2CAN092501, Request to Revise Typographical Errors in Technical Specifications

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Request to Revise Typographical Errors in Technical Specifications
ML25247A291
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 09/04/2025
From: Couture P
Entergy Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
2CAN092501
Download: ML25247A291 (1)
v • d • e


Text

Entergy Operations, Inc. 1340 Echelon Parkway, Jackson, MS 39213 2CAN092501 10 CFR 50.90 September 4, 2025 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request to Revise Typographical Errors in Technical Specifications Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) requests an amendment to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS). This amendment corrects several related, obvious typographical errors. These errors were inadvertently introduced into the TS by License Amendment 323 (Reference 1). Part of Amendment 323 revised Surveillance Requirement (SR) 4.4.6.2.1 by deleting subsection 4.4.6.2.1.b and relabeling SR 4.4.6.2.1.a as SR 4.4.6.2.1.

TS Limiting Condition for Operation (LCO) 3.4.6.1, "Leakage Detection Systems" Actions a, b, and c and LCO 3.6.4.1, "Containment Sump" Action a.2 direct performance of the now non-existent SR 4.4.6.2.1.a instead of SR 4.4.6.2.1 to perform a Reactor Coolant System water inventory balance. This error is also reflected in the TS Bases for 3/4.6.4.1 Actions a.1, a.2, and a.3.

Since these errors were present in their respective notices to the public and were present during NRC review, correction of the errors does not fall within the scope of the guidance provided by SECY-96-238 (Reference 2); therefore, a license amendment request is required.

The enclosure contains the description and assessment for the request to revise the Technical Specifications to correct the typographical errors discussed above. Attachment 1 to the enclosure contains the mark-ups of the affected Technical Specification pages. Attachment 2 of the enclosure contains the clean, retyped Technical Specification pages. Attachment 3 of the enclosure contains the mark-ups of the affected Technical Specification Basis pages (for information only).

Entergy has reviewed the information supporting a finding of no significant hazards consideration and the environmental considerations provided to the NRC in Reference 1. The information provided in this letter does not affect the basis for concluding that the previously Phil Couture Sr. Manager Fleet Regulatory Assurance - Licensing 601-368-5102

2CAN092501 Page 2 of 3 approved license amendment does not involve a significant hazards consideration.

Furthermore, neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

This letter contains no new regulatory commitments.

The proposed changes will be implemented within 90 days of issuance of the amendment.

In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," Entergy is notifying the State of Arkansas of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.

If there are any questions or if additional information is needed, please contact Joshua Toben, Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-3135.

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

Executed on September 4, 2025.

Sincerely, Phil Couture PC/mar

Enclosure:

Evaluation of Proposed Change Attachments:

1.

Technical Specification Page Markups

2.

Technical Specification Pages Retyped

3.

Technical Specification Basis Page Markup (For Information Only)

References:

1)

NRC Letter to Entergy, "Arkansas Nuclear One, Unit 2 - Issuance of Amendment No. 323 RE: Technical Specification Deletions, Additions, and Relocations" (2CNA022101) ML20351A153, dated February 8, 2021

2)

NRC Policy Issue from James M. Taylor to the Commissioners -

SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors," ML20134M324, dated November 19, 1996 Philip Couture Digitally signed by Philip Couture Date: 2025.09.04 16:37:15

-05'00'

2CAN092501 Page 3 of 3 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official

Enclosure 2CAN092501 Evaluation of Proposed Change

Enclosure 2CAN092501 Page 1 of 7 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION.............................................................................................. 2 2.0 DETAILED DESCRIPTION............................................................................................... 2

3.0 TECHNICAL EVALUATION

............................................................................................. 5

4.0 REGULATORY EVALUATION

......................................................................................... 5 4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA............................... 5 4.2 PRECEDENTS...................................................................................................... 6 4.3 NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS.............................. 6

4.4 CONCLUSION

S.................................................................................................... 7

5.0 ENVIRONMENTAL CONSIDERATION

............................................................................ 7

6.0 REFERENCES

.................................................................................................................. 7

Enclosure 2CAN092501 Page 2 of 7 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) requests an amendment to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS). This amendment corrects several related, obvious typographical errors. These errors were inadvertently introduced into the TS by License Amendment 323 (Reference 1). Part of Amendment 323 revised Surveillance Requirement (SR) 4.4.6.2.1 by deleting subsection 4.4.6.2.1.b and relabeling SR 4.4.6.2.1.a as SR 4.4.6.2.1.

TS Limiting Condition for Operation (LCO) 3.4.6.1, "Leakage Detection Systems" Actions a, b, and c and LCO 3.6.4.1, "Containment Sump" Action a.2 direct performance of the now non-existent SR 4.4.6.2.1.a instead of SR 4.4.6.2.1 to perform a Reactor Coolant System water inventory balance. This error is also reflected in the TS Bases for 3/4.6.4.1 Actions a.1, a.2, and a.3.

2.0 DETAILED DESCRIPTION Amendment 323 of the ANO-2 TS (Reference 1) revised several TS requirements by the addition, deletion, or relocation of certain TS Limiting Conditions of Operation (LCOs),

Actions, and Surveillance Requirements. In the license amendment request (LAR) for Amendment 323, SR 4.4.6.2.1 Reactor Coolant System operational leakage was revised as follows:

From Amendment 322 4.4.6.2.1 Reactor Coolant System operational leakage, except for primary to secondary leakage, shall be demonstrated to be within each of the above limits by:

a.

Performance of a Reactor Coolant System water inventory balance in accordance with the Surveillance Frequency Control Program during steady state operation except when operating in the shutdown cooling mode*.

b.

Monitoring the reactor head flange leakoff temperature in accordance with the Surveillance Frequency Control Program.

To Amendment 323 4.4.6.2.1 Reactor Coolant System operational leakage, except for primary to secondary leakage, shall be demonstrated to be within each of the above limits by performance of a Reactor Coolant System water inventory balance in accordance with the Surveillance Frequency Control Program during steady state operation except when operating in the shutdown cooling mode*.

As can be seen above, SR 4.4.6.2.1.b was deleted, and SR 4.4.6.2.1.a was incorporated into the body of the SR. As such, SR 4.4.6.2.1 no longer has any subsections.

Enclosure 2CAN092501 Page 3 of 7 LCO 3.4.6.1 "Reactor Coolant System Leakage - Leakage Detection Systems" Action a.2 states:

a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a.

This is an obvious typographical error since the current ANO-2 TS do not have SR 4.4.6.2.1.a and a Reactor Coolant System (RCS) water inventory balance is required. The correct wording is as follows [emphasis added]:

a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.

Action b states:

With the containment sump level monitor inoperable, operation may continue for up to 30 days provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

This is an obvious typographical error since the current ANO-2 TS do not have SR 4.4.6.2.1.a and an RCS water inventory balance is required. The correct wording is as follows [emphasis added]:

With the containment sump level monitor inoperable, operation may continue for up to 30 days provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Action c states:

With the containment sump level monitor inoperable and one containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days for each inoperable monitor provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

This is an obvious typographical error since the current ANO-2 TS do not have SR 4.4.6.2.1.a and an RCS water inventory balance is required. The correct wording is as follows [emphasis added]:

With the containment sump level monitor inoperable and one containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days for each inoperable monitor provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1; otherwise, be in at least HOT STANDBY within

Enclosure 2CAN092501 Page 4 of 7 the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

LCO 3.6.4.1 "Containment Systems - Containment Sump" Action a.2 states:

SR 4.4.6.2.1.a is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and This is an obvious typographical error since the current ANO-2 TS do not have SR 4.4.6.2.1.a and an RCS water inventory balance is required. The correct wording is as follows [emphasis added]:

SR 4.4.6.2.1 is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and The TS basis for 3/4.6.4.1 "Containment Sump" Actions a.1, a.2, and a.3 states in part:

While in this condition, the RCS water inventory balance, SR 4.4.6.2.1.a, must be performed at an increased Frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump.

The more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.

This is an obvious typographical error since the current ANO-2 TS do not have SR 4.4.6.2.1.a and an RCS water inventory balance is required. The correct wording is as follows [emphasis added]:

While in this condition, the RCS water inventory balance, SR 4.4.6.2.1, must be performed at an increased Frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump.

The more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.

A review of the current TS for other occurrences of this error was performed, and no other occurrences were found.

Since these errors were present in the notice to the public and were present during NRC review of the proposed ANO-2 TS Amendment 323, correction of the errors does not fall within the scope of the guidance provided by SECY-96-238 (Reference 2); therefore, this license amendment request is required.

Enclosure 2CAN092501 Page 5 of 7

3.0 TECHNICAL EVALUATION

The proposed amendment contains no technical changes. All the proposed changes are editorial. These changes are consistent with the intent of what the Nuclear Regulatory Commission (NRC) has already approved for these pages.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical Specifications" The NRC's regulatory requirements related to the content of the Technical Specifications (TS) are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TS include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls.

Per 10 CFR 50.36(c)(2)(ii), a TS LCO must be established for each item meeting one or more of the following criteria:

Criterion 1:

Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2:

A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3:

A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4:

A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Conclusion Entergy has evaluated the proposed changes against the applicable regulatory requirements described above. The proposed amendment contains no technical changes; all the proposed changes are editorial and do not affect compliance with any of the four criteria above. Based on this evaluation, there is reasonable assurance that the health and safety of the public will remain unaffected following the approval of these proposed changes.

Enclosure 2CAN092501 Page 6 of 7 4.2 Precedents Entergy finds that these type changes are consistent with the changes requested previously by Arkansas Nuclear One, Unit 2 in Reference 3 and Southern Nuclear for Plant Hatch in Reference 4.

4.3 No Significant Hazards Consideration Analysis The proposed amendment corrects obvious typographical errors in the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS).

As required by 10 CFR 50.91(a), Entergy Operations, Inc. (Entergy) has evaluated the proposed changes to the ANO-2 TS and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards is presented below:

1)

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

Response: No The proposed amendment contains no technical changes. All the proposed changes are editorial. These changes are consistent with the intent of what has already been approved by the Nuclear Regulatory Commission (NRC). There are no accidents affected by this change; therefore, there is no increase in the probability or consequences of an accident that has been previously evaluated.

2)

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

Response: No The proposed amendment contains no technical changes; all proposed changes are editorial. These changes are consistent with the intent of what has already been approved by the NRC. There are no accidents affected by this change; therefore, there is no possibility of a new or different kind of accident from any accident that has been previously evaluated.

3)

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

Response: No The proposed amendment contains no technical changes; all proposed changes are editorial. These changes are consistent with the intent of what has already been approved by the NRC. There are no accidents affected by this change; therefore, there is no reduction in the margin of safety for the plant.

Enclosure 2CAN092501 Page 7 of 7 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Entergy has evaluated the proposed change and determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1.

NRC Letter to Entergy, "Arkansas Nuclear One, Unit 2 - Issuance of Amendment No.

323 RE: Technical Specification Deletions, Additions, and Relocations" (2CNA022101)

ML20351A153, dated February 8, 2021

2.

NRC Policy Issue from James M. Taylor to the Commissioners - SECY-96-238, "Proposed Guidance for Correction of Technical Specification Typographical Errors,"

ML20134M324, dated November 19, 1996

3.

Entergy Letter to NRC, "Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications" (2CAN042401) ML24095A063, dated April 4, 2024

4.

Southern Nuclear Operating Company, Inc. Letter to NRC, "Edwin I. Hatch Nuclear Plant Request to Revise Typographical Error in Unit 1 Operating License and in Unit 2 Technical Specifications, and to add STAGGERED TEST BASIS to Unit 1 and Unit 2 Technical Specifications," ML15216A602, dated August 4, 2015

2CAN092501 Technical Specification Page Markups

[2 pages]

ARKANSAS - UNIT 2 3/4 4-13 Amendment No. 231,281, REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a.

One containment sump level monitor

b.

One containment atmosphere particulate radioactivity monitor, and

c.

One containment atmosphere gaseous radioactivity monitor.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With one or more containment atmosphere radioactivity monitor(s) inoperable, operation may continue for up to 30 days for each inoperable monitor provided:

1.

grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or

2.

a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a;*

otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the containment sump level monitor inoperable, operation may continue for up to 30 days provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a;*

otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c.

With the containment sump level monitor inoperable and one containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days for each inoperable monitor provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1.a;* otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

  • Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state conditions.

ARKANSAS - UNIT 2 3/4 6-18 Amendment No. 318, CONTAINMENT SYSTEMS CONTAINMENT SUMP LIMITING CONDITION FOR OPERATION 3.6.4.1 The containment sump shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems -

Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided:

1.

Action is initiated immediately to mitigate containment accident generated and transported debris, and

2.

SR 4.4.6.2.1.a is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

3.

The containment sump is restored to OPERABLE status within 90 days.

b.

With the containment sump inoperable for reasons other than ACTION a:

1.

Immediately enter the applicable ACTIONS of LCO 3.5.2, "ECCS Subsystems -

Tavg 300 °F" and LCO 3.5.3, "ECCS Subsystems - Tavg < 300 °F," for emergency core cooling trains made inoperable by the containment sump, and

2.

Immediately enter the applicable ACTIONS of LCO 3.6.2.1, "Containment Spray System," for containment spray trains made inoperable by the containment sump, and

3.

Restore the containment sump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.4.1.1 Verify, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage in accordance with the Surveillance Frequency Control Program.

2CAN092501 Technical Specification Pages Retyped

[2 Pages]

ARKANSAS - UNIT 2 3/4 4-13 Amendment No. 231,281, REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a.

One containment sump level monitor

b.

One containment atmosphere particulate radioactivity monitor, and

c.

One containment atmosphere gaseous radioactivity monitor.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With one or more containment atmosphere radioactivity monitor(s) inoperable, operation may continue for up to 30 days for each inoperable monitor provided:

1.

grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or

2.

a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1;*

otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the containment sump level monitor inoperable, operation may continue for up to 30 days provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1;*

otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c.

With the containment sump level monitor inoperable and one containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days for each inoperable monitor provided a Reactor Coolant System water inventory balance is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with Surveillance Requirement 4.4.6.2.1;* otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state conditions.

ARKANSAS - UNIT 2 3/4 6-18 Amendment No. 318, CONTAINMENT SYSTEMS CONTAINMENT SUMP LIMITING CONDITION FOR OPERATION 3.6.4.1 The containment sump shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With the containment sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits, entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems -

Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided:

1.

Action is initiated immediately to mitigate containment accident generated and transported debris, and

2.

SR 4.4.6.2.1 is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and

3.

The containment sump is restored to OPERABLE status within 90 days.

b.

With the containment sump inoperable for reasons other than ACTION a:

1.

Immediately enter the applicable ACTIONS of LCO 3.5.2, "ECCS Subsystems -

Tavg 300 °F" and LCO 3.5.3, "ECCS Subsystems - Tavg < 300 °F," for emergency core cooling trains made inoperable by the containment sump, and

2.

Immediately enter the applicable ACTIONS of LCO 3.6.2.1, "Containment Spray System," for containment spray trains made inoperable by the containment sump, and

3.

Restore the containment sump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.4.1.1 Verify, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage in accordance with the Surveillance Frequency Control Program.

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ARKANSAS - UNIT 2 B 3/4 6-12 Rev. 75, CONTAINMENT SYSTEMS BASES 3/4.6.4.1 CONTAINMENT SUMP (continued)

ACTIONS a.1, a.2, and a.3 ACTION a is applicable when there is a condition which results in containment accident generated and transported debris exceeding the analyzed limits. Containment debris limits are defined in engineering calculations. The ACTION states that entry into the applicable ACTION(s) of LCO 3.5.2, "ECCS Subsystems - Tavg 300 °F," LCO 3.5.3, "ECCS Subsystems

- Tavg < 300 °F," and LCO 3.6.2.1, "Containment Spray System," is not required provided specific remedial actions are taken as described in ACTIONs a.1, a.2, and a.3. Therefore, while the aforementioned LCOs are not met, compliance with the ACTIONs of these LCOs is not required. This is an exception to LCO 3.0.2, which would require that the ACTIONS of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's ACTIONs.

When ACTION a is entered, immediate action must be initiated to mitigate the condition.

Examples of mitigating actions are:

Removing the debris source from containment or preventing the debris from being transported to the containment sump; Evaluating the debris source against the assumptions in the analysis; Deferring maintenance that would affect availability of the affected systems and other LOCA mitigating equipment; Deferring maintenance that would affect availability of primary defense-in-depth systems, such as containment coolers; Briefing operators on LOCA debris management actions; or Applying an alternative method to establish new limits.

While in this condition, the RCS water inventory balance, SR 4.4.6.2.1.a, must be performed at an increased Frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump. The more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.

The inoperable containment sump must be restored to OPERABLE status in 90 days. A 90-day allowable outage time (AOT) is reasonable for emergent conditions that involve debris in excess of the analyzed limits that could be generated and transported to the containment sump under accident conditions. The likelihood of an initiating event in the 90-day AOT is very small and there is margin in the associated analyses. The mitigating actions of ACTION a.1 provides additional assurance that the effects of debris in excess of the analyzed limits will be mitigated during the AOT.

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