1CAN111302, Response to Request for Additional Information ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441)

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Response to Request for Additional Information ANO-1 Adoption of TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441)
ML13319A877
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 11/14/2013
From: Jeremy G. Browning
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN111302, BAW-2441 TSTF-431, Rev 3
Download: ML13319A877 (19)
v • d • e


Text

s Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One 1CAN111302 November 14, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information ANO-1 Adoption of TSTF-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)"

Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. Entergy letter dated March 26, 2013, License Amendment Request -

Adoption of Technical Specification Task Force (TSTF)-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)"

(1CAN031306) (ML13085A282)

2. NRC email dated October 28, 2013, Arkansas Nuclear One, Unit 1 - RAI Related to the Adoption of TSTF-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)" (TAC No. MF1182)

(ML13301A675)

Dear Sir or Madam:

By email dated October 28, 2013 (Reference 2), the NRC requested additional information (RAI) associated with the Entergy Operations, Inc. (Entergy) request to amend the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TS) to incorporate the NRC-approved TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441) (Reference 1).

Enclosed is Entergys response to the RAI.

With respect to the original Entergy request (Reference 1), changes proposed in this letter have been evaluated and Entergy has determined that the changes do not invalidate the assessment of the no significant hazards consideration included in the Reference letter.

In accordance with 10 CFR 50.91(b)(1), a copy of this application is being provided to the designated Arkansas state official.

No new commitments have been identified in this letter.

1CAN111302 Page 2 of 2 If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 14, 2013.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/dbb Attachments:

1. Response to Request for Additional Information - ANO-1 TSTF-431 Adoption
2. Replacement Markups of Technical Specification and Technical Specification Bases Pages
3. Replacement Clean (Revised) Technical Specification Pages 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. Kaly Kalyanam 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 1CAN111302 Response to Request for Additional Information ANO-1 TSTF-431 Adoption to 1CAN111302 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ANO-1 TSTF-431 Adoption By email dated October 28, 2013 (Reference 2), the NRC requested additional information (RAI) associated with the Entergy Operations, Inc. (Entergy) request to amend the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TS) to incorporate the NRC-approved TSTF-431, Revision 3, Change in Technical Specifications End States (BAW-2441) (Reference 1). The following includes the NRC RAI, followed by the Entergy response.

Background Provided in NRC RAI The licensees application proposes changes to end-states associated with several of its TS Limiting Conditions for Operation (LCOs) as listed in the application. During review of the application, the Staff noticed a concern regarding changes to four of the specific LCOs as below:

LCO 3.8.1, AC Sources-Operating, (REQUIRED ACTION F.2),

LCO 3.8.4, DC Sources - Operating, (REQUIRED ACTION B.2),

LCO 3.8.7, Inverters-Operating, (REQUIRED ACTION B.2), and LCO 3.8.9, Distribution Systems - Operating, (REQUIRED ACTION D.2),

For these LCOs, if the required actions and associated completion times cannot be met, ANOs current TSs prescribe Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The licensees proposed change would modify the end-state change from Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee does not propose any change to MODE 3s Completion Time requirement.

The staff is concerned that upon implementation of the proposed end state changes in these LCO Conditions, when the plant enters in that Condition, plant operations will be placed in Mode 3 AND Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per the revised REQUIRED ACTION B.2, F.2 or D.2.

Since there is no change in the MODE 3s Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, both (3 and 4) Modes change action would have to be completed within the same 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time clock, which seems to be unusual. In addition, it may create confusion for operators and inspectors.

For instance, if the licensee takes most of the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to transition the plant into Mode 3, there may be insufficient time remaining in the REQUIRED ACTION Completion Time to complete the transition to Mode 4.

Standard Technical Specifications (STS, NUREG-1432 Revision 4), for these LCO Conditions, typically specify a Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Mode 3 and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Mode 4 change.

RAI The Staff requests the licensee to provide technical basis for having simultaneous Completion Times for Modes 3 and 4. As mentioned above, the STS allow up to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> for such Modes change in an orderly fashion.

to 1CAN111302 Page 2 of 2 The regulations under 10 CFR 50.36 (c)(2)(i) state that Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility (emphasis added). When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. The licensees proposed remedial action Completion Time provides a potentially confusing expectation on operators, and needs clarification or modification.

Entergy Response The 12-hour Completion Time allowance to reach Mode 3 is the original ANO-1 licensing basis for the subject TSs, which was retained during conversion of the ANO-1 TSs to the STS in 2001. However, in light of the 12-hour Completion Time to enter Mode 4 associated with adoption of TSTF-431, Entergy agrees that a potential human factors concern may result with a 12-hour Completion Time for entry into both Mode 3 and Mode 4. Therefore, Entergy requests the subject Completion Times associated with entry into Mode 3 be revised to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Requiring entry to Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in lieu of the current 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a more restrictive change.

However, this change will provide greater consistency with the majority of other ANO-1 TSs where Conditions and Required Actions are not met, including LCO 3.0.3, which requires prompt shutdown when one or more safety functions are not met. Therefore, revising the subject Completion Times to require entry to Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> does not create an unreasonable challenge to the plant or station Operators. Based on this assessment, the proposed changes do not invalidate the regulatory analysis or environmental consideration included in Sections 3.0 and 4.0, respectively, of the original amendment request (Reference 1).

In light of the above, new markups of the affected TS and TS Bases pages are included in of this letter and clean (revised) TS pages are included in Attachment 3 of this letter. Entergy requests the respective TS and TS Bases pages of the original TS amendment request (Reference 1) be replaced with the attached pages.

REFERENCES

1. Entergy letter dated March 26, 2013, License Amendment Request - Adoption of Technical Specification Task Force (TSTF)-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)" (1CAN031306) (ML13085A282)
2. NRC email dated October 28, 2013, Arkansas Nuclear One, Unit 1 - RAI Related to the Adoption of TSTF-431, Revision 3, "Change in Technical Specifications End States (BAW-2441)" (TAC No. MF1182) (ML13301A675)

Attachment 2 to 1CAN111302 Replacement Markups of Technical Specification and Technical Specification Bases Pages

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Be in MODE 3. 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> Associated Completion Time of Condition A, B, C, AND D, or E not met.

F.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 45. 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br /> G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power 7 days availability for each required offsite circuit.

SR 3.8.1.2 ------------------------------NOTE--------------------------------

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each DG starts from standby conditions and, 31 days in 15 seconds achieves ready-to-load conditions.

SR 3.8.1.3 MOVED TO NEXT PAGE ANO-1 3.8.1-1 Amendment No. 215,

DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 Both DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical power A.1 Restore DC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> Associated Completion Time not met. AND B.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 45. 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br /> SURVEILLANCES MOVED TO NEXT PAGE ANO-1 3.8.4-1 Amendment No. 215,xxx,

Inverters - Operating 3.8.7 CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> associated Completion Time not met. AND OR B.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable Two or more of the four when entering Mode 4.

inverters required by LCO -------------------------------------- 3.8.7.a and LCO 3.8.7.b inoperable. Be in MODE 45. 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br /> C. Two or more of the four C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inverters required by LCO 3.8.7.a and AND LCO 3.8.7.b inoperable.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and 7 days alignment to associated 120 VAC buses RS1, RS2, RS3, and RS4.

ANO-1 3.8.7-2 Amendment No. 215,230,

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Two AC, DC, and 120 VAC electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical A.1 Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution distribution subsystem(s) to subsystem(s) inoperable. OPERABLE status. AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO B. One or more 120 VAC B.1 Restore 120 VAC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> electrical power power distribution distribution subsystem(s) subsystem(s) to OPERABLE AND (RS1, RS2, RS3, RS4) status.

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from inoperable.

discovery of failure to meet LCO C. One or more DC electrical C.1 Restore DC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution distribution subsystem(s) to subsystem(s) inoperable. OPERABLE status. AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO D. Required Action and D.1 Be in MODE 3. 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> associated Completion Time not met. AND D.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 45. 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br /> ANO-1 3.8.9-1 Amendment No. 215

AC Sources - Operating B 3.8.1 ACTIONS (continued)

E.1 With Train A and Train B DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ES functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power).

Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

With both DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

F.1 and F.2 If the inoperable AC electrical power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimizedthe LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> and to MODE 45 within 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 9). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. In particular, in MODE 4 the turbine-driven emergency feedwater pump[s] are available following a loss of AC sources to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action F.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

G.1 Condition G corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

ANO-1 B 3.8.1-11 Amendment No. 215 Rev. 6,22,

DC Sources - Operating B 3.8.4 ACTIONS A.1 Condition A represents one subsystem with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected subsystem. The 8-hour limit is consistent with the allowed time for an inoperable DC distribution subsystem.

If one of the required DC electrical power subsystems is inoperable (e.g., inoperable battery, inoperable battery chargers, or inoperable battery chargers and associated inoperable battery),

the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst-case single failure could, however, result in the loss of the minimum necessary electrical subsystems to mitigate a worse case accident, continued steady-state power operation should not exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8-hour Completion Time reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

B.1 and B.2 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimizedthe LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> and to MODE 45 within 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 11). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. For example, in MODE 4 the turbine driven emergency feedwater pump[s] are available to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ANO-1 B 3.8.4-4 Amendment No. 215 Rev.

Inverters - Operating B 3.8.7 ACTIONS (continued)

Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24-hour limit takes into consideration the time required to repair an inverter, the availability of a swing inverter, and the additional risk to which the unit is exposed because of the inverter inoperability. This must be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the 120 VAC bus is powered from its alternate AC source, it is relying upon interruptible AC electrical power sources (offsite and onsite). The uninterruptible inverter source to the 120 VAC buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the Required Actions and associated Completion Time are not met or if any two inverters required by LCO 3.8.7.a and LCO 3.8.7.b are inoperable, the unit must be brought to a MODE in which overall plant risk is minimizedthe LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> and to MODE 45 within 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. For example, in MODE 4 the turbine driven emergency feedwater pump is available to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

C.1 and C.2 If any two inverters required by LCO 3.8.7.a and LCO 3.8.7.b are inoperable, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

ANO-1 B 3.8.7-3 Amendment No. 215 Rev. 13,16,

Distribution Systems - Operating B 3.8.9 ACTIONS (continued)

C.1 (continued)

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This could lead to a total of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable and DC distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16-hour Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is minimizedthe LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> and to MODE 45 within 1236 hours0.0143 days <br />0.343 hours <br />0.00204 weeks <br />4.70298e-4 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). There are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms in MODE 4 than in MODE 5. For example, in MODE 4 the turbine driven emergency feedwater pump are available to provide RCS cooling via the steam generators utilizing natural circulation. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

E.1 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. Therefore, no additional time is justified for continued operation. LCO 3.0.3 must be entered immediately to commence a controlled shutdown.

ANO-1 B 3.8.9-6 Amendment No. 215 Rev. 1,16,

Attachment 3 to 1CAN11130x Replacement Clean (Revised) Technical Specification Pages

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion Time of Condition A, B, C, AND D, or E not met.

F.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power 7 days availability for each required offsite circuit.

SR 3.8.1.2 ------------------------------NOTE--------------------------------

All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each DG starts from standby conditions and, 31 days in 15 seconds achieves ready-to-load conditions.

ANO-1 3.8.1-4 Amendment No. 215,

DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 Both DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One DC electrical power A.1 Restore DC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion Time not met. AND B.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ANO-1 3.8.4-1 Amendment No. 215,xxx,

Inverters - Operating 3.8.7 CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C. Two or more of the four C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inverters required by LCO 3.8.7.a and AND LCO 3.8.7.b inoperable.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and 7 days alignment to associated 120 VAC buses RS1, RS2, RS3, and RS4.

ANO-1 3.8.7-2 Amendment No. 215,230,

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Two AC, DC, and 120 VAC electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical A.1 Restore AC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution distribution subsystem(s) to subsystem(s) inoperable. OPERABLE status. AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO B. One or more 120 VAC B.1 Restore 120 VAC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> electrical power power distribution distribution subsystem(s) subsystem(s) to OPERABLE AND (RS1, RS2, RS3, RS4) status.

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from inoperable.

discovery of failure to meet LCO C. One or more DC electrical C.1 Restore DC electrical power 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution distribution subsystem(s) to subsystem(s) inoperable. OPERABLE status. AND 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND D.2 ---------------NOTE---------------

LCO 3.0.4.a is not applicable when entering Mode 4.

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ANO-1 3.8.9-1 Amendment No. 215,218,230,

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