In addition, a LOOP is not assumed to cause a fuel handling accident and fuel handling equipment can be operated manually (without power) if necessary to achieve safe fuel location.

Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a fuel handling accident.

Boron Dilution Accident The SAR considers this accident to be incredible in the subject modes due to the high concentration of boric acid in the RCS. Dilution detection may be by observation of unexpected refueling/SFP level changes (which can be verified locally, without use of powered instrumentation), a change in neutron countrate (battery-backed instrumentation), or by routine sample. The temporary modification does not impact detection capability. Response to a boron dilution event requires isolation of the dilution source, which may be accomplished by manual means. In addition, due to the high RCS boron concentration, sufficient time is available to support detection and source isolation before a significant loss of Shutdown Margin (SDM) would occur. Based on the above, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a boron dilution accident.

Loss of DHR Loss of DHR is not an accident, but is conservatively evaluated in this 5059. As noted above, the temporary modification does not have an appreciable impact on LOOP events; therefore, the probability of a loss of DHR event remains unchanged with regard to a LOOP initiator. The respective EDGs are being maintained in Lockout as an added EDG protective measure. However, EDG auto-start and auto-connection to the respective 4160 V vital bus is not required in the modes in which this temporary EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 14 of 16 modification has been approved for use. In addition, DHR recovery following a LOOP is via manual actions (no automatic features are associated with DHR startup). Because the temporary modification does not appreciably impact the potential for a LOOP event or the potential for a loss of a required EDG, this activity does not result in more than a minimal increase in the frequency of occurrence of a loss of DHR event.

Loss of SFP Cooling Loss of SFP cooling is not an accident, but is conservatively evaluated in this 5059. SFP cooling pumps are vital powered and the discussion of the temporary modification impact is, therefore, equivalent to the loss of DHR discussion above. Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a loss of SFP cooling event.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the SAR? No BASIS:

The components that can be affected by the temporary modification include SU1, A3 (A4), the respective EDGs, and required loads powered from A3 (A4).

SU1, A3 (A4), and Required Loads The temporary breaker and cabling meet the necessary environmental, electrical loading, and other standards that qualify this electrical configuration in such a way that offsite power continues to be delivered to the ES buses at rated frequency and voltage. The temporary breaker is equipped with necessary protective relaying to ensure no impact to SU1. The configuration of the bus lockout, directional overcurrent, and undervoltage relays associated with bus A3 (A4) do not increase the probability of a bus fault. The protective features associated with the temporary breaker and breaker A310 (A410) continue to ensure A3 (A4) is de-energized should a fault occur on the bus or temporary cabling, protecting downstream loads. As discussed previously, the temporary modification establishes a qualified offsite power source to the ES bus and will continue to provide necessary power at rated frequency and voltage to required loads during operation in Modes 5 and 6, including during the movement of fuel while operating in these modes. No feature is implemented by this temporary modification that would increase the likelihood of occurrence of a malfunction of a structure, system, or component important to safety (SU1, A3 (A4), and required loads) previously evaluated in the SAR.

EDG The only affect of this temporary modification on the EDG is the inability of the bus lockout relay to actuate under all designed scenarios. This configuration could permit the EDG to auto-connect to a faulted bus, which could damage the EDG. Although such an occurrence is unlikely, the EDG is being maintained in Lockout as an added protective measure. Note that the EDG would not be of use in a faulted bus scenario; however, it is prudent to protect the EDG in the event a faulted bus could be repaired and returned to service, re-establishing the need for the EDG power source. The administrative controls established ensure that the likelihood of a loss of a vital 4160 V bus or supporting AC power sources has not changed.

Because of these administrative controls, the potential for the temporary modification to result in an EDG malfunction is removed. In addition, as established in the Description section above, EDG auto-start and auto-connect features are not required by the TSs or the SAR in the modes of which this temporary modification supports. Therefore, this activity does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety (EDGs) previously evaluated in the SAR.

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10 CFR 50.59 EVALUATION FORM Sheet 15 of 16

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the SAR? No BASIS:

As concluded in response to Question 1 above, there is no appreciable impact with regard to the initiation of any Mode 5 or 6 accident or event. The temporary modification provides a qualified offsite power source to the ES buses and the EDGs remain protected and available to supply the respective ES bus by manual start and connection to the bus upon a LOOP. The accident and event analyses account for a LOOP and do not credit auto-start and auto-connection of the EDGs in the modes for which this temporary modification supports.

The loss of all power does not cause a fuel handling accident and the response to a fuel handling accident should power be unavailable is not adversely impacted or changed by this temporary modification. This is also true for the boron dilution accident. CREVS operability is maintained in support of minimizing Control Room Operator dose should a fuel handling accident occur. In addition, the safety analysis does not credit containment closure in meeting offsite dose limits following a fuel handling accident.

Because recovery of systems following a LOOP is via manual operator action, relying on manual action to start and connect an EDG to its respective ES bus continues to support accident mitigation, since the safety analysis does not require auto-start and auto-connection of the EDG in the subject modes. This is because sufficient time is available to establish power to the bus from the EDG and place required loads in service (manual operations) prior to reaching conditions in the RCS or the SFP that would challenge the safety of the fuel (see discussion in Description section above related to TTB). Even if boiling temperatures were reached, significant additional time remains to establish cooling or makeup to the RCS or SFP prior to challenging the safety of the fuel.

The response to these events considering a loss of power remains unchanged when compared to a loss of power when normally aligned via the non-vital A1 (A2) bus. Therefore, this activity does not result in more than a minimal increase in the consequences of an accident previously evaluated in the SAR.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the SAR? No BASIS:

As concluded in response to Question 2 above, there is no appreciable change in the probability of a malfunction of equipment that could be affected by this temporary modification (SU1, A3 (A4), required loads, and EDGs). The SAR and station procedures consider both LOOP and loss of all power with respect to a fuel handling accident, boron dilution accident, loss of DHR, or loss of SFP cooling. Procedures and the SAR assumptions associated with mitigating the consequences of these accidents/events were established prior to implementation of this temporary modification. Because the temporary modification does not change the mitigation strategy or eliminate equipment used to mitigate the consequences of an accident or event, the response to these events remains unchanged when compared to a loss of power under normal configurations. No additional malfunction or equipment loss is created by this activity.

Therefore, this activity does not result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the SAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 16 of 16

5. Create a possibility for an accident of a different type than any previously evaluated in the SAR? Yes No BASIS:

Because the temporary method of restoring offsite power to vital 4160 V buses maintains required qualifications of power sources (with regard to operation in Modes 5 and 6, and during the movement of fuel in these modes), and because administrative controls have been established to protect the respective EDGs (maintained in Lockout), no configuration has been established that would create a scenario different than that considered in the SAR (i.e., LOOP, loss of all power, etc.). As discussed above, the consequences that may result upon a LOOP or loss of all power have been previously considered or evaluated in the SAR (loss of DHR, loss of SFP cooling). A loss of all power or reliance on manual start /

manual connection of the EDGs cannot cause a fuel handling accident or a boron dilution accident.

Therefore, the temporary modification does not create a possibility for an accident of a different type than any previously evaluated in the SAR.

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the SAR? No BASIS:

As discussed previously, the effects of a loss of power, which is considered by the safety analyses, remain unchanged. Administrative controls are established to eliminate potential of EDG malfunction during faulted bus scenarios. Regardless, the loss of the EDG and/or offsite power sources are supported by proceduralized recovery actions that are unchanged by this temporary modification. In addition, the consequences of a loss of power event remains unchanged with respect to this activity. Therefore, this activity does not create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the SAR.

7. Result in a design basis limit for a fission product barrier as described in the SAR being Yes exceeded or altered? No BASIS:

Because this activity does not increase the probability of a loss of power event or change the consequences of a loss of power event, this activity cannot decrease the margin to fission product barrier limits for loss of power events in Modes 5 and 6.

8. Result in a departure from a method of evaluation described in the SAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

As discussed previously, this activity is unrelated to any method of evaluation described in the SAR used in establishing the design bases or in the safety analyses.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-003

10 CFR 50.59 EVALUATION FORM Sheet 1 of 4 I. OVERVIEW / SIGNATURES1 Facility: ANO Unit 1 Evaluation #FFN-13-003 / Rev. #: 0 Proposed Change / Document: Vendor Procedure 03-9002583-001 Description of Change: The proposed activity, OTSG Tube Preload Determination (Frequency Response Test), provides a means of determining the preload condition of a sample of the steam generator tubes. The sample size will consist of a planned inspection of 39 tubes and all of the sample tubes are located in Unit 1 Steam Generator B. In general, the methodology is to insert the frequency response test (FRT) probe into the tube span which exhibits the most significant modal displacement for the particular frequency that is being tested. For the first modal frequency of the tube, this would be the 8th span. The FRT probe is comprised of a rotating eccentric mass attached to an electrical motor which can be sweep through a range of frequencies in order to excite the tube at its resonant frequency. The FRT probe is also equipped with an accelerometer that measures the response of the tube accelerations which enable the deduction of the resonant frequencies of the tube. Once the fundamental natural frequency of the tube is determined, the correlation between the natural frequency and its preload is used to verify the tube load at which the testing is performed.

The analytical correlation between the axial tube load and the modal frequencies of the tube is also developed in this document. This is a non-destructive test and is similar to eddy current testing. The test utilizes a spinning probe to cause excitation of the tubes and the probe is stabilized in the tube via nylon washers which center the probe in the tube and will not cause damage to the tube while spinning. The inspection will determine what state the tubes are in, whether they are in tension, compression, or neutral. The tubes are designed to be in a tensional state while inactive and compress to a neutral state while in-service. This test is being performed in order to validate the root cause for the potentially new damage mechanism of tube to tube wear identified in CR-ANO-1-2011-2609.

Summary of Evaluation: This activity is similar to eddy current testing, however: it is not a test or experiment discussed in the UFSAR. The activity is non-destructive and will be performed on safety related equipment while it is in an inoperable state. This test utilizes a probe which contains an eccentric mass, attached to a motor, to induce a frequency in a tube. The natural frequency of the tube is determined and used in correlation with the preload condition to confirm the tube load at which the test is performed. Pre and post eddy current testing will be performed to validate no damage was induced by the test. The qualification test, document number 32-9199423-000, and development of the test procedure was performed by the vendor using an Alloy 600 tube with simulated support plates and the appropriate elevations. The Unit 1 steam generator tubes are made of Alloy 690; however, there is no significant difference between the two as far as this test is concerned. The evaluation is focused on those accidents associated with the steam generator tubes (i.e. steam generator tube rupture). The tubing will be tested with the approved test method (eddy current) both pre and post to validate that no damage will be initiated into the tubing by this test.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 4 Preparer: Dan Meatheany / ORIGINAL SIGNED BY DAN MEATHEANY / EOI / EP&C / 05-03-13 Name (print) / Signature / Company / Department / Date Reviewer: Robert OQuinn / ORIGINAL SIGNED BY ROBERT OQUINN / EOI / EP&C / 05-03-13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / ORIGINAL SIGNED BY DALE E. JAMES / 05-03-13 Chairmans Name (print) / Signature / Date 13-017 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer Yes all questions below. No Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

This is a non-destructive inspection of a sample of the steam generator tubes to determine their preload condition. This activity is not an accident initiator; therefore, it does not increase the frequency of occurrence of an accident. The steam generator tubing is relied upon to cool the reactor under various conditions including accident analysis such as Main Steam Line Break, Feed Water Line Break and Steam Generator Tube Rupture. A single tube double ended sever has been analyzed. This test will not induce damage into the tube and will be validated by performing eddy current testing following the frequency test on all tubes. Any damage that could have been initiated will be identified and the tube will either meet its design criteria limit or will be removed from service. Therefore there would be no increase in occurrence of an accident since the tube will still meet its design requirements. The FRT does not produce appreciable tube-to-TSP wear or induce significant stress or high cycle fatigue to the tube, the tube-to-tubesheet weld or the hydraulic tube expansion in the tubesheet.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 4

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the UFSAR? No BASIS:

The steam generator tubes are a RCS boundary. The eccentric mass in the frequency test probe induces a load in the steam generator tube which causes the tube to vibrate. The frequency of the eccentric mass will increase from 39 to 42 Hz at a rate of 0.25 Hz/s. The maximum amount of stress exerted on the tube due to the moment of the eccentric mass is significantly less than the maximum stress seen by the tube during normal operation Eddy current testing is performed in order to detect flawed tubes for repair. For this inspection, eddy current test will be performed before and after the tube preload determination. Based on this information, the eddy current testing will ensure that the RCS pressure boundary (SG tubing) will meet or exceed the design criteria and ensure that the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the UFSAR will not increase.

Those accident analyses that address steam generator tube damage will still be bounding. The FRT does not produce appreciable tube-to-TSP wear or induce significant stress or high cycle fatigue to the tube, the tube-to-tubesheet weld or the hydraulic tube expansion in the tubesheet.

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

The preload determination inspection will be performed while the steam generators are inoperable. Eddy current test will be conducted pre and post inspection to ensure the integrity of the tube before the steam generator is returned to service. The FRT does not produce appreciable tube-to-TSP wear or induce significant stress or high cycle fatigue to the tube, the tube-to-tubesheet weld or the hydraulic tube expansion in the tubesheet. Therefore, for the accidents as discussed in question one, the use of the FRT will not result in more than a minimal increase in their consequences.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the UFSAR? No BASIS:

The loads experienced by the tubes during the test will be significantly less than what the tubes experience during normal operation. Eddy current will also be performed before and after the frequency test to ensure the integrity of the tubes. Based on this, the activity will not result in a more than minimal increase in the consequences of a malfunction of a structure, system, or component important to safety previously evaluated in the UFSAR. Additionally if the probe was to fall apart, the pieces are contained by having the nozzle dams in place preventing entry into the reactor. This is no different for an eddy current probe.

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes UFSAR? No BASIS:

This inspection is not an accident initiator. Pre and post eddy current testing will be performed to ensure the integrity of the tubes. As discussed in question one above the accidents evaluated in the SAR are applicable to this test and the test will not create a possibility for an accident of a different type than any previously evaluated in the UFSAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 4

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the UFSAR? No BASIS:

This is not an initiator to any event. The eccentric mass in the frequency test probe induces a load in the steam generator tube which causes the tube to vibrate. The frequency of the eccentric mass will increase from 39 to 42 Hz at a rate of 0.25 Hz/s. The maximum amount of stress exerted on the tube due to the moment of the eccentric mass is significantly less than the maximum stress seen by the tube during normal operation. Therefore, this activity does not create a possibility for a malfunction of a structure, system, or component important to safety with a different result than any previously evaluated in the UFSAR.

7. Result in a design basis limit for a fission product barrier as described in the UFSAR being Yes exceeded or altered? No BASIS:

The steam generators will be inoperable during the time of the test. If any wear is created in the tube due to the inspection, the most likely place will be around the tube support plates. The pre and post eddy current test will verify if any wear occurs. If any flaws are detected, the tubes will be evaluated for structural integrity and plugged if necessary before the steam generator is returned to service. This method of evaluation is what is referenced in the SAR. Therefore, this inspection does not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.

8. Result in a departure from a method of evaluation described in the UFSAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

This activity is not a method of evaluation nor is it related to a method of evaluation described in the UFSAR used in establishing the design basis or in the safety analyses. Eddy current testing, which is described in the UFSAR, will be conducted before and after the frequency test to ensure tube integrity.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-004

10 CFR 50.59 EVALUATION FORM Sheet 1 of 11 I. OVERVIEW / SIGNATURES1 Facility: ANO-1 Evaluation # / Rev. #: 13-004 / 0 Proposed Change / Document: EC 43758 Install Temporary Offsite Power to ES Bus A3/A4 from SU2 Description of Change:

A Process Applicability Determination (PAD) screening was performed for the subject Engineering Change (EC) which determined no adverse affect on design functions as described in the Arkansas Nuclear One, Unit 1 (ANO-1) Safety Analysis Report (SAR) and that the activity did not involve a test or experiment. In accordance with the NRC-endorsed guidance contained in NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Implementation, a 10 CFR 50.59 (5059) evaluation is not required unless a change to the facility involves either a test or experiment not described in the SAR or if an adverse affect results in relation to a design function credited in the SAR. Based on the above, the change supported by the subject EC does not require evaluation under 5059. However, due to the off-normal plant circumstances leading to the need to supply power to ANO-1 vital bus(es) A3 (A4) via temporary means and the underlying complexity of these circumstances, this 5059 evaluation is being performed as a conservative measure.

Of importance is the differentiation between a design feature and a design function. The SAR describes many design features, including features of non-safety related or insignificant (from a nuclear safety perspective) structures, systems, or components (SSCs). Because the SAR describes the design of an SSC does not mean the SSC has a related design function. In general, the NEI 96-07 process focuses on design functions credited in the SAR. This is because the TSs are derived from the SAR. Nevertheless, the screening process thoroughly reviews regulatory and licensing bases, in relation to the SSC being changed, to determine if an adverse affect on a design function has resulted.

This 5059 evaluation focuses on the qualification of the offsite power source (SU2), specifically the temporary cabling and temporary switchgear exposed to environmental conditions. While this configuration is not unlike the SAR normal design configuration (with regard to exposure to ambient conditions) for the non-safety related offsite power sources, the EC does increase the amount of equipment exposed to these conditions. The following specifics of EC43758, Revision 1 (except in relation to environmental exposure), are not evaluated in this 5059 because either the supporting PAD or previous evaluations have clearly determined no adverse impact on design function:

Modification Feature Discussion/Assessment Reference Design, capability, and protective features of temporary switchgear EC 43758, Revision 1, PAD Capability and protective features of cable/connections EC 43758, Revision 1, PAD A3/A4 protective relaying EC 43758, Revision 1, PAD Emergency Diesel Generator (EDG) protective relaying EC 43758, Revision 1, PAD Synchronizing EDG with SU2 EC 43758, Revision 1, PAD Temporary power to Fire Pump P-6A EC 43758, Revision 1, PAD Cable penetration into ANO-1 Intake Structure EC 43758, Revision 1, PAD Maintaining EDG in Lockout, A308/A408 in Pull-to-Lock (PTL) EC 43686 5059 Evaluation (LO-LAR 2013-0117)

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 11 This evaluation is performed considering ANO-1 operation in Modes 5 and 6, and during the movement of fuel while in these modes (or when defueled). This 5059 evaluation does not assess the acceptability of entering a lowered RCS inventory condition, since no new failure modes are introduced and the probability of malfunctions or accidents are not changed by this temporary modification. Other operations, such as lowered inventory, must be assessed separately with consideration of applicable TSs and the restrictions contained with the Shutdown Operations Protection Plan (SOPP).

Background

During 1R-24, a stator replacement incident caused damage to the ANO-1 4.16 and 6.9 kV non-safety related (NSR) buses (A1, A2, H1, and H2). EC 43686 has been implemented to restore power from Startup Transformer #1 (SU1) to the safety related (SR) 4.16 kV switchgear A3 and A4. EC 43686 provides a qualified offsite source (SU1) to A3 and A4 via breakers A310 and A410, respectively, required by Tech Spec 3.8.2 (AC Sources - Shutdown). EC 43686 will not be affected by implementation of the temporary modification (TMod) evaluated herein (EC 43758, Revision 1).

EC 43763 was previously implemented to disconnect ANO-1 NSR buses A1, A2, H1, and H2 from Startup Transformer #2 (SU2) while maintaining SU2 operability for ANO-2.

EC 43758, Revision 0, installed a temporary 4.16kV switchgear on a concrete pad directly east of the the ANO-1 Main Spare Phase Transformer (currently installed as C phase) and provided for connections to SU2 via the bus work above the SU2 Current Limiting Reactor (CLR), which is currently bypassed. EC43758, Revision 0, also installed a new cable that was routed from the temporary switchgear to a terminal box on Elevation 372 of the turbine building in order to include the temporary switchgear within the differential relay protection of SU2. Revision 1 of EC43758 will connect loads noted below to the temporary switchgear:

P-6A Fire Pump VCH-1B Main Chiller P-3A Circulating Water Pump P-3D Circulating Water Pump B-1 480 VAC Load Center B-2 480 VAC Load Center B-3 480 VAC Load Center A-3 4160 VAC Safety Related Switchgear A-4 4160 VAC Safety Related Switchgear EC 43758, Revision 1, also installs a remote operation panel and DC control power for the temporary switchgear. Process Applicability Determination (PAD) screenings addressing EC 43686, EC 43763, and Revision 0 of EC 43758 are included within the respective EC packages. The 10 CFR 50.59 (5059) evaluation associated with EC 43686 is attached to LO-LAR-2013-0117.

Procedural controls established by EC 43758, Revision 1, are utilized to assure loading of the temporary switchgear does not exceed the 8.5 MVA previously evaluated by CALC-11-E-0006-01. The temporary switchgear was installed above the Probable Maximum Flood (PMF) Elevation of 361, rated for outdoor use, and the switchgear and breakers are rated for the required continuous and short circuit currents. The bus current transformers (CTs) for the temporary switchgear are utilized to maintain the connected cable within the zone of protection for the SU2 Differential Relay. With the exception of the load cables, all cabling, switchgear, breakers, controls (local and remote) are located above the PMF elevation. Relay settings are provided to assure proper cable protection and selective tripping. An undervoltage bus trip for the main temporary switchgear breaker and its large motor breakers are also provided.

Since crosstie breakers A310 and A410 have been supplied from SU1 via a temporary breaker per EC 43686, the crosstie breaker for the respective bus must be open and racked down prior to closing a breaker from the temp switchgear to the respective safety related bus (A3/A4). The EDG Control Room hand switch and the EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 11 associated breaker (A308 and/or A408) are procedurally maintained in Lockout when the respective crosstie breaker (A310 and/or A410) is closed. Breakers A310 and A410 must be racked down prior to racking up breaker(s) A308, A408, A309 or A409. To summarize, the only live bus transfer allowed is the EDG being synchronized and added to the respective bus A3(A4) during load testing while A3(A4) is supplied from SU2 via A309(A409).

TMOD EC43686 powers A3 and A4 from SU1 through breakers A310 and A410, while TMOD EC43758 power temporary switchgear from SU2, and in turn this switchgear supplies A3 and A4 through breakers 107A and 105B to breakers A309 and A409.

Breaker alignment criteria are provided below:

Breakers A309(A409) racked down if SU1 is powering A3(A4) via A310(A410).

Breakers A310(A410) racked down if SU2 is powering A3(A4) via A309(A409).

EDG handswitch is in lockout and breaker A308(A408) handswitch in PTL if SU1 is powering A3(A4) through A310(A410).

EDG handswitch is in lockout and breaker A308(A408) handswitch in PTL if SU2 is powering A3(A4) through A309(A409), except for EDG testing in parallel operation.

A309(A409) supply from SU2 is racked down whenever the EDG is powering A3(A4), except for EDG testing in parallel operation.

A310(A410) supply from SU1 is racked down whenever the EDG is powering A3 (A4).

To summarize, the only live bus transfer allowed is the EDG being synchronized and added to the respective bus A3(A4) during load testing while A3(A4) is supplied from SU2 via A309(A409). EDG breakers A308(A408) may only be closed during testing by synchronizing to A3(A4) after the bus is energized from A309(A409). In the event an EDG is being tested and the A309(A409) breaker trips or offsite power is lost, A308(A408) must be opened prior to reconnecting any offsite power source to the bus.

To enhance understanding of both the normal and temporary configuration of offsite power, the following simplified drawing is included. The temporary configuration is shown using dashed lines.

500 KV 161 KV OFFSITE OFFSITE POWER POWER SU#2 TRANSFORMER 161-4.16 KV AUTO TRANSFORMER To Unit 2 500/161-22 KV SU#1 TRANSFORMER 22-4.16 KV Temporary Switchgear 4.16 KV BUS A1 4.16 KV BUS A2 P6A EDG1 EDG2 Temporary VCH1B Breaker P3A P3B A309 A308 A408 A409 A310 A410 B1 B2 4.16 KV BUS A3 4.16 KV BUS A4 B3 EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 11 Evaluation As stated previously, EC 43758, Revision 0, installed a temporary 4.16 kV outdoor-rated switchgear located in the transformer yard directly east and outside the oil retention barrier of Main Transformer X-01S. The EC also routed and connected cabling from the non-segregated bus directly above the bypassed SU2 CLR to the feeder breaker of the temporary 4.16 kV switchgear. The temporary switchgear CTs were connected to the SU2 differential relay. The main feeder breaker CT in the temporary switchgear was connected to re-instate the ANO-1 portion of the SU2 differential relay protection associated with the temporary switchgear.

The temporary cabling is NSR and does not replace SR cables. None of the cables installed under EC43758 (as described in both Revisions 0 and 1) are routed within the vicinity of SR equipment in the Turbine Building or Aux Building. The cabling from the bus work above the SU2 CLR to the temporary switchgear is routed in a dedicated cable tray mounted above the PMF. This tray proceeds directly east from the CLR to the temporary switchgear, only making a minor deviation to go around the spare phase main transformer.

Cables from the temporary switchgear to the A3 and A4 connections are routed in a cable tray directly to the south end of the transformer yard. At the south end of the transformer yard, the cables turn west and go to the southeast corner of the Turbine Building. Inside the Turbine Building the cables travel along a ledge on the south end of the Turbine Building to approximately Column Line 5.9. From there the cables head north and go up to Elevation 372 through a block-out between Column Lines B and C. Once at Elevation 372, the cables from the temporary switchgear are spliced to cables from A309 and A409 at cable tray DA003 and DA007, respectively. These cables are two conductors per phase 500 MCM. The overall cable run includes softeners, as appropriate, to prevent unnecessary damage to the temporary cables and all cabling is rated for indoor or outdoor use. The bends of the cables associated with the temporary switchgear comply with OP-6030.109, Installation of Electrical Cable & Wire. As discussed previously, this evaluation focuses on the extended length of cable and the temporary switchgear located outside the Turbine Building.

The temporary modification does not affect the capability of the offsite power source (SU2) and includes the necessary physical breakers, cabling, and administrative controls to maintain a qualified source of power to the vital 4160 V bus(es). In addition, this temporary modification is electrically sized (temporary breakers, cables) to meet the aforementioned applicable (Mode 5 and 6, and fuel movement) safety analyses and TS requirements. Entergy and/or industry standards were utilized to ensure the temporary cabling, breaker, and associated electrical connects meet or exceed the original design configuration with respect to providing offsite power to the vital 4160 V buses.

Exposure of the cabling and temporary switchgear to potential missile hazards does not create an appreciable change in risk because 1) the temporary modification is limited to Modes 5 and 6, and the movement of fuel while operating in these modes (including defueled conditions), such that proximity to high energy systems is eliminated, 2) susceptibility of the cable located outside the turbine building to missile hazards is insignificant when compared to the overhead cable extending from the SU2 transformer to the switchyard (and the switchyard 161 KV bus itself), which is also non-safety related and exposed to missile hazards, and 3) the non-safety related SU2 transformer, associated voltage regulator, and 161 KV Breakers are exposed to missile hazards.

The TSs require a qualified offsite power source to be operable. TS 3.8.2 states:

The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 5 of 11 The ANO-1 SAR and the associated TS 3.8.2 Bases do not directly define a qualified offsite power source.

The TS Bases for this specification, as approved by the NRC in Amendment 215, state, in part:

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safeguards (ES) bus(es). Qualified offsite circuits are those that are described in the SAR and are part of the licensing basis for the unit.

An offsite circuit includes the necessary breakers and equipment to properly align the circuit from the transmission line sources to the required 4160 V ES bus(es). Only one of the possible offsite circuits is required provided it can supply the required Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10. If a single offsite circuit cannot provide all the required distribution subsystem(s), a second offsite circuit is also required.

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply the required equipment.

The above Bases information is consistent with correspondence reviewed relative to qualified offsite power sources and the standard TSs (NUREG 1430, Revision 4).

In light of the above, the SAR (and TS Bases) describes the normal electrical path from SU2 to the vital 4160 V buses as originally designed. However, the design function of the offsite power source assumes an electrical path is available from the switchyard to the ES buses (A3 and A4) that maintains the necessary voltage and frequency for important station loads. The A1 and A2 buses were designed to use this offsite power source for non-vital loads while maintaining the SAR and TS required connection to the ES buses. However, A1 and A2 are not credited in the SAR accident analyses associated with Modes 5 and 6, or during the movement of irradiated fuel, for accident prevention or mitigation. Therefore, although the design of A1 and A2, including the normal power path associated with these buses, is detailed in the SAR and TS Bases, these buses serve no design function in Modes 5 and 6, or during the movement of irradiated fuel in these modes. The installed temporary modification, which routes offsite power directly to the ES buses, meets the TS and SAR intended design function of powering important loads (i.e., loads assumed to be available and relied upon in the accident analyses) under both normal or accident conditions.

While the temporary configuration does not match the SAR descriptions with regard to above protective features or the physical path in which power is transported from SU2 to the vital 4160 V buses, the necessary qualification of the circuit has been achieved. Because necessary standards have been met and the intended function of the offsite power source is maintained, the offsite power source is considered qualified for meeting both SAR and TS requirements.

The following provides a high-level summary of important factors related to the quality of the temporary electrical configuration and equipment:

Component Design

- Tied directly to 4160 VAC bus work from SU2.

- Outdoor rated switchgear and sized for ES bus loads.

Temporary Switchgear - Breaker relay settings determined by ANO personnel for proper coordination with ES buses and to protect cabling. Peer reviewed by ANO personnel.

- Entry of relay settings was coordinated and overseen by ANO personnel.

- Cables are correctly sized for the load and are rated for outdoor service.

- Cables are routed away from recovery efforts.

- Cables are protected from impacts/egress and flagged to minimize personnel exposure Cables & and shown as protected train when in use.

Connections - Cables are meggered. A walk-down of the cable routing between SU2 and the A3/A4 vital switchgear is performed daily.

- Connection of cables to A309/A409 cables are spliced in accordance with approved maintenance practices. Splices have been thermographied.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 6 of 11 Component Design

- Used to trip (or prevent closing) breakers feeding the respective bus.

- Phase and ground overcurrent relays for A309 (A409) actuate the bus lockout relay as originally designed.

Bus Lockout - Procedures require EDG to remain in Lockout (when not being tested) and respective Relay output breaker to remain in PTL to preclude EDG damage by preventing connection to the bus until bus is verified to not be faulted. Note Directional Overcurrent Relays provide protection during testing. Procedures prevent connecting A3(A4) and respective EDG to offsite source other than in support of EDG testing.

- A309(A409) has directional phase overcurrent and directional ground overcurrent Directional protection which will isolate a fault on the temporary switchgear when back-feeding using Overcurrent an EDG.

Relays - This feature is required since procedures allow the EDG to be connected to A3(A4) for load testing while connected to the temporary switchgear.

- Relays sense low voltage and act to open incoming power supplies. If in test, the Undervoltage / respective EDG, will disconnect from the bus, and reconnect the EDG to the respective Loss of bus when the bus has cleared/de-energized.

Voltage Relays - Undervoltage / Loss of Voltage relays and EDG auto-start / auto-connection are not required in Modes 5, 6, or during the movement of irradiated fuel.

Accident Analyses The PADs associated with Revisions 0 and 1 of this EC determined that no adverse impact had been created by implementation of this temporary modification on any design function, method of controlling or performing a design function, or method of evaluation of a design function. Because a method of evaluation of a design function is associated with approved calculational methods or codes utilized in the accident analyses, it is clear this activity is unrelated to this criteria. In addition, the EC PAD determined that this activity did not involve a test or experiment not described in the SAR (or otherwise). To address the first two items, the design function (and method of controlling the design function) of AC power sources must be understood.

The design function of AC power with respect to TSs is discussed above and is met with respect to the temporary modification. The design function, as it relates to the accident analyses assumptions in the SAR, is further discussed here. For Modes 5 and 6, the only accident assumed in the SAR is a fuel handling accident (reference SAR Section 14.2.2.3). Fuel handling equipment is not powered via the 4160 V vital buses. In addition, the temporary power configuration implemented by this EC has no adverse affect on current non-vital power capabilities. Mitigation of a fuel handling accident includes establishing containment closure and placing the fuel, where possible, in a safe configuration. The non-vital powered fuel handling equipment is designed for manual operation (such as hand-cranks) should power be lost (reference System Training Manuals STM 51-1 and STM 51-2) which enables placing the fuel in a safe condition. The accident analysis does not credit containment closure to ensure offsite dose consequences remain within 10 CFR 50.67 limits. Nevertheless, containment breaches are tracked and require a method of closure be available should a fuel accident occur.

Closure methods may include remote manual operation of a valve from the control room, but can be achieved locally if needed. Note that the methods of establishing containment closure and the administrative controls associated with containment breaches are not affected or changed as a result of this temporary modification (response remains unchanged whether power is lost while utilizing the temporary cable or whether lost when aligned normally via A1 (A2)). Based on the above, this temporary modification has no impact on the fuel handling accident.

The SAR describes Mode 5 and 6 events that are considered beyond that of the fuel handling accident. With regard to a boron dilution event, the large volume of highly borated water maintained in the refueling canal precludes any significant loss of shutdown margin given the length of time available for Operators to recognize a boron dilution event and stop the dilution. This remains true even in lowered inventory due to the high concentration of boron. The SAR considers this event in conjunction with a refueling accident. AC power EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 7 of 11 unavailability does not prevent securing a dilution source or detecting the dilution via physical observation or DC-backed level instrumentation or neutron flux indication (or by boron sample). In addition, because AC power source operability is maintained, no difference in boron dilution mitigation has been created due to a loss of offsite power while this temporary modification is installed. Therefore, this temporary modification has no impact on the considerations given to a boron dilution event as described in the SAR (reference SAR Section 14.1.2.4).

The Decay Heat Removal (DHR) system utilizes vital AC power to function and is described in SAR Section 9.5. This temporary modification provides a qualified offsite power source and maintains an operable EDG as required by TSs. Neither the TSs or SAR assume auto-start capability of the EDG to mitigate this event (reference ANO 10 CFR 50.59 Evaluation 13-002). Therefore, the consequences of a loss of offsite power or the loss of the EDG remain unchanged with respect to this temporary modification. Note that single failure is not assumed in Modes 5 and 6. In addition, the recovery actions for a loss of DHR contained in the respective abnormal operating procedure (OP-1203.028) are unchanged by this temporary modification.

With regard to Spent Fuel Pool (SFP) cooling, a loss of SFP cooling event is likewise not adversely affected by this temporary modification. Like the DHR pumps, the SFP pumps are EDG-backed. The loss of power response remains unchanged. Emergency makeup to the SFP can be accomplished utilizing a multitude of sources based on availability, including the vital powered Service Water system, boric acid makeup systems, etc. (reference OP-1203.050).

Summary of Evaluation:

This 5059 evaluation and the PAD associated with this EC consider operation in Modes 5 and 6, and when moving fuel in these modes (or defueled). Operation in Modes 1-4 has not been evaluated. In addition to the EC process and other administrative controls utilized to safely support this temporary modification, plant pre-heatup checklists (reference OP-1102.001 Step 7.5.1, OP 1107.001 Supplement 10) prevent Mode 4 entry, further ensuring the temporary configuration is limited to the modes for which it has been evaluated. Prior to transitioning to Mode 4, the checklist requires verification of offsite power sources and bus alignments via the SAR-described normal configuration (via the non-vital 4160 V buses). The requirements of TS 3.8.1, AC Sources - Operating, must also be met when entering Mode 4. This specification requires auto start and auto connection capability of both EDGs. This and other regulatory controls (TSs) also prevent Mode 4 entry under the described temporary electrical configuration.

As described in the EC PAD and as established above, this activity does not result in an adverse impact to a design function, method of controlling or performing a design function, or method of evaluation of a design function. In addition, this activity does not involve a test or experiment not described in the SAR or otherwise.

Nevertheless, the equipment associated with this activity exposed to environmental conditions is evaluated under 10 CFR 50.59 by response to the eight questions below. This evaluation concludes that the activity meets the necessary requirements for implementation without further NRC approval.

ANO has not yet developed a shutdown risk model that quantifies changes in core damage frequency (CDF) or large early release frequency (LERF). However, risk monitoring tools are available to qualitatively assess risk based on changes in plant configuration while shutdown. As concluded above, TS and SAR requirements for an offsite and onsite power source are maintained. In addition, the frequency of any Mode 5, 6, or fuel movement related accident is not changed, nor are the response and mitigation assumptions to accident conditions adversely impacted. Therefore, no appreciable change in CDF is evidenced due to implementation of this temporary electrical configuration. Also as stated previously, the SAR analysis concludes that 10 CFR 50.67 offsite dose limits will not be exceeded following a fuel handling accident, even without containment closure. Therefore, no appreciable change in LERF is evidenced due to implementation of this temporary electrical configuration. Station risk will continue to be managed according to procedures with consideration of significant changes in plant configuration. The SOPP will also provide assessment of plant configurations and establish necessary defense-in-depth criteria as appropriate.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 8 of 11 Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: David Bice / See EC in Asset Suites / EOI / Licensing / 05-10-13 Name (print) / Signature / Company / Department / Date Reviewer Glenn Dobbs / See EC in Asset Suites / EOI / DESIC / 05-10-13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / See EC in Asset Suites / 05-10-13 Chairmans Name (print) / Signature / Date 13-018 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the SAR? No BASIS:

Loss of Offsite Power (LOOP)

The temporary breaker and cabling meet the necessary environmental, electrical loading, and other standards that qualify this electrical configuration in such a way that offsite power continues to be delivered to the ES buses at rated frequency and voltage. Cabling is routed away from high traffic areas and avoids the areas of recovery from the March 31, 2013, stator drop event. The temporary electrical components are treated as protected equipment. The potential for damage caused by missiles is negligible since the modification is approved for Modes 5, 6, and the movement of irradiated fuel only, which eliminates high energy systems in the turbine building which could produce missiles of concern. In addition, missile hazard susceptibility of the cables from SU2 to the turbine building is insignificant when compared to the exposure of overhead cables connecting SU2 to the switchyard, as well as SU2 itself and its associated voltage regulator and 161 KV breaker, all of which are non-safety related components. The temporary switchgear is equipped with necessary protective relaying. Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a LOOP.

Further detail of the physical quality of the temporary breaker and cabling is included in the Description section above and in EC 43758.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 9 of 11 Fuel Handling Accident The temporary modification is associated with establishing a qualified offsite power source to vital 4160 V buses. All fuel handling equipment is non-vital powered. Because this temporary modification establishes a qualified offsite power source, the temporary power configuration implemented by this EC has no significant affect on current non-vital power capabilities. A LOOP, whether a result of loss of power from normal design configurations or from this temporary power configuration, does not result in a fuel handling accident. Furthermore, fuel handling equipment can be operated manually (without power), if necessary, to achieve safe fuel location. Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a fuel handling accident.

Boron Dilution Accident The SAR considers this accident to be incredible in the subject modes due to the high concentration of boric acid in the RCS. Dilution detection may be by observation of unexpected refueling/SFP level changes (which can be verified locally, without use of powered instrumentation), a change in neutron countrate (battery-backed instrumentation), or by routine sample. The temporary modification does not impact detection capability. Response to a boron dilution event requires isolation of the dilution source, which may be accomplished by manual means. In addition, due to the high RCS boron concentration, sufficient time is available to support detection and source isolation before a significant loss of Shutdown Margin (SDM) would occur. Based on the above, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a boron dilution accident.

Loss of DHR Loss of DHR is not an accident, but is conservatively evaluated in this 5059. As noted above, the temporary modification does not have an appreciable impact on LOOP events; therefore, the probability of a loss of DHR event remains unchanged with regard to a LOOP initiator. DHR recovery following a LOOP is via manual actions (no automatic features are associated with DHR startup). Because the temporary modification does not appreciably impact the potential for a LOOP event or the potential for a loss of a required EDG, this activity does not result in more than a minimal increase in the frequency of occurrence of a loss of DHR event.

Loss of SFP Cooling Loss of SFP cooling is not an accident, but is conservatively evaluated in this 5059. SFP cooling pumps are vital powered and the discussion of the temporary modification impact is, therefore, equivalent to the loss of DHR discussion above. Therefore, the temporary electrical configuration does not result in more than a minimal increase in the frequency of occurrence of a loss of SFP cooling event.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the SAR? No BASIS:

The safety-related components that can be affected by the temporary modification include A3(A4), the respective EDGs, and required loads powered from A3(A4).

A3(A4) and Required Loads The temporary switchgear and cabling meet the necessary environmental, electrical loading, and other standards that qualify this electrical configuration in such a way that offsite power continues to be delivered to the ES buses at rated frequency and voltage. The temporary switchgear is equipped with necessary protective relaying to ensure no impact to SU2. The temporary electrical configuration associated with bus A3(A4) does not increase the probability of a bus or EDG fault. As discussed previously, the temporary modification establishes a qualified offsite power source to the ES bus and will continue to provide necessary power at rated frequency and voltage to required loads during operation in Modes 5 and 6, including during the movement of fuel while operating in these modes. No feature is implemented by this temporary modification that would increase the likelihood of occurrence of a malfunction of a structure, system, or component important to safety (A3(A4)/EDG, and required loads) previously evaluated in the SAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 10 of 11

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the SAR? No BASIS:

As concluded in response to Question 1 above, there is no appreciable impact with regard to the initiation of any Mode 5 or 6 accident or event. The temporary modification provides a qualified offsite power source to the ES buses and the EDGs remain protected and available to supply the respective ES bus by manual start and connection to the bus upon a LOOP. The accident and event analyses account for a LOOP and do not credit auto-start and auto-connection of the EDGs in the modes for which this temporary modification supports.

The loss of all power does not cause a fuel handling accident and the response to a fuel handling accident should power be unavailable is not adversely impacted or changed by this temporary modification. This is also true for the boron dilution accident. In addition, the safety analysis does not credit containment closure in meeting offsite dose limits following a fuel handling accident.

Because recovery of systems following a LOOP is via manual operator action, relying on manual action to start and connect an EDG to its respective ES bus continues to support accident mitigation, since the safety analysis does not require auto-start and auto-connection of the EDG in the subject modes. This is because sufficient time is available to establish power to the bus from the EDG and place required loads in service (manual operations) prior to reaching conditions in the RCS or the SFP that would challenge the safety of the fuel (see discussion in Description section above related to TTB). Even if boiling temperatures were reached, significant additional time remains to establish cooling or makeup to the RCS or SFP prior to challenging the safety of the fuel.

The response to these events considering a loss of power remains unchanged when compared to a loss of power when normally aligned via the non-vital A1 (A2) bus. Therefore, this activity does not result in more than a minimal increase in the consequences of an accident previously evaluated in the SAR.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the SAR? No BASIS:

As concluded in response to Question 2 above, there is no appreciable change in the probability of a malfunction of equipment that could be affected by this temporary modification (A3(A4), required loads, and EDGs). The SAR and station procedures consider both LOOP and loss of all power with respect to a fuel handling accident, boron dilution accident, loss of DHR, or loss of SFP cooling. Procedures and the SAR assumptions associated with mitigating the consequences of these accidents/events were established prior to implementation of this temporary modification. Because the temporary modification does not change the mitigation strategy or eliminate equipment used to mitigate the consequences of an accident or event, the response to these events remains unchanged when compared to a loss of power under normal configurations. No additional malfunction or equipment loss is created by this activity.

Therefore, this activity does not result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the SAR.

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes SAR? No BASIS:

Because the temporary method of restoring offsite power to vital 4160 V buses maintains required qualifications of power sources (with regard to operation in Modes 5 and 6, and during the movement of fuel in these modes), no configuration has been established that would create a scenario different than that considered in the SAR (i.e., LOOP, loss of all AC power, etc.). As discussed above, the consequences that may result upon a LOOP or loss of all power have been previously considered or evaluated in the SAR (loss of DHR, loss of SFP cooling). A loss of all power or reliance on manual start /

manual connection of the EDGs cannot cause a fuel handling accident or a boron dilution accident.

Therefore, the temporary modification does not create a possibility for an accident of a different type than any previously evaluated in the SAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 11 of 11

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the SAR? No BASIS:

As discussed previously, the effects of a loss of power, which is considered by the safety analyses, remain unchanged. The loss of the EDG and/or offsite power sources are supported by proceduralized recovery actions that are unchanged by this temporary modification. In addition, the consequences of a loss of power event remains unchanged with respect to this activity. Therefore, this activity does not create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the SAR.

7. Result in a design basis limit for a fission product barrier as described in the SAR being Yes exceeded or altered? No BASIS:

Because this activity does not increase the probability of a loss of power event or change the consequences of a loss of power event, this activity cannot decrease the margin to fission product barrier limits for loss of power events in Modes 5 and 6.

8. Result in a departure from a method of evaluation described in the SAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

As discussed previously, this activity is unrelated to any method of evaluation described in the SAR used in establishing the design bases or in the safety analyses.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-006

10 CFR 50.59 EVALUATION FORM Sheet 1 of 5 I. OVERVIEW / SIGNATURES1 Facility: ANO-1 Evaluation # / Rev. #: 13-006 / 0 Proposed Change / Document: Work Plan 1408.778 Description of Change:

This work plan provides instructions for performing a ventilation flow test of the refurbished main generator stator. This test will be performed with the generator exposed to atmospheric pressure. The test will be performed at two turbine test speeds (e.g., approximately one-fourth and one-third normal speed of 1800 rpm).

The reactor will be sub-critical, all Control Rod Assemblies (CRAs) fully inserted, pressurizer level maximized within recommended limits, a main feedwater pump latched, turbine bypass valves in automatic maintaining

~895 psig, and letdown reduced to minimum. During the proposed test, the Reactor Coolant System (RCS) will be slowly cooled down. Due to the limitations of the available heat output from the Reactor Coolant Pumps (RCPs), the stored inventory of the steam generators will be increased to 200 inches. This should produce more steam flow during high steam demand during the test.

Summary of Evaluation:

The normal evolution of returning the unit to normal full power operation is to heat the RCS to normal operating temperature and pressure using the heat generated from the operation of the RCPs. The cooling system for the turbine generator has been purged with carbon dioxide and then hydrogen. Once the RCS is at operating temperature and pressure, the core is transitioned to a critical state. The turbine generator is then warmed.

This is accomplished with the withdrawal of the CRAs and/or diluting the soluble boron concentration.

The proposed evolution will utilize heat from the RCS via heat from the RCPs. The RCS will be isolated as much as possible to maximize the amount of heat available to turn the turbine. The cooling system for the turbine generator will not be purged at the time of this evolution and will operate for a few hours at lower speeds than normal operations. The core will not be taken critical. The reactor will be tripped. Procedural controls exist to lift a lead to block the reactor to turbine trip. All the Technical Specification required systems and indications needed to support this evolution will be operable.

The normal controls and protection systems for the turbine will be operating during the proposed test.

The initial temperature for the proposed test is ~ 532 °F (turbine header pressure of ~895 psig). As the test progresses and the RCS temperature approaches 500 °F, the turbine acceleration will be put on hold until the RCS temperature restores to ~532 °F. The cooldown limit is less than or equal to 40 °F per hour.

At 500 °F the steam generator pressure is greater than or equal to 650 psig saturation pressure. This provides margin to the actuation setpoint for the Main Steam Line Isolation (MSLI) (600 psig). The feedwater startup control valves will be in manual to maintain steam generator level. Operating these values in manual will require entry into a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Limiting Condition of Operation (ANO-1 Technical Specification 3.7.3).

Tie-rod bowing in the steam generators is predominately occurring during a cooldown. A structural assessment has been performed of the tie-rods and it was concluded that this test will not result in any adverse effects on the tie-rods and is bounded by current design basis and operability evaluations as long as the current procedural cooldown limit of less than or equal to 40 °F per hour is maintained.

MSLI is operable during this test. However, the startup control valves will be placed in manual and will not automatically close if MSLI is actuated. No safety systems are bypassed as part of this test.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 5 Once the evolution is complete, normal plant startup activities will be recommenced.

An independent 725 rpm trip will be established to provide turbine overspeed protection. Additional operators will be available during the performance of this proposed test to manually trip the turbine as needed. The last trip setpoint for the turbine is the MSLI trip setpoint. In addition the output breakers will be opened during this evolution to prevent the automatic attempt to ramp up the speed of the turbine and block load the turbine.

This test may be terminated at any time by manually tripping the turbine. Once tripped, any overcooling event would be terminated as well.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: Robert W. Clark / ORIGINAL SIGNED BY ROBERT W. CLARK / EOI / Licensing / 08-02-13 Name (print) / Signature / Company / Department / Date Reviewer: Daniel W. Fouts / ORIGINAL SIGNED BY ROBERT W. CLARK FOR DANIEL W. FOUTS PER TELECOM / EOI / F&A / 08-02-13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / ORIGINAL SIGNED BY DALE E. JAMES / 08-02-13 Chairmans Name (print) / Signature / Date OSRC-13-034 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature),

e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 5 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If Yes, Questions 1 - 7 are not applicable; answer only Question 8. If No, answer No all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

An overcooling event of the RCS and a steam line break inside containment are accidents that are evaluated in the SAR. The limits listed for a cooldown in the proposed evolution are the same that are used in the normal operating procedures (i.e., pressure / temperature limits for the vessel, pressurizer and the steam generators). The core is protected from a cooldown event with respect to reactivity control by having all the CRAs fully inserted and the boron concentration greater than that required for bypassing MSLI or raising SG levels > 40. This is a core specific boron concentration determination.

This evolution does not require any changes to plant equipment. All the systems are operated within their design limits. Accident initiators remain unaffected due to this proposed evolution.

Based on the above, this evolution does not result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the SAR.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the UFSAR? No BASIS:

The proposed evolution does not change the availability of any structure, system, or component important to safety. This evolution does not require equipment important to safety to be operated in a different manner or with a higher duty. No new failure modes were assumed in this evolution. This includes overriding the automatic closure of the startup control valves if MSLI is actuated. This renders the valves inoperable. This override does not prevent the automatic closure of the Main Feedwater Isolation Valves upon actuation of MSLI. The bases for ANO-1 Technical Specification 3.7.3 states that the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months completion time takes into account the redundancy afforded by the Main Feedwater Isolation Valve and the low probability of an event occurring during this time period that would require isolation of the Main Feedwater flow paths. In addition, the bases state that manual operation of the valves (where manual operation is not the result of a failure of a valve component) does not constitute a failure and is not assumed to be a common mode failure concern. Procedures currently exist to address this configuration.

Therefore the proposed evolution does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety previously evaluated in the UFSAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 5

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

With boron concentration able to maintain shutdown margin with RCS temperatures down to 70 °F, any unexpected adverse consequences that may be associated with this test are bounded by the current RCS overcooling and the steam line break analysis. The initial boron concentration for this test will be the concentration required to bypass the MSLI. This concentration is several hundred parts per million boron greater than the boron concentration required to perform the CRA drop test which is greater than the critical boron concentration. In addition all the CRAs are fully inserted. With respect to a steam line break inside containment, the initial steam generator inventory (mass) will be greater than what is assumed in the current analysis; however, the feedwater flow (resulting in mass addition after the break) will be significantly less and the heat source will be almost non-existent (compared to initial 100% power and subsequent decay heat power), so the full power case bounds this condition due to the lack of energy to heatup the incoming feedwater. The proposed evolution does not impact any of the assumptions used in the calculations of the dose consequences to any accident evaluated in the SAR. No new release mechanism or radiological release rate / duration were introduced based on the proposed evolution.

4. Result in more than a minimal increase in the consequences of a malfunction of a structure, Yes system, or component important to safety previously evaluated in the UFSAR? No BASIS:

Because this test does not change the mitigation strategy or eliminate equipment used to mitigate the consequences of an accident or event, the response to these events remains unchanged when compared to normal or accident operations. No unanalyzed malfunction or equipment loss is created by this activity.

Therefore, this test does not result in more than a minimal increase in the consequences of a malfunction of a structure, system or component important to safety previously in the UFSAR.

5. Create a possibility for an accident of a different type than any previously evaluated in the Yes UFSAR? No BASIS:

The proposed test does not require equipment to be operated in a different manner or with a higher duty.

All the design criteria for the equipment have been met for this test. No new failure modes that could lead to an accident of a different type were determined. No change will occur in the radiological release rate /

duration and no new release mechanics have been postulated. Therefore, this test does not create a possibility for an accident of a different type than any previously evaluated in the SAR.

6. Create a possibility for a malfunction of a structure, system, or component important to safety Yes with a different result than any previously evaluated in the UFSAR? No BASIS:

This test will not change any parameter that would affect the function of structures, systems or components important to safety. This test will require the startup control valves to be operated in manual.

ANO-1 Technical Specification 3.7.3 provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO for this condition.

There are no changes to the failure modes of the structures, systems, or components important to safety.

Based on the above discussion, this test does not create the possibility for a malfunction of a structure, system or component important to safety with a different result than any previously evaluated in the SAR.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 5 of 5

7. Result in a design basis limit for a fission product barrier as described in the UFSAR being Yes exceeded or altered? No BASIS:

This test does not impact containment. In an overcooling event, the RCS could be challenged as could the fuel. The controlling design basis limit for the RCS for this test is the cooldown rate of the steam generators. This limit will not be exceeded during the test. The fuel cladding limits will not be exceeded or altered during this test since the fuel will not be critical and, therefore, will not be generating any heat. The fuel is maintained subcritical by having all the CRAs fully inserted and sufficient boron to maintain shutdown margin even with a cooldown. Therefore none of the design basis limits for any of the fission product barriers are exceeded or altered due to this test.

8. Result in a departure from a method of evaluation described in the UFSAR used in establishing Yes the design bases or in the safety analyses? No BASIS:

No new methodology was introduced during the evaluation of this test. All evaluations and assessments associated with this test continued to use existing methodologies regardless if they are described in the SAR or not.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

ANO 50.59 Evaluation Number 13-007

10 CFR 50.59 EVALUATION FORM Sheet 1 of 4 I. OVERVIEW / SIGNATURES1 Facility: ANO-1 Evaluation # / Rev. #: 13-007 / 0 Proposed Change / Document: EC-45808 EC Markup for CALC-92-E-0103-01 to Update Room 104 Free Convection Model and Determine New Operator Actions OP-1104.027 "Battery And Switchgear Emergency Cooling System Description of Change:

Emergency chillers VCH-4A and VCH-4B and associated room coolers provide emergency cooling for the vital powered battery, DC equipment and electrical switchgear. South Electrical Room cooler VUC-14D provides cooling for room 104 with chilled water from VCH-4B. For emergency cooling, it is also necessary to open doors 49 and 62 to the Turbine Building to provide supplemental free convection room cooling since VUC-14D has insufficient capacity. Post accident actions are also credited to open these doors for free convection cooling when VUC-14D is not available due to emergent maintenance.

Previous demonstration of adequate cooling in Room 104 has been documented by GOTHIC modeling in CALC-92-E-0103-01, Rev 5, however, it has been determined that the method used to model the Turbine Building in this GOTHIC model is not correct.

Specifically, the calculation incorrectly uses two boundary conditions to non-conservatively simulate the turbine building heat sink (CR-ANO-1-2013-0495). The correct method is to model the TB as another control volume with its own pressure and flow boundary conditions.

This Activity is a markup of Calculation CALC-92-E-0103-01, Rev 5, ANO-1 Switchgear, Battery DC and Corridor 98 HVAC Evaluation to incorporate two new cases in the calculation for post accident cooling of South Electrical Room 104 using a corrected turbine building model. The calculation results show that adequate cooling of Room 104 is still provided with VUC-14D in operation and opening doors. For conditions where VUC-14D or associated chiller VCH-4B requires emergent maintenance, post accident cooling by opening doors is insufficient and additional load shedding in Room 104 is needed for free convection cooling to be adequate.

The following aspect of this activity has been deemed adverse and is evaluated herein:

This activity adds to the post-accident compensatory actions (load shedding) necessary to maintain electrical equipment Room 104 within its limiting temperature as discussed in UFSAR Section 9.7.2.1 when VUC-14D or associated chiller VCH-4B are removed from service due to emergent maintenance.

The addition of necessary steps is considered an adverse change. New post accident actions include opening MCC B-21 breakers in Room 104 and the B-21 breaker at load center B-2 in the Turbine Building and securing cabinet C579 at the breaker in Room 109. In addition, in coordination with Security, CSG will be notified to secure multiplexer RMT-07 and associated cooler VUC-21. All of these electrical loads are not safety related. These post accident actions will be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the event. All actions are taken to maintain Tech Spec operability of electrical equipment in Room 104 in response to degraded non conforming (DNC) conditions of VUC-14D or associated chiller VCH-4B.

The equipment to be manipulated by new operator actions is accessible, actions taken are relatively simple, and actions can be accomplished in a short time. New manual actions will be included in Procedure OP-1104.027. These new manual actions do not take the place of existing automatic actions.

Operators will be trained on these changes via routine training methods. Dedicated operators are maintained on shift to perform post event manual actions as needed. This change does not impact existing information displays. Actions are taken several hours after an event and adequate time is available to perform these operator actions. Adequate environmental conditions will be present at the manual action locations post accident for operator actions. Equipment required to perform these actions is identified and labeled in the field.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 2 of 4 Radiological dose assessments in areas where these manual actions are taken have been performed consistent with NUREG 0737. Per NUREG 0737, the dose rate for areas requiring infrequent access is per GDC 19, i.e. dose to personnel shall not exceed 5 rem whole body or its equivalent for the duration of the accident. Post LOCA doses from manipulation of doors and equipment in Corridor 98 and adjacent areas have been previously evaluated in CR-ANO-C-2007-0289, CA-13.

The CA-13 response noted that a reasonable estimate for maximum dose rate in Room 104 is 100 millirem/hr and outside the room (at the door), the dose rate is estimated to be 10 millirem/hr. Actions to open the breakers on B-21 would be expected to take several minutes and be well within an hour for the total time required. Opening the B-21 breaker would take a few minutes in a field of 10 millirems or less.

Therefore, the total dose to the operator would be expected to be below 100 millirem. Doses received from securing C579 in Room 109 are bounded by doses previously evaluated since the additional action is expected to take less time than actions previously evaluated in the same area (Room 109) in CA-13. Per discussion with Security, actions to secure RMT-07 and VUC-21 take place in low dose areas and are relatively simple. Doses received from CSG activities are thus negligible. It is concluded that GDC 19 dose limits of 5 rem whole body to individual operators will not be exceeded with these actions. In post-accident conditions, the Emergency Response Organization is staffed and available to manage dose and provide local dose rate information to the individuals in the field.

In conclusion, equipment to be manipulated by these actions is accessible, actions taken are relatively simple and can be accomplished in a short time, and dose consequences are expected to be within allowable limits. These new actions meet EN-OP-104 requirements are thus considered acceptable.

Because operator action is already assumed in the SAR (opening doors), and because the additional actions to be credited meet EN-OP-104 requirements, this activity meets the 10 CFR 50.59 criteria as described in response to the eight questions below.

Summary of Evaluation:

The new post-accident manual actions are acceptable and do not create an unreviewed safety question.

Is the validity of this Evaluation dependent on any other change? Yes No If Yes, list the required changes/submittals. The changes covered by this 50.59 Evaluation cannot be implemented without approval of the other identified changes (e.g., license amendment request). Establish an appropriate notification mechanism to ensure this action is completed.

Based on the results of this 50.59 Evaluation, does the proposed change Yes No require prior NRC approval?

Preparer: David MacPhee / See AS / Entergy Operations, Inc. / Design Engineering / 8/22/13 Name (print) / Signature / Company / Department / Date Reviewer: Jerry W. Howell / See AS / Entergy Operations, Inc. / Design Engineering / 8/27/13 Name (print) / Signature / Company / Department / Date OSRC: Dale E. James / ORIGINAL SIGNED BY DALE E. JAMES / 08-29-2013 Chairmans Name (print) / Signature / Date OSRC-13-037 OSRC Meeting #

1 Signatures may be obtained via electronic processes (e.g., PCRS, ER processes), manual methods (e.g., ink signature), e-mail, or telecommunication. If using an e-mail or telecommunication, attach it to this form.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 3 of 4 II. 50.59 EVALUATION Does the proposed Change being evaluated represent a change to a method of Yes evaluation ONLY? If Yes, Questions 1 - 7 are not applicable; answer only No Question 8. If No, answer all questions below.

Does the proposed Change:

1. Result in more than a minimal increase in the frequency of occurrence of an accident Yes previously evaluated in the UFSAR? No BASIS:

The new manual actions ensure electrical equipment in Room 104 will be available to mitigate accidents. Manual action steps have been evaluated against appropriate EN-OP-104 procedural criteria for operator response. This activity is unrelated to accident initiators.

2. Result in more than a minimal increase in the likelihood of occurrence of a malfunction Yes of a structure, system, or component important to safety previously evaluated in the No UFSAR?

BASIS:

Equipment in Room 104 is subject to malfunction if temperature in the room exceeds qualified limits.

The SAR currently assumes manual operator action may be required to maintain room temperature within limits post-accident. New manual actions meet EN-OP-104 guidelines for crediting operator manual action. These actions act to enhance operation of SSCs important to safety and, therefore, do not increase the likelihood of occurrence of a malfunction of a subject SSC.

3. Result in more than a minimal increase in the consequences of an accident previously Yes evaluated in the UFSAR? No BASIS:

Actions taken per this activity ensure that the electrical equipment in Room 104 will be adequately cooled in the event of an accident. Operator dose from actions taken outside the control room are expected to be well within dose limits per GDC-19 and NUREG 0737 and the increase in dose is considered minimal. Since this electrical equipment will continue to adequately mitigate accident events and dose effects are minimal, these actions will not result in more than a minimal increase in the dose consequences of an accident previously evaluated.

4. Result in more than a minimal increase in the consequences of a malfunction of a Yes structure, system, or component important to safety previously evaluated in the No UFSAR?

BASIS:

This activity does not affect possible malfunctions of equipment used for mitigating accidents which may occur for reasons other than a loss of cooling in Room 104. Non-safety related electrical loads that are shed in Room 104 are not credited for accident mitigation. Operator actions ensure proper electrical cooling in Room 104 and potential added operator dose received as a result of a failure of VUC-14D or VCH-4B is considered minimal. Therefore, this activity will not result in more than a minimal increase in the consequences of possible malfunctions of SSC.

EN-LI-101-ATT-9.1, Rev. 9

10 CFR 50.59 EVALUATION FORM Sheet 4 of 4

5. Create a possibility for an accident of a different type than any previously evaluated in Yes the UFSAR? No BASIS:

The additional operator actions mitigate the consequences of an accident by ensuring adequate cooling is provided for electrical equipment in Room 104 used to mitigate accidents. Manual action steps have been evaluated against appropriate EN-OP-104 procedural criteria for operator response. This activity creates no new accident initiators.

6. Create a possibility for a malfunction of a structure, system, or component important to Yes safety with a different result than any previously evaluated in the UFSAR? No BASIS:

The new operator actions do not introduce the possibility for a malfunction of an SSC with a different result because it does not introduce a new failure mode. The combination of passive cooling provided by opening doors 49 and 62 and shedding of electrical heat loads in Room 104 provide an adequate operating environment for proper equipment operation.

7. Result in a design basis limit for a fission product barrier as described in the UFSAR Yes being exceeded or altered? No BASIS:

This change makes no physical changes to fission product barriers. New operator actions support proper operation of SSCs that maintain fission product barriers. Therefore, this activity does not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered

8. Result in a departure from a method of evaluation described in the UFSAR used in Yes establishing the design bases or in the safety analyses? No BASIS:

This 10 CFR 50.59 evaluation is concerned with changes to how design functions are performed or controlled. The GOTHIC methodology is the same as used in previous analyses. The methodology used in the markup to CALC-92-E-0103-01, rev 5 is not discussed in the SAR. There are no changes to evaluation methodologies used in establishing the design bases or in the safety analyses.

If any of the above questions is checked Yes, obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure EN-LI-103.

EN-LI-101-ATT-9.1, Rev. 9

Attachment 2 to 0CAN021403 ANO-1 and ANO-2 Commitment Change Summary Report to 0CAN021403 Page 1 of 32 ANO-1 and ANO-2 Commitment Change Summary Report Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date The NRC inspectors found that the Emergency Operations Facility (EOF) This commitment has been in EOF Activation emergency ventilation system had been place for greater than 2 years Checklist - turned off during activation of the EOF, and and is well established in normal Communication of that the EOF Radiation Protection (RP) processes or otherwise P1455 07/27/90 11/07/12 Ventilation Changes supervisor was not aware that the system embedded in site procedures.

and Evaluation of had been shut off until questioned by an Therefore, tracking this action as Dosimetry inspector. Also, EOF personnel were not a commitment is no longer issued personal dosimetry as required by necessary. Commitment closed.

procedure.

This commitment has been in place for greater than 2 years and is well established in normal Examples of incorrect and delayed processes or otherwise P1457 07/27/90 11/07/12 EOF Status Board information on status boards in the EOF embedded in site procedures.

constitutes an exercise weakness.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

A means of determining release rate This commitment has been in information will be available in the Technical place for greater than 2 years Support Center (TSC) with the installation of and is well established in normal Install RDACS a terminal for the Radiological Dose processes or otherwise P1458 07/27/90 11/08/12 Terminal in the TSC Assessment Computer system (RDACS). embedded in site procedures.

Technical personnel will be trained and Therefore, tracking this action as located in the TSC to interrogate RDACS a commitment is no longer and interpret this information. necessary. Commitment closed.

to 0CAN021403 Page 2 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in Relocation of RP & Radwaste Manager place for greater than 2 years Relocation of RP & from the OSC to the TSC provides more and is well established in normal Radwaste Manager readily available RP expertise to the TSC processes or otherwise P1460 07/27/90 11/07/12 from the Operations staff and facilitates the flow of radiological embedded in site procedures.

Support Center information to the TSC. First line Therefore, tracking this action as (OSC) to the TSC supervision of the onsite monitoring teams a commitment is no longer remains with the RP supervisor in the OSC.

necessary. Commitment closed.

This commitment has been in The new ERO position of Accident place for greater than 2 years New Emergency Assessment Manager has responsibility for and is well established in normal Response oversight of job prioritization with emphasis processes or otherwise P1461 07/27/90 11/07/12 Organization (ERO) on long-term aspects of accident embedded in site procedures.

Position - Accident assessment and recovery (the Engineering Therefore, tracking this action as Assessment Manager Manager's responsibilities focus on a commitment is no longer immediate recovery efforts.)

necessary. Commitment closed.

Additional technical resources have been allocated to support the direction ED&C function in the Control Room (CR), the TSC, This commitment has been in and the EOF. This support includes a EAL Reviewer place for greater than 2 years procedural task entitled Emergency Action Position to Support and is well established in normal Level (EAL) review, with the task being the Emergency processes or otherwise P1464 07/27/90 11/07/12 staffed by Senior Reactor Operators in Direction and Control embedded in site procedures.

support of the Shift Operations Supervisor (ED&C) function in Therefore, tracking this action as (SOS), TSC Director, and the EOF Director.

ERO a commitment is no longer The purpose of this assignment is to necessary. Commitment closed.

formulate recommendations to the individual with ED&C regarding emergency classification.

to 0CAN021403 Page 3 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Quarterly Emergency System will be tested quarterly once processes or otherwise P1734 03/27/91 11/07/12 Notification System installed. embedded in site procedures.

(ERDS) Testing Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal ERDS Activation at ERDS will be initiated within one hour of processes or otherwise P1735 03/27/91 11/08/12 Alert or Higher declaration of an Alert, or higher, embedded in site procedures.

Emergency Class emergency class.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Licensees are requested to make and is well established in normal Emergency modifications to facilities and procedures to processes or otherwise P2687 09/23/91 11/07/12 Telecommunications ensure compliance with NRC regulations in embedded in site procedures.

Upgrade 10 CFR 50.47(b)(6) and 10 CFR 50, Therefore, tracking this action as Appendix E, IV.E.9.d.

a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Implement a Business Plan with the main Enhance Safety and processes or otherwise P2935 03/14/90 01/22/13 objective to enhance overall safety and Performance embedded in site procedures.

performance at ANO.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 4 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date Although cooling water flow will continue to be monitored via Develop thermal performance procedures overall SW flow testing, specific from initial test program documents to air/water flow testing through establish retesting methods. Develop room coolers VUC-7A/B/C will no P2967 programs for inspection of pumps seal/lube Thermal Performance longer be performed since these 01/18/90 12/03/12 oil coolers. Develop trending program for P2968 Testing coolers are not required for area heat exchanger performance. Specifically, equipment to perform the develop or revise the appropriate ANO-1 specified safety functions.

procedures for retesting of the Service Therefore, the commitment for Water (SW) heat exchangers.

air flow testing of VUC-7A/B/C is removed.

This commitment has been in place for greater than 2 years and is well established in normal Protective Clothing Provide administrative controls to ensure processes or otherwise P3333 08/20/92 11/08/12 for Offsite Monitoring that in future drills the off-site monitoring embedded in site procedures.

Teams teams carry protective clothing.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in Revise procedures to provide guidelines for place for greater than 2 years conducting offsite authority briefings. and is well established in normal Guidelines for Briefings will furnish concise and useful processes or otherwise P3334 08/20/92 11/07/12 Briefing Offsite information, and identify sources within the embedded in site procedures.

Authorities ERO for information not immediately Therefore, tracking this action as available during the briefing. a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 5 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date Clarify instructions for: 1) mandatory information to be provided in initial notifications to the NRC Operations Center,

2) log requirements of notification times as verified by the recipient, and 3) notifications and updates when both units are affected.

Remedial training for Notifications Communicators and Shift Communicators. This commitment has been in This training will include the following place for greater than 2 years Remedial Training objectives: 1) demonstrate knowledge of and is well established in normal and Instructions on the required message content and the processes or otherwise P3335 08/20/92 11/08/12 Use of Computerized ability to transmit initial notification of an embedded in site procedures.

Notifications System emergency class to the NRC, 2) Therefore, tracking this action as demonstrate knowledge of the proper a commitment is no longer protocol for message content during events necessary. Commitment closed.

which affect both units, 3) demonstrate the ability to properly construct messages which convey a significant change in the status of the emergency, and 4) demonstrate knowledge of the correct logging procedure with respect to the notification times to offsite authorities.

This commitment has been in place for greater than 2 years and is well established in normal Produce a set of dose assessment Dose Assessment processes or otherwise P3742 02/05/93 11/08/12 instructions and guidelines that incorporate Procedures embedded in site procedures.

effective human factor techniques.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 6 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Emergency Kit Conduct Emergency Kit equipment processes or otherwise P4067 09/28/82 11/07/12 Operational Tests operational tests embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Personnel Monitoring Personnel will be monitored when entering processes or otherwise P4078 03/15/83 11/08/12 at EOF the EOF. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Communications and Provisions will be added to the emergency and is well established in normal Recordkeeping in response training program procedure for processes or otherwise P4109 12/09/83 11/08/12 Radiation Monitoring demonstrating communications and embedded in site procedures.

Drills recordkeeping capabilities. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Integrated Doses Provide integrated dose projections and to processes or otherwise P4139 03/15/83 11/08/12 Needed to Determine generate offsite Protective Action embedded in site procedures.

Protective Actions Recommendations (PARs).

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 7 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Establish Rumor A Rumor Control Coordinator is established processes or otherwise P4140 03/15/83 11/08/12 Control Coordinator to monitor all rumors. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years An RM-14 radiation monitor is available in and is well established in normal Continuous Radiation the onsite TSC kit. The RP Superintendent processes or otherwise P4141 03/15/83 11/07/12 Monitoring in TSC will ensure the monitor is placed in service embedded in site procedures.

in the TSC. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years A communicator/logger will be assigned by and is well established in normal Communicator the RP OSC Supervisor upon activation of processes or otherwise P4143 03/15/83 11/07/12 Assignment the onsite radiological monitoring section of embedded in site procedures.

the Emergency Radiation Team. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in The Emergency Radiation Team leader will place for greater than 2 years track team members and team assignments and is well established in normal OSC Radiological in addition to maintaining records in a processes or otherwise P4192 09/28/82 11/07/12 Status tabbed notebook. Instructions to post embedded in site procedures.

radiological survey results in the TSC and Therefore, tracking this action as OSC will be provided. a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 8 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal TSC Personnel The RP Superintendent will ensure that processes or otherwise P4193 03/15/83 11/07/12 Thermoluminescent personnel dosimeters are distributed to the embedded in site procedures.

Dosimeters TSC staff.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Provide more definitive guidance relating to and is well established in normal TSC and OSC the conditions which warrant the processes or otherwise P4235 08/01/86 11/07/12 Control Points establishment of control points for TSC and embedded in site procedures.

OSC activities. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Maintain and document continuous and is well established in normal OSC, TSC, and EOF accountability of onsite personnel at the processes or otherwise P4405 08/01/86 11/07/12 Continuous start of an emergency (i.e., the evacuation embedded in site procedures.

Accountability of non-essential personnel) Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal State and NRC Include requirement for NRC notification processes or otherwise P4284 06/14/85 11/08/12 Notifications immediately after State notification. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 9 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Provide additional guidance to RP and is well established in normal personnel in evaluating the radiological Control Room processes or otherwise P4874 10/17/86 11/07/12 habitability of the CR and continuously Habitability embedded in site procedures.

advising the SOS of the status of Therefore, tracking this action as radiological conditions.

a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal P4978 Incorporate the assigning of an individual as TSC and EOF Status processes or otherwise 05/20/81 11/07/12 a status board communicator in the TSC P4983 Board embedded in site procedures.

and EOF.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment is related to an exception to American Society of Mechanical Engineers (ASME)

Section XI 1974 Edition, 1975 Summer Addenda for the 1st ten year ISI interval. The ANO Visual inspections for leakage will be Reactor Coolant Inservice Inspection (ISI)

P4993 06/22/89 12/18/13 conducted during the hydrostatic pressure Pump programs are currently in the 4th test required by IWB-5000.

ten year interval and have been updated to the ASME Section XI 2001 Edition, 2003 Addenda.

This commitment was applicable to the 1st ten year ISI interval only and is, therefore, closed.

to 0CAN021403 Page 10 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Enhance training and procedures to aid field and is well established in normal Field Monitoring monitoring teams in determining whether or processes or otherwise P5013 04/18/86 11/07/12 Teams not a specific sample has been taken while embedded in site procedures.

immersed in a radioactive plume. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Revise procedure change process to Master Test Control processes or otherwise P5144 10/06/89 01/22/13 include determination of whether the MTCL List (MTCL) embedded in site procedures.

also requires change.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and was written to perform an Inspect the vessel head penetrations for inspection of a mechanical Control Rod Drive leakage during each refueling outage and, connection on the ANO-1 P5378 1/02/91 12/18/13 Mechanism (CRDM) as subsequent CRDMs are disassembled, Reactor head CRDM flange.

Seal new gaskets will be installed and the studs Tracking this commitment is no torqued using the ultrasonic method.

longer necessary as it is a standard function of the ANO boric acid program.

to 0CAN021403 Page 11 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in Incorporate QC hold points to further ensure place for greater than 2 years that maintenance and testing is performed and is well established in normal Pressurizer Code on the correct valve, critical internal settings processes or otherwise P6453 10/30/87 01/02/13 Safety Valves (adjusting ring positions) are achieved, embedded in site procedures.

pressure bolting is properly torqued, and Therefore, tracking this action as critical tolerances are achieved. a commitment is no longer necessary. Commitment closed.

This commitment was associated with licensed Enhance controls related to accelerated Operator Operator training only. This P7381 07/15/88 01/02/13 requalification training requirements and Requalification commitment reference is, associated documentation.

therefore, removed from non-licensed training procedures.

This commitment has been in place for greater than 2 years and is well established in normal Containment Spray Simulate the use of the Containment Spray processes or otherwise P7437 04/14/89 11/07/12 Simulation pump during ERO drill. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Address (1) the scope of authority that will and is well established in normal be delegated to the EOF Director and Delegation of processes or otherwise P7553 07/19/85 11/07/12 (2) the provisions for support to the Authority embedded in site procedures.

Emergency Coordinator by staff located at Therefore, tracking this action as the EOF during the alert.

a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 12 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years NRC to be notified of any event that may and is well established in normal P7596 04/16/79 endanger the health and safety of the public processes or otherwise 11/08/12 NRC Notification P7706 04/24/79 or that may have potential of significant embedded in site procedures.

public interest. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal processes or otherwise embedded in site procedures.

Validity of actuations are determined prior to overriding Overriding Safety Require Shift Manager (SM) notification components. Overriding P7617 04/11/79 12/18/13 Systems prior to override of Engineered Safeguards. actuated components is directed by procedure and is directed by the Control Room Supervisor (CRS) / SM. Overriding components due to component failures requires CRS/SM permission prior to component operation. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal processes or otherwise Provided enhanced guidance for conducting embedded in site procedures. In P7683 05/07/91 12/18/13 Hydrostatic Testing hydrostatic tests on systems, components, addition, ISI programs have and partial systems.

since been updated to ASME Code Section XI 2001 Edition and 2003 Addenda, which address these requirements.

to 0CAN021403 Page 13 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Proceduralize a specified lubricant to be processes or otherwise P7736 04/21/83 08/15/12 Work Instructions used for their applicable component or embedded in site procedures.

subcomponent.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Record the necessary information to and is well established in normal calculate a projected total dose and processes or otherwise P7879 04/13/87 11/08/12 Projected Total Dose compare the total dose value to PAR embedded in site procedures.

guidelines. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Clarify the turnover of offsite notifications processes or otherwise P7899 05/15/87 11/07/12 Turnover of ED&C and PARs. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Procedure Change Enhance procedure change/development processes or otherwise P8255 06/12/79 01/22/13 Process processes. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 14 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Revise dose projection procedures to processes or otherwise P8878 04/18/86 11/08/12 Dose Projection contain correction factors derived from field embedded in site procedures.

team radiation measurements.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Enhance procedures to relieve Operators of processes or otherwise P8882 03/06/87 11/07/12 Operator Duties other duties during an emergency. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Assign EOF personnel to communicate with processes or otherwise P8886 03/06/87 11/07/12 Communications NRC during emergencies. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

Local radio stations will be monitored This commitment has been in (rumor control). Company media place for greater than 2 years P9010 representative to serve as communications and is well established in normal Emergency link between Emergency Coordinator and processes or otherwise P9141 03/15/83 11/08/12 Communications Rumor Control Coordinator. Internal embedded in site procedures.

P9142 Communications Coordinator will prepare Therefore, tracking this action as exciter updates & AP&L today messages a commitment is no longer for all employees. necessary. Commitment closed.

to 0CAN021403 Page 15 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Specific procedures are needed for the and is well established in normal Emergency operation of the media center, preparation processes or otherwise P9134 04/15/85 11/08/12 Communications and approval of releases, and conduct of embedded in site procedures.

briefings. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Rumor Control Coordinator to distribute Emergency processes or otherwise P9143 03/15/83 11/08/12 approved info releases to business offices Communications embedded in site procedures.

via customer service teleprocessing system.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency System of notifying business offices and processes or otherwise P9144 03/15/83 11/08/12 Communications district offices (rumor control). embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal The Incident Response Center makes all Emergency processes or otherwise P9145 03/15/83 11/08/12 news releases available to Rumor Control Communications embedded in site procedures.

Coordinator.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 16 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Emergency Communications Superintendent to processes or otherwise P9146 03/15/83 11/08/12 Communications determine action to respond to rumor. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal (Rumor Control) request to be time dated Emergency processes or otherwise P9147 03/15/83 11/08/12 and forwarded to the Incident Response Communications embedded in site procedures.

Director.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Rumor Control Coordinator can notify Emergency processes or otherwise P9148 03/15/83 11/08/12 Communications Superintendent by phone Communications embedded in site procedures.

or fax.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal A message is to be distributed to all Emergency processes or otherwise P9149 03/15/83 11/08/12 employees advising them to report all Communications embedded in site procedures.

rumors to Rumor Control Coordinator.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 17 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Rumor Control Coordinator to provide Emergency processes or otherwise P9150 03/15/83 11/08/12 company wide rumors to Communications Communications embedded in site procedures.

Superintendent using standard form.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Little rock area TV stations will be processes or otherwise P9151 03/15/83 11/08/12 Communications monitored (rumor control). embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Provide guidance to first aid team to obtain and is well established in normal Emergency assistance from control room(s) for processes or otherwise P9152 01/12/84 11/07/12 Communications assistance in locating scene of emergency embedded in site procedures.

as needed. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Provide offsite monitoring data exchange and is well established in normal Emergency from TSC to Arkansas Department of processes or otherwise P9459 05/25/84 11/07/12 Procedures Health (ADH) prior to Emergency Control embedded in site procedures.

Center (ECC) staffing. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 18 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Require an approval signature by Protective Action processes or otherwise P9461 05/25/84 11/08/12 authorized individual prior to issuance of Recommendations embedded in site procedures.

PARs.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Provide adequate assurance of prompt processes or otherwise P9466 09/10/82 11/08/12 ERO Staffing response time for ERO staffing under embedded in site procedures.

normal circumstances.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Include Communications Operators and a processes or otherwise P9475 04/15/93 11/07/12 TSC Staffing Status Board Keeper in the TSC staff. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Delineate responsibilities for report processes or otherwise P9589 08/12/83 11/08/12 Emergency Reporting preparation and submittal of unusual embedded in site procedures.

events.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 19 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Emergency Include evacuation time estimates and processes or otherwise P9755 01/12/84 11/08/12 Procedures checklist in procedure. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Protective Action processes or otherwise P9875 11/25/83 11/08/12 Clarify the responsibility for making PARs.

Recommendations embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Maintain direct access between the NRC Emergency processes or otherwise P10420 12/19/80 11/07/12 and individual responsible for making offsite Communications embedded in site procedures.

dose projections.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Provide a communication link with the processes or otherwise P10421 12/19/80 11/08/12 Communications National Weather Service. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 20 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Provide identification of contact positions in Emergency processes or otherwise P10455 12/19/80 11/08/12 the ERO and procedures for establishing Communications embedded in site procedures.

contact.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency processes or otherwise P10758 06/30/83 11/08/12 Verify follow-up message capability.

Communications embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Verify sufficient number of personnel Emergency processes or otherwise P10760 06/30/83 11/07/12 available to maintain 24-hour coverage as Communications embedded in site procedures.

liaison between ANO and the ADH Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Verify only one individual (at a time) is Protective Action processes or otherwise P10766 06/30/83 11/08/12 designated with the authority to issue Recommendations embedded in site procedures.

PARS.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 21 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Emergency Update emergency phone numbers on a processes or otherwise P10767 06/30/83 11/08/12 Communications quarterly basis. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Corrections of erroneous performances will processes or otherwise P10769 06/30/83 11/08/12 Emergency Training be made by the drill instructor. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years Annually drills will be conducted which and is well established in normal include the analysis of in-plant liquid processes or otherwise P10770 06/30/83 11/08/12 Emergency Training samples with actual elevated radiation embedded in site procedures.

levels. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Add provisions for communications and processes or otherwise P10771 06/30/83 11/08/12 Communications record keeping. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 22 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Reflect NRC and Federal Emergency and is well established in normal Management Agency requirements for processes or otherwise P10772 06/30/83 11/08/12 Emergency Training conduct of radiological emergency embedded in site procedures.

exercises in procedure. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Develop procedures for rumor control and processes or otherwise P10783 04/15/85 11/07/12 Communications the release of information to public. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Provide adequate assurance of prompt processes or otherwise P10823 10/21/82 11/08/12 Response response time for ERO staffing. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Provide method for atmospheric stability Emergency processes or otherwise P10831 12/20/82 11/08/12 class determination when not available via Procedures embedded in site procedures.

local sources.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 23 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Emergency processes or otherwise P10833 05/07/82 11/08/12 Establish an annual EAL review.

Procedures embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Ensure availability of off-site monitoring processes or otherwise P10843 04/08/82 11/08/12 Preparedness vehicle. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Provide explicit recall instructions for ERO processes or otherwise P10847 10/19/82 11/08/12 Preparedness staff augmentation. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Utilize state phones continuously during an Emergency processes or otherwise P10855 12/20/82 11/08/12 emergency, and local office phones as Communications embedded in site procedures.

needed.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 24 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Ensure the continuity of dose projection and and is well established in normal decision making during the Emergency processes or otherwise P10858 12/20/82 11/07/12 evacuation/relocation of TSC personnel to Procedures embedded in site procedures.

the ECC, and for ECC personnel to the Therefore, tracking this action as backup ECC.

a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Include on-the-job training program for the processes or otherwise P10860 12/20/82 11/08/12 Emergency Training emergency planning coordinators. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Address methods for plant staff to provide processes or otherwise P10861 12/20/82 11/08/12 Emergency Training input for Emergency Plan (EP) embedded in site procedures.

improvement.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Continue practice of training EP individuals processes or otherwise P10872 05/07/82 09/19/12 Emergency Training for state-of-the-art knowledge in the field embedded in site procedures.

of emergency preparedness.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 25 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Incorporate all applicable emergency call and is well established in normal Emergency lists into one notification procedure for use processes or otherwise P10936 06/16/81 11/08/12 Communications by the Shift Administrative Assistant during embedded in site procedures.

emergencies. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Revise Channel Functional Test procedures processes or otherwise P11001 04/08/81 08/15/12 Channel Test to compare as-found conditions with embedded in site procedures.

allowable values.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Provide a checklist for revisions or Procedure Change processes or otherwise P11069 05/19/81 01/22/13 procedures superseding or replacing Process embedded in site procedures.

another procedure.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Clarify guidance on radiological controls as processes or otherwise P14029 10/11/94 11/08/12 Radiological Controls related to responding to medical embedded in site procedures.

emergencies.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 26 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Document that spare self-contained Emergency processes or otherwise P14103 12/16/94 11/07/12 breathing apparatus bottles have been Preparedness embedded in site procedures.

verified to contain 2000 psi of air pressure.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in Perform annual review of the EP and place for greater than 2 years implementing procedures to verify that and is well established in normal changes that have occurred which impact processes or otherwise P14145 01/01/95 11/08/12 Emergency Plan the plan and/or procedures have been embedded in site procedures.

incorporated (submit copy of revised E-plan Therefore, tracking this action as to licensing for submittal to NRC). a commitment is no longer necessary. Commitment closed.

The hold point is revised to 12%

power. During power ascension the Core Protection Calculator ASI auxiliary trip is enabled when the raw neutron flux average power reaches 17%. The original commitment provided Establish specific hold point requiring significant power margin to the ANO-2 Startup stabilizing power at approximately 10% until trip enable threshold to ensure P14619 09/27/95 10/04/12 Procedures the Axial Shape Index (ASI) is verified to be ASI was controlled below trip less than the trip setpoint. setpoint. The revised commitment provides additional operating flexibility while still ensuring adequate power margin to the trip enable threshold. The intent of the original commitment remains satisfied. Commitment revision.

to 0CAN021403 Page 27 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date The ANO program is modified to address valves outside the Joint Owners Group effort to use a combination of industry Implement a motor operated valve (MOV) guidance, engineering analysis periodic verification program in accordance P15200 11/15/96 04/25/12 Verification Program and in-situ testing to verify with the requirements of Generic Letter (validate) the capability of the (GL) 96-05.

MOVs to perform the intended function. The intent of the original commitment remains satisfied. Commitment revision.

This commitment has been in place for greater than 2 years Require verbatim transmission of and is well established in normal Emergency information from form 1903.011Y to NRC processes or otherwise P15339 03/03/97 11/08/12 Communications using the Emergency Notification System embedded in site procedures.

and require follow-up fax to the NRC. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Emergency Ensure Shift Superintendent review of the processes or otherwise P15456 05/14/97 11/08/12 Procedures plant evacuation checklist. embedded in site procedures.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 28 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years Establish guidance for maintenance and is well established in normal Temporary Alteration planners and operations liaisons specifically processes or otherwise P15859 02/25/98 01/22/13 Process related to applicable modes in which a embedded in site procedures.

temporary alteration may be utilized. Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Ensure effects of commitment Implementation of processes or otherwise P15862 02/25/98 01/22/13 implementation are evaluated as part of Commitments embedded in site procedures.

procedure approval process.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Revise the sampling procedure to address Environmental processes or otherwise P15976 04/30/98 01/31/13 job orders, sample tracking, and sample Sampling embedded in site procedures.

storage time.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in Address format consistency, radiological place for greater than 2 years release information, separation and is well established in normal Emergency requirements, administrative dose rate call processes or otherwise P16218 11/09/98 11/08/12 Procedures back information, and as low as reasonably embedded in site procedures.

achievable (ALARA) in the OSC team Therefore, tracking this action as briefing. a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 29 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years and is well established in normal Develop an emergency entry electronic Emergency processes or otherwise P16219 11/09/98 11/08/12 dosimeter alarm setpoint process that Procedures embedded in site procedures.

represents expected area dose rates.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

This commitment has been in place for greater than 2 years and is well established in normal Severe Accident Implement Severe Accident Management processes or otherwise P16243 12/14/98 11/07/12 Management Guidelines (SAMG) in accordance with the embedded in site procedures.

Guidelines requirements of NEI-91-04.

Therefore, tracking this action as a commitment is no longer necessary. Commitment closed.

to 0CAN021403 Page 30 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment has been in place for greater than 2 years.

Since the time that B&W letter No. APL-85-349 was issued in June of 1985, the frequency of water hammer events in the industry has decreased significantly as documented in NRC IN 91-50. The ANO-1 EFW riser piping successfully operated without failure for approximately 31 years and was replaced in 2005 during the Perform surface exams and visual steam generator replacement inspection of Emergency Feedwater (EFW) project. The EFW piping has P16456 04/29/99 01/21/13 Water Hammer riser welds in accordance with Babcock & been inspected in past outages Wilcox (B&W) letter No. APL-85-349. with satisfactory results. Water hammer events in the ANO EFW system have not been a significant issue. NSSS vendor AREVA, as well as the ANO owners group representative for B&W plants were not aware of any recent water hammer or cracking issues in the EFW /

Auxiliary Feed Water systems in B&W plants. Therefore, tracking this action as a commitment is no longer necessary.

Commitment closed.

to 0CAN021403 Page 31 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date Remove reference to Post Accident This commitment has been in Sampling System (PASS) in the EP and place for greater than 2 years SAMG procedures, and incorporate and is well established in normal radiological dose rate estimates into processes or otherwise P16724 07/14/99 11/08/12 Elimination of PASS appropriate procedures. Establish embedded in site procedures.

consistent terminology in EP procedures Therefore, tracking this action as concerning cladding failure, fuel failure, and a commitment is no longer fuel overheating. necessary. Commitment closed.

This commitment has been in place for greater than 2 years Develop, implement, and maintain and is well established in normal contingency plans for obtaining and processes or otherwise P16725 07/14/99 11/08/12 Elimination of PASS analyzing highly radioactive samples of embedded in site procedures.

reactor coolant, the containment sump, and Therefore, tracking this action as containment atmosphere.

a commitment is no longer necessary. Commitment closed.

P17635 P17636 P17637 P17638 This commitment has been in place for greater than 2 years P17639 and is well established in normal P17640 Revise appropriate procedures to assure processes or otherwise 01/07/03 11/06/12 Access Authorization compliance with NRC Order dated P17644 embedded in site procedures.

January 7, 2003.

Therefore, tracking this action as P17645 a commitment is no longer P17646 necessary. Commitment closed.

P17648 P17649 P17650 to 0CAN021403 Page 32 of 32 Date of Original Changed Number Short Title Original Commitment Justification of Change Commitment Date This commitment is associated with an AOT extension that could Establish administrative controls to ensure only be applied during operating one train of Containment Spray System cycles 19 and 20, which have One-Time Extension (CSS) and one train of Containment Cooling P18463 09/19/05 8/16/12 long passed. Since the AOT of CSS TS AOT System will be available during the extension is no longer valid, extended CSS Technical Specification (TS) tracking of this commitment is no allowable outage time (AOT).

longer necessary. Commitment closed.

0CAN021403, Units 1 and 2 - 10 CFR 50.59 Summary Report and Commitment Change Summary Report

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0CAN021403, Units 1 and 2 - 10 CFR 50.59 Summary Report and Commitment Change Summary Report

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