Text

Application for Technical Specifications (TS) Change Regarding Mode Change Limitations (TSTF-359) Using the Consolidated Line Item Improvement Process (CLIIP)
	ML051600214
Person / Time
Site:	FitzPatrick
Issue date:	05/31/2005
From:	Ted Sullivan; Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	JAFP-05-0084, TSTF-359
	Download: ML051600214 (60)
	v • d • e

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP PRO. Box 110

- ;. eg1 y Lycoming, NY 13093

,-_.- HTel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Site Vice President - JAF May 31, 2005 JAFP-05-0084 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Application for Technical Specifications (TS) Change Regarding Mode Change Limitations (TSTF-359) Using the Consolidated Line Item Improvement Process (CLIIP)

Dear Sir:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) hereby requests an amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant.

The proposed amendment would modify TS requirements for Mode change limitations in LCO 3.0.4 and SR 3.0.4. The proposed TS changes are consistent with Revision 9 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-359, "Increase Flexibility in MODE Restraints."

The availability of this TS improvement was announced in the FederalRegister on April 4, 2003 as part of the consolidated line item improvement process (CLIIP).

Attachment I provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Table 1 of this attachment provides a brief summary of the changes.

Attachment 2 provides the existing TS pages marked-up to show the proposed changes.

Attachment 3 provides revised, clean TS pages (re-typed).

Attachment 4 provides a summary of regulatory commitments made in this submittal.

Attachment 5 provides the existing TS Bases pages marked-up to show the proposed changes. The Bases changes are provided for information only. The final TS Bases pages (revised, clean pages) will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

ENO requests approval of the proposed License Amendment by June 1, 2006, with the amendment being implemented within 60 days from the date of approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York State Official.

4\C)

The commitments made in this letter are contained in Attachment 4. If you have any questions, please contact Mr. Rick Plasse of the Regulatory Compliance Department at 315-349-6793.

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

Executed on the _L/_day of /$fatL , 2005 Attachments: 1. Description and Assessment

2. Proposed Technical Specification Pages (Marked-Up)

3. Proposed Technical Specification Pages (Re-Typed)

4. Summary of Regulatory Commitments

5. Proposed Technical Specification Bases Pages (Marked-Up) cc:

Mr. Samuel J. Collins USNRC Resident Inspector Regional Administrator, Region I James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P.O. Box 136 475 Allendale Road Lycoming, NY 13093-0136 King of Prussia, PA 19406-1415 Mr. Patrick Milano, Sr. Project Manager Mr. Paul Eddy Project Directorate I New York State Department of Division of Licensing Project Management Public Service Office of Nuclear Reactor Regulation 3 Empire State Plaza U. S. Nuclear Regulatory Commission Albany, NY 12223 Mail Stop 8-C2 Washington, DC 20555-0001 Mr. Peter R. Smith President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 2

Attachment 1 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 DESCRIPTION AND ASSESSMENT

Attachment 1 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify the James A. FitzPatrick (JAF) Technical Specifications (TS) requirements for Mode change limitations in LCO 3.0.4 and SR 3.0.4.

The JAF TS already contain a TS Bases Control Program (TS 5.5.11) and SR 3.0.1, thus these requirements do not need to be added as described in NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change, TSTF-359, Rev. 9, "Increase Flexibility in MODE Restraints."

The proposed TS changes are consistent with TSTF-359. The availability of this TS improvement was announced in the Federal Register on April 4, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation published on April 4, 2003 (68 FR 16579) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's safety evaluation, as well as the supporting information provided to support TSTF-359, Rev. 9. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to JAF and justify this amendment for the incorporation of the changes to the JAF TS.

2.2 Optional Changes and Variations ENO is not proposing any variations or deviations from the TS changes described in the modified TSTF-359, Rev. 9 and the NRC staff's model safety evaluation dated April 4, 2003, other than a few minor editorial changes based on JAF specific terminology or design. Table 1 of this attachment provides a brief summary of the changes, including a description of these minor editorial changes.

For clarification, the following TS Sections described in the TSTF are not included in this submittal because they are not part of the JAF TS based on the plant specific design:

STS 3.3.6.3 Low-Low Set (LLS) Instrumentation

STS 3.6.3.1 Primary Containment Hydrogen Recombiners

STS 3.6.3.2 Drywell Cooling System Fans

STS 3.7.3 Diesel Generator (DG) [1 B] Standby Service Water (SSW) System (The JAF Emergency Diesel Generators (EDGs) are cooled by the Emergency Service Water (ESW) System, which does not contain an LCO 3.0.4 allowance.

Note that if an ESW subsystem is inoperable, TS 3.7.2, "Emergency Service Water (ESW) and Ultimate Heat Sink (UHS)," Condition A requires that applicable Conditions and Required Actions of LCO 3.8.1, 'AC Sources - Operating," be entered for EDG subsystems made inoperable by ESW. Thus, an LCO 3.0.4.b exclusion is not required for TS 3.7.2.)

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Attachment 1 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Description and Assessment

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination ENO has reviewed the proposed no significant hazards consideration determination published on April 4, 2003 (68 FR 16579) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to JAF and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003 (68 FR 16579) for this TS improvement, the following plant-specific verifications were performed as follows:

ENO has proposed changes to the TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS mode change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to operable status before entering an associated MODE or other specified condition in the TS Applicability.

The proposed changes also include changes to the Bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The Bases changes provide guidance for changing Modes or other specified conditions in the Applicability when an LCO is not met. The Bases changes describe in detail how: LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, which is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity) though it may be applied to other Specifications based on NRC plant-specific approval. The Bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. In addition, the Bases state that upon entry into a Mode or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions for no more than the duration of the 2

Attachment 1 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Description and Assessment 3.2 Verification and Commitments (continued) applicable Completion Time or until the LCO is met or the unit is not within the Applicability of the TS. The Bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3. Finally, as noted in Section 1.0 above, the JAF TS already contain a TS Bases Control Program (TS 5.5.11) and SR 3.0.1, thus these requirements do not need to be added to the TS.

4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on April 4, 2003 (68 FR 16579) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to JAF and the evaluation is hereby incorporated by reference for this application.

3

Attachment 1 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Description and Assessment Table 1 STS No. JAF TS Description of Change No.

LCO 3.0.4 LCO 3.0.4 Existing LCO has been replaced in its entirety with the revised insert.

SR 3.0.4 SR 3.0.4 Existing SR has been replaced in its entirety with the revised insert.

3.3.3.1 3.3.3.1 The ACTIONS NOTE stating 'LCO 3.0.4 is not applicable." has been deleted and the remaining NOTE renumbered.

3.3.3.2 3.3.3.2 The ACTIONS NOTE stating 'LCO 3.0.4 is not applicable." has been deleted and the remaining NOTE renumbered.

3.4.6 3.4.5 The REQUIRED ACTION A.1 NOTE stating "LCO 3.0.4 is not applicable." has been deleted. The REQUIRED ACTION C NOTE stating "LCO 3.0.4 is not applicable." has been deleted. JAF TS differ slightly from STS based on approved deviations during ITS conversion.

Removal of NOTES in this Specification is consistent with the TSTF.

3.4.7 3.4.6 The REQUIRED ACTION A.1/A.2 NOTE is modified to state "LCO 3.0.4.c is applicable."

3.4.8 3.4.7 The ACTIONS NOTE stating "LCO 3.0.4 is not applicable." has been deleted and the remaining NOTE renumbered.

3.5.1 3.5.1 A NOTE is added to the ACTIONS stating "LCO 3.0.4.b is not applicable to HPCI."

3.5.3 3.5.3 A NOTE is added to the ACTIONS stating "LCO 3.0.4.b is not applicable to RCIC."

3.6.3.4 3.6.3.2 The REQUIRED ACTION A.1 NOTE stating "LCO 3.0.4 is not applicable." has been deleted.

3.8.1 3.8.1 A NOTE is added to the ACTIONS stating "LCO 3.0.4.b is not applicable to EDG subsystems." The modification to the TSTF insert wording is based on JAF specific terminology and design in that each EDG subsystem contains two EDGs.

The TS Bases have been revised consistent with the above TS changes and TSTF-359.

Additional information is provided below.

STS Bases TS Bases Description of Change No. No.

LCO 3.0.4 LCO 3.0.4 Existing LCO Bases have been replaced in their entirety with the revised insert. The bracketed portion of the LCO 3.0.4.c discussion in the Bases has been modified with the JAF Specification that is applicable (i.e., TS 3.4.6, RCS Specific Activity).

SR 3.0.4 SR 3.0.4 Existing SR Bases have been replaced in their entirety with the revised insert.

3.4.7 3.4.6 Bases revised to describe the provisions of LCO 3.0.4.c.

3.5.1 3.5.1 Bases revised to describe that LCO 3.0.4.b is not applicable. JAF uses the term HPCI 'System' vs. subsystem as stated in the TSTF insert.

3.5.3 3.5.3 Bases revised to describe that LCO 3.0.4.b is not applicable.

3.8.1 3.8.1 Bases revised to describe that LCO 3.0.4.b is not applicable. JAF uses I the term 'EDG subsystem' vs. DG, as described above.

4

Attachment 2 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION PAGES (MARKED-UP)

TS PAGES 3.0-1 3.0-2 3.0-4 3.3.3.1-1 3.3.3.2-1 3.4.5-1 3.4.5-2 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.6.3.2-1 3.8.1-1 Inserts (2 pages)

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the plant shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the plant, as applicable, in:

a. MODE 2 within 7 hour8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months s:

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

(continued)

JAFNPP 3.0-1 Amendment 4-

LCO Applicability A -N 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 xcept s to this Spec Xcation are sta d in the (continued) ind dual Specifica ons.

/ O3.0.4 is o plicable for edry a MODE o te into specified iion in the Ap t blity in MODES/,

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

JAFNPP 3.0-2 Amendment -274

SR Applicability 3.0 3.0 SR APPLICABILITY (continued)

SR 3.0.4 Entry into ODE or other s ified conditio in thi

/Applicai ty of an LCO sh&ad not be made u dess the LC'

/uveioCnces have been, it within their s 'ecf ed I Fre -ency. This shl ntprd t entiry into /

PruKio MO S or other spefied conditions ibothe Applicabilit 6:4~tJfat are requir edt comply with Actins or that a rof dit a____-- ashutdown hplant.//

SR 3.0.4 s only applicable r entry into a MO or other specif d condition in th pplicability in H ES 1, 2, JAFNPP 3.0-4 Amendment-2'4

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

I APPLICABILITY: MODES 1 and 2.

ACTIONS

NT------ --......................................... .. ~ -- -- - -- - -- - -- -- - -- - -- -

, Separt Co.0.n, d ion t s aoepplio X eparate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6.

not met.

C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status.

(continued)

JAFNPP 3.3.3.1-1 Amendment -280-

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

------- NOTEr ------------------------------------

<Seprate ondiion entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

JAFNPP 3.3.3.2-1 Amendment-274-

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system;

b. One channel of the drywell continuous atmospheric particulate monitoring system; and

c. One channel of the drywell continuous atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1. 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain sump monitoring system 1LC .0.4) not Xlicab~e.)

inoperable. ---- -----

A.1 Restore drywell floor 30 days drain sump monitoring system to OPERABLE status.

B. One drywell continuous B.1 -------- NOTE---------

atmospheric monitoring Not applicable when system inoperable. both drywell continuous atmospheric monitoring systems are inoperable.

Perform SR 3.4.5.1. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

JAFNPP 3.4.5-1 Amendment -a4-

RCS Leakage Detection Instrumentation A .13.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Both drywell ---

continuous atmospheric .0.4ivnot iLCO plicab .

monitoring systems .......

inoperable.

C.1 Analyze grab samples Once per of drywell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmosphere.

AND C.2 Restore one drywell 30 days continuous atmospheric monitoring system to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, AND B. or C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. All required leakage E.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

JAFNPP 3.4.5-2 Amendment RCS Specific Activity 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT I-131 specific activity

0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant -NOTE-----------

specific activity LCOis applicable.

> 0.2 pCi/gm and

2.0 pCi/gm DOSE EQUIVALENT I-131. A.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT I-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT I-131 to within limits.

B. Required Action and B.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion EQUIVALENT I-131.

Time of Condition A not met. AND OR B.2.1 Isolate all main 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months steam lines.

Reactor coolant specific activity OR

> 2.0 pCi/gm DOSE EQUIVALENT I-131.

(continued)

JAFNPP 3.4.6-1 Amendment z274

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE.

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

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR cut in permissive pressure.

ACTIONS

~_6----

A-------------- .....--NOTEr------------------------------------

(z .Owe spplagg

,Z0 Separate Condition entry is allowed for each RHR shutdown cooling su system.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to Immediately shutdown cooling restore RHR shutdown subsystems inoperable. cooling subsystem(s) to OPERABLE status.

AND A.2 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

AND A.3 Be in MODE 4. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months JAFNPP 3.4.7-1 Amendment 274-

ECCS- Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief val ves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure

150 psig.

ACTIONS E x sE r§ CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OPERABLE status.

OR One low pressure coolant injection (LPCI) pump in both LPCI subsystems inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

JAFNPP 3.5.1-1 Amendment-244-

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACT I O q7tSN CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System A.1 Verify by Immediately inoperable. administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

150 psig.

JAFNPP 3.5.3-1 Amendmenti2qt4

CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System LCO 3.6.3.2 Two CAD subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CAD subsystem A.1 -O- NOTE -- --

inoperable. L 3.0.4 not pplica e.

Restore CAD subsystem 30 days to OPERABLE status.

B. Two CAD subsystems B.1 Verify by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. administrative means that the hydrogen AND control function is maintained. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Restore one CAD 7 days subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

JAFNPP 3.6.3.2-1 Amendment Aq4u-

AC Sources- Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the plant Class lE AC Electrical Power Distribution System: and

b. Two emergency diesel generator (EDG) subsystems.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS J\s-CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. for OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no discovery of no offsite power offsite power to available inoperable one division when the redundant concurrent with required feature(s) inoperability of are inoperable. redundant required feature(s)

AND (continued)

JAFNPP 3.8.1-1 Amendment INSERTS FOR PROPOSED TS PAGES (MARKED-UP)

INSERT 1 (LCO 3.0.4)

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent 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.

INSERT 2 (SR 3.0.4)

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into 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.

Page I of 2

INSERTS FOR PROPOSED TS PAGES (MARKED-UP)

BWR4 INSERT 1 (LCO 3.5.1, ECCS - OPERATING)

-NOTE-LCO 3.0.4.b is not applicable to HPCI.

BWR4 INSERT 2 (LCO 3.5.3, RCIC SYSTEM)

-NOTE-LCO 3.0.4.b is not applicable to RCIC.

BWR4 INSERT 3 (LCO 3.8.1, AC SOURCES - OPERATING)

-NOTE-LCO 3.0.4.b is not applicable to EDG subsystems.

Page 2 of 2

Attachment 3 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION PAGES (RE-TYPED)

TS PAGES 3.0-1 3.0-2 3.0-3 3.0-4 3.0-5 3.3.3.1-1 3.3.3.2-1 3.4.5-1 3.4.5-2 3.4.6-1 3.4.7-1 3.5.1-1 3.5.3-1 3.6.3.2-1 3.8.1-1

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the plant shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the plant, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)

JAFN PP 3.0-1 Amendment XXXM

LCO Applicability 3.0

3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent 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.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

JAFN PP 3.0-2 Amendment XXX

LCO Applicability 3.0

, LCO APPLICABILITY (continued)

LCO 3.0.7 Special Operations LCOs in Section 3.10 allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

JAFNPP 3.0-3 Amendment XXX

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per. . ." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

JAFNPP 3.0-4 Amendment XXX

SR Applicability 3.0 3.0 SR APPLICABILITY (continued)

SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3.

When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into 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.

JAFN PP 3.0-5 Amendment XXX

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required channel 30 days with one required to OPERABLE status.

channel inoperable.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.6.

met.

C. One or more Functions C.1 Restore one required 7 days with two required channel to OPERABLE channels inoperable. status.

(continued)

JAFNPP 3.3.3.1-1 Amendment XXX

Remote Shutdown System 3.3.3.2 3.3 INSTRUMENTATION 3.3.3.2 Remote Shutdown System LCO 3.3.3.2 The Remote Shutdown System Functions shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required Function 30 days Functions inoperable. to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

JAFNPP 3.3.3.2-1 Amendment XXX

RCS Leakage Detection Instrumentation 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Leakage Detection Instrumentation LCO 3.4.5 The following RCS leakage detection instrumentation shall be OPERABLE:

a. Drywell floor drain sump monitoring system;

b. One channel of the drywell continuous atmospheric particulate monitoring system; and

c. One channel of the drywell continuous atmospheric gaseous monitoring system.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain sump A.1 Restore drywell floor drain 30 days monitoring system sump monitoring system inoperable. to OPERABLE status.

B. One drywell continuous B.1 -- NOTE-------

atmospheric monitoring Not applicable when both system inoperable. drywell continuous atmospheric monitoring systems are inoperable.

Perform SR 3.4.5.1. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

JAFNPP 3.4.5-1 Amendment XXX

RCS Leakage Detection Instrumentation 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Both drywell continuous C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months atmospheric monitoring drywell atmosphere.

systems inoperable.

AND C.2 Restore one drywell 30 days continuous atmospheric monitoring system to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, B, or AND C not met.

D.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. All required leakage E.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

JAFN PP 3.4.5-2 Amendment XXX

RCS Specific Activity 3.4.6 f

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Specific Activity LCO 3.4.6 The specific activity of the reactor coolant shall be limited to DOSE EQUIVALENT 1-131 specific activity < 0.2 pCi/gm.

APPLICABILITY: MODE 1, MODES 2 and 3 with any main steam line not isolated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant specific ---------- NOTE----------

activity > 0.2 pCi/gm and LCO 3.0.4.c is applicable.

< 2.0 pCi/gm DOSE ------------------------

EQUIVALENT 1-131.

A.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EQUIVALENT 1-131.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limits.

B. Required Action and B.1 Determine DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion EQUIVALENT 1-131.

Time of Condition A not met. AND OR B.2.1 Isolate all main steam 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lines.

Reactor coolant specific activity > 2.0 pCi/gm OR DOSE EQUIVALENT 1-131.

(continued)

JAFNPP 3.4.6-1 Amendment XXX

RHR Shutdown Cooling System-Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE.

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

One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the RHR cut in permissive pressure.

ACTIONS

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

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR A.1 Initiate action to restore Immediately shutdown cooling RHR shutdown cooling subsystems inoperable. subsystem(s) to OPERABLE status.

AND A.2 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

AND A.3 Be in MODE 4. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months JAFNPP 3.4.7-1 Amendment XXX

ECCS-Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure < 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem(s) to OR OPERABLE status.

One low pressure coolant injection (LPCI) pump in both LPCI subsystems inoperable.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not AND met.

B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

JAFNPP 3.5.1-1 Amendment XXX

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY: MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

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

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A. RCIC System inoperable. A.1 Verify by administrative Immediately means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to 14 days OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Reduce reactor steam 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months dome pressure to

< 150 psig.

JAFN PP 3.5.3-1 Amendment XXX

CAD System 3.6.3.2 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Containment Atmosphere Dilution (CAD) System LCO 3.6.3.2 Two CAD subsystems shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CAD subsystem A.1 Restore CAD subsystem 30 days inoperable. to OPERABLE status.

B. Two CAD subsystems B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. means that the hydrogen control AND function is maintained.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.2 Restore one CAD 7 days subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

JAFNPP 3.6.3.2-1 Amendment XXX

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the plant Class 1E AC Electrical Power Distribution System; and

b. Two emergency diesel generator (EDG) subsystems.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS i n

- - - - ------------------------- NOTE--- -a-t-E-----------

LCO 3.0.4.b is not applicable to EDG subsystems.

CONDITION REQUIRED ACTION COMPLETION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no discovery of no offsite power available offsite power to inoperable when the one division redundant required concurrent with feature(s) are inoperability of inoperable. redundant required feature(s)

AND (continued)

JAFNPP 3.8.1-1 Amendment XXX

Attachment 4 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333

SUMMARY

OF REGULATORY COMMITMENTS

Attachment 4 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

SUMMARY

OF REGULATORY COMMITMENTS Commitments Description Completion Schedule None N/A N/A 1

Attachment 5 to JAFP-05-0084 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKED-UP)

TS BASES PAGES B 3.0-5 B 3.0-6 B 3.0-17 B 3.0-18 B 3.3.3.1-8 B 3.3.3.2-3 B 3.4.5-3 B 3.4.5-4 B 3.4.6-2 B 3.4.7-3 B 3.5.1-6 B 3.5.3-2 B 3.6.3.2-3 B 3.8.1-6 Inserts (4 pages) 1

LCO Applicability B 3.0 BASES (continued)

LCO 3.0.4 LCO 3.0.4 establis limitations on change n MODES or other specified nditions in the Agplica ity when an LCO is not met. precludes placing the t in a MODE o other speci *ed condition stated in at Applicability (e.g.. Ap icability desired to be ntered when the followi exist:

a. Plant conditions are s that the require ts of the LCO would not be met *nthe Applicabilit desired to be entered: and

b. Continued nonc pliance with the requirements, if the Applicab' ity were entered, uld result in the plant bein required to exit e Applicability desired to be ent ed to comply wit he Required Actions.

Compliance ith Required Acti s that permit continued operatio of the plant for unlimited period of ti in a MODE ther specified codition provides an acce able level of safety for con nued operation. This without re d to the status the plant before or a er the MODE c nge. Therefore, n such cases, entry i a MODE or ther specified c dition in the Applic ity may be made in accordance wi the provisions of e Required Actions.

The provisions of this Specificatio should not be interpreted endorsing the fai e to exercise the good practice of restoring systems components to OPERABLE status be ore entering an a ociated MODE or other specif conditi in the Applicab ity.

The ovisions of LC 3.0.4 shall not prevent cha es in MOPS or other spe fied conditions in the Appl' ability at are require 0to comply with ACTIONS. I addition, the provisions of 0 3.0.4 shall not prevent anges in MODES or other spe fied conditions in the Ap cability that result ftay plant shutdown. /

Except ns to LCO 3.0.4 are stat in the individual Spec ications. The exception allow entry into MODES or othr specified conditions i the Applicability when the associated ACTIONS to be ered do not provide for

{continued operation for n unlimited period of time.

Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

(continued)

JAFNPP B 3.0-5 Revision/

LCO Applicability B 3.0 BASES LCO 3.0.4 ell do not have to be perf.med on the associat LC

.. urveillancead o aet eprs'do h asoiatd (continued) inoperabl equipment (or on variale's outside the specified limits as permitted by SR 3. . Therefore, changing MOD or other specified co tions while in an ACTIONS dition, either in comp *ance with LCO 3.0.4 or whe'an exception to LCO 3.0.4 stated, is not a violati n of 3 SR 3.0.1 or SR 3.0.4 or those Surveillances thW do not have to be perfor due to the associated i erable equipment. How er, SRs must be met to e re OPERABILITY prior to dec ing the associated equip nt OPERABLE (or variable w, in limits) and restorin compliance with the affecte CO.

LC .0.4 is only applicable en entering MODE 3 from DE 4, MODE 2 from MODE 34. or 5, or MODE 1 from MODK2.

Furthermore, LCO 3.0.4 i applicable when entering a other specified condition i he Applicability only whil operating in MODE 1 , or 3. The requirements LCO 3.0.4 do not apply in M 4 and 5, or in other speg fied conditions of t Applicability (unless in MOE 1, 2, or 3) because the A ONS of individual specific ions sufficientl 'definethe remedial measureto be taken.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY.

his Specification does not provide time to perform any other preventive or corrective maintenance.

(continued)

JAFNPP B 3.0-6 Revision Y

SR Applicability B 3.0 BASES (continued)

SR 3.0.4 /SR 3.0.4 estlishes the re rement that al applicable SRs must be m before entry to a MODE or o er specified conditi in the Appl ility.

K Th Specificatio ERABILITY re ensures that sy m and component rements and varile limits are me efore entry into MUGS or other specied conditions in e Applicabil* y for which thes systems and compo nts ensure safe ope tion of the plan The ovisions of thi pecification sho d not be i rpreted as endor ing the failure t exercise the goo actice of restorng systems or com nents to OPERABL status before e ering an associat MODE or other s cified condition in e Applicability.

However, certain circums ces, failing to et an SR will no result in SR 3.0. restricting a M change or other specified conditi change. When aystem. subsystem, div ion, component, ice, or variabl is inoperable or ofside its specifie limits, the ass iated SR(s) are not equired to be per rmed per SR 3.0 , which states tha Surveillances do ot have to be p formed on inoperabl equipment. Wh equipment is i perable, SR 3.0.4 es not apply to the ssociated SR(s) ince the requireme for the SR(s) to b performed is re ved. Therefore, f ing to perform e SurveillanceC within the specifi Frequency, on equ ment that is in erable, does not r lt in an SR 3 .4 restriction changing MODES or her specified co itions of the A icability. Howev . since the LCO is t met in this i tance, LCO 3.0.4 w govern any restrictions th may (or may not) ply to MODE or other specified con tion changes.

The provi ons of SR 3.0.4 sh not prevent changes i MODES or other specified co itions in the Applicabi y that e required to com with ACTIONS. In addi on, the provsions of SR 3.0.4 all not prevent change n MODES or ot0 r specified condi ons in the Applicabili that result om any plant shut wn.

The precise re rements for performan of SRs are specified su that exceptions to 5 .0.4 are not necessary. he specific time fra and condition necessar or meeting the SRs ar specified in t Freque , in the Surveillanc or both. This lows performance of Surveillances when the prereq site (continued)

JAFNPP B 3.0-17 Revi si on X

SR Applicability B 3.0 BASES SR 3.0.4 condition(s) speci ed in a Surveillance proc ure require (continued) entry into the W or other specified con ion in the Applicability the associated LCO prio o the performance or completi ?!of a Surveillance. A Suoeillance that could not be p ormed until after enteri the LCO Applicability would yVe its Frequency specifie such that it is not "due" unti he specific conditions geeded are met. Alternately, th urveil lance may be stated in the form of a Note as no quired (to be met or pe ormed) until a particular ev condition, or time has en reached. Further discuss n of the specific formats f SRs' annotation is found i Section 1.4. Freq cy.

SR 3.0.4 is o y applicable when entering E 3 from MODE 4. MO 2 from MODE 3, 4. or 5. or E1 from MODE 2.

Furtherm e, SR 3.0.4 is applicable w entering any other specifld condition in the Applicab ity only while ope ing in MODE 1, 2. or 3. Th requirements of SR 3 .

not apply in MODES 4 and 5, in other specified conditions of the Applicabil' y (unless in MODE 1, , or 3) because the ACTIONS of ind' idual Specification sufficiently define the remedial measures to b taken.

JAFNPP B 3.0-18 Revision ,

PAM Instrumentation B 3.3.3.1 BASES LCO 10. Drvwell Water Level I (continued)

Drywell Water Level is a Category 1 variable provided to detect whether plant safety functions are being accomplished. Two drywell water level channels monitor the range from 22 feet to 106 feet. Each drywell water level channel consists of level transmitters, with an associated indicator and recorder in the control room. These level transmitters and associated indicators and recorders provide the primary indication used by the operator during an accident. Therefore, the PAM Specification deals specifically with these portions of the instrument channel.

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1 and 2.

These variables are related to the diagnosis and preplanned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1 and 2. In MOD ES 3, 4, and 5, plant conditions are such that the likelihood of an event that would require PAM instrumentation is extremely low; therefore, PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS Note 1 has b iaadded to the ACTIONS to c ude the MODE change reg iction of LCO 3.0.4. Th' exception allows entry 'fto the applicable MODE wh"P21relying on the ACTIONS ev rythough the ACTIONS may ev ually require plant utdown. This exception acceptable due to the p ive function of the instruns, the operator's abili to diagnose an accide sing alternative instru s and methods, and t ow probability of an ev requiring these instruments. J gh Note2has been provided to modify the ACTIONS related to PAM instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable PAM instrumentation channels provide appropriate compensatory measures for separate Functions. As such, a Note has been provided that allows separate Condition entry for each inoperable PAM Function.

(continued)

JAFNPP B 3.3.3.1-8 Revision )1K

Remote Shutdown System B 3.3.3.2 BASES LCO The Remote Shutdown System instruments and control circuits (continued) covered by this LCO do not need to be energized to be considered OPERABLE. This LCO is intended to ensure that the instruments and control circuits will be OPERABLE if plant conditions require that the Remote Shutdown System be placed in operation.

APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1 and 2. This is required so that the plant can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

This LCO is not applicable in MODES 3, 4, and 5. In these MODES, the plant is already subcritical and in a condition of reduced Reactor Coolant System energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control becomes unavailable. Consequently, the LCO does not require OPERABILITY in MODES 3, 4, and 5.

ACTIONS e

A Note (N 1) is included that exgp des the MODE change restri on of LCO 3.0.4. This nception allows entry i an icable MODE while rel g on the ACTIONS even t ugh e ACTIONS may eventuallyequire a plant shutdow This exception is acceptabl due to the low probabili of an event requiring thi; system.

ote has been provided to modify the ACTIONS related to Remote Shutdown System Functions. Section 1.3, Completion Times, specifies that once a Condition has been entered.

subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable Remote Shutdown System Functions provide appropriate compensatory measures for separate Functions.

As such, a Note has been provided that allows separate Condition entry for each inoperable Remote Shutdown System Function.

(continued)

JAFNPP B 3.3.3.2-3 Revision Or

RCS Leakage Detection Instrumentation B 3.4.5 BASES APPLICABLE A control room alarm or indication allows the operators to SAFETY ANALYSES evaluate the significance of the indicated LEAKAGE and, if (continued) necessary, shut down the reactor for further investigation and corrective action. The allowed LEAKAGE rates are well below the rates predicted for critical crack sizes (Refs. 6 and 7). Therefore, these actions provide adequate response before a significant break in the RCPB can occur.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii) (Ref. 8).

LCO The drywell floor drain sump monitoring system is required to quantify the unidentified LEAKAGE from the RCS. Thus, for the system to be considered OPERABLE, the flow monitoring portion of the system must be OPERABLE since this portion is capable of quantifying unidentified LEAKAGE from the RCS. The other monitoring systems (one channel each of the drywell continuous atmospheric particulate and drywell continuous atmospheric gaseous monitoring systems) provide early alarms to the operators so closer examination of other detection systems will be made to determine the extent of any corrective action that may be required. With the leakage detection systems inoperable, monitoring for LEAKAGE in the RCPB is degraded.

APPLICABILITY In MODES 1, 2, and 3, leakage detection systems are required to be OPERABLE to support LCO 3.4.4. This Applicability is consistent with that for LCO 3.4.4.

ACTIONS A.1 With the drywell floor drain sump monitoring system inoperable, no other form of sampling can provide the equivalent information to quantify leakage. However, the drywell continuous atmospheric monitors will provide indication of changes in leakage.

With the drywell floor drain sump monitoring system inoperable, but with RCS unidentified and total LEAKAGE being determined every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (SR 3.4.4.1), operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable, based on operating experience, considering the multiple forms of leakage detection that are still available./Sequi Actiont isn )

bmy a sta ht visio (continued)

JAFNPP B 3.4.5-3 Revision Y

RCS Leakage Detection Instrumentation B 3.4.5 BASES ACT co LCO 3.0.4 ite not app] aRe. As a resla MODE change allowedw en the dry foor drain w oitoring swe is ixoperable. Th'w allowance is pi ded because ofe W trumentatio available to ior RCS leaka~e B..1 With one required drywell continuous atmospheric monitoring channel inoperable, SR 3.4.5.1 must be performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for the remaining OPERABLE drywell continuous atmospheric monitoring channel to provide periodic information of activity in the drywell at a more frequent interval than the routine Frequency of SR 3.4.5.1. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action to be not applicable if both drywell continuous atmospheric monitoring systems are inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment.

C.1 and C.2 With both required gaseous and particulate drywell continuous atmospheric monitoring channels inoperable, grab samples of the drywell atmosphere must be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the plant may be operated for up to 30 days to allow restoration of at least one of the two monitors.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval provides periodic information that is adequate to detect LEAKAGE. The 30 day Completion Time for restoration recognizes that at least one other form of leakage detection is available.

Require ons are m y a Note th o ti at

/ the provi i Es of LCO 3.0.4 r o applicable/Aa result, 4MODE change isRswdwenbt 8 gaseous and/

par i'late drywell c gtnous atmosphricmnitoring /

sweter ae iopea~tte Tis allowanti povided be~rs othelon intrumnt s aailale montorRCS lekge (continued)

JAFNPP B 3.4.5-4 Revision IV

RCS Specific Activity B 3.4.6 BASES APPLICABLE The limits on specific activity are values from a parametric SAFETY ANALYSES evaluation of typical site locations. These limits are (continued) conservative because the evaluation considered more restrictive parameters than for a specific site, such as the location of the site boundary and the meteorological conditions of the site.

RCS specific activity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii) (Ref. 4).

LCO The specific iodine activity is limited to

0.2 pCi/gm DOSE EQUIVALENT I-131. This limit ensures the source term assumed in the safety analysis for the MSLB is not exceeded, so any release of radioactivity to the environment during an MSLB is less than a small fraction of the 10 CFR 100 limits.

APPLICABILITY In MODE 1, and MODES 2 and 3 with any main steam line not isolated, limits on the primary coolant radioactivity are applicable since there is an escape path for release of radioactive material from the primary coolant to the environment in the event of an MSLB outside of primary containment.

In MODES 2 and 3 with the main steam lines isolated, such limits do not apply since an escape path does not exist. In MODES 4 and 5. no limits are required since the reactor is not pressurized and the potential for leakage is reduced.

ACTIONS A.1 and A.2 When the reactor coolant specific activity exceeds the LCO DOSE EQUIVALENT I-131 limit, but is

2.0 pCi/gm, samples must be analyzed for DOSE EQUIVALENT I-131 at least once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In addition, the specific activity must be restored to the LCO limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is based on the time needed to take and analyze a sample. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time to restore the activity level provides a reasonable time for temporary coolant activity increases (iodine spikes or crud bursts) to be cleaned up with the normal processing systems.

r A Notthe Requi ctions of Xndition A e - des te~D M M c # hne res ittion of LCO,2.'0.4. This jxnep-tion allos se'

) ntry into Napplicable MQKM(S) while r ting on the/

{ > S CLAPCTIONS sv£S_2hyL the AeTIONS may evenrually requirt'ln his pption is acceptable due to the

~ (continued)

JAFNPP B 3.4.6-2 Revision /

RHR Shutdown Cooling System-Hot Shutdown B 3.4.7 BASES APPLICABILITY The requirements for decay heat removal in MODES 4 and 5 are (continued) discussed in LCO 3.4.8, "Residual Heat Removal MRHR)

Shutdown Cooling System-Cold Shutdown"; LCO 3.9.7, "Residual Heat Removal (RHR)-High Water Level"; and LCO 3.9.8, "Residual Heat Removal (RHR)-Low Water Level."

ACTIONS A Note to th CTIONS excludes the MODE eange restriction of LCO 3 . . This exception allow§,& try into the a ph e MODE(S) while relyin the ACTIONS even thou t CTIONS may eventually re ire plant shutdown. Thi xception is acceptable d o the redundancy of th OPERABLE subsystems. t ow pressure at which t plant is operating, the low obability of an event ocsufring during omration in t hscndition, and the availability ofv aaternate m S's of decay heat removal Capability.

A &ecpitNote has been provided to modify the ACTIONS related to RHR shutdown cooling subsystems. Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable shutdown cooling subsystems provide appropriate compensatory measures for separate inoperable shutdown cooling subsystems. As such, a Note has-been provided that allows separate Condition entry for each inoperable RHR shutdown cooling subsystem.

A.1, A.2, and A.3 With one required RHR shutdown cooling subsystem inoperable for decay heat removal, except as permitted by the LCO Note, the inoperable subsystem must be restored to OPERABLE status without delay. In this condition, the remaining OPERABLE subsystem can provide the necessary decay heat removal. The overall reliability is reduced, however, because a single failure in the OPERABLE subsystem could result in reduced RHR shutdown cooling capability. Therefore, an alternate method of decay heat removal must be provided.

With both RHR shutdown cooling subsystems inoperable, an alternate method of decay heat removal must be provided in addition to that provided for the initial RHR shutdown (continued)

JAFNPP B 3.4.7-3 Revision JV

ECCS - Operating B 3.5.1 BASES (continued)

APPLICABILITY All ECCS subsystems are required to be OPERABLE during MODES 1, 2, and 3, when there is considerable energy in the reactor core and core cooling would be required to prevent fuel damage in the event of a break in the primary system piping. In MODES 2 and 3, when reactor steam dome pressure is

150 psig, ADS and HPCI are not required to be OPERABLE because the low pressure ECCS subsystems can provide sufficient flow below this pressure. ECCS requirements for MODES 4 and 5 are specified in LCO 3.5.2, "ECCS -Shutdown."

ACTIONS A.1 If any one low pressure ECCS injection/s pray subsystem is inoperable or if one LPCI pump in both LPCI subsystems is inoperable, the inoperable subsystem(s) must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE subsystems provide adequate core cooling during a LOCA. However, overall ECCS reliability is reduced, because a single active component failure in one of the remaining OPERABLE subsystems, concurrent with a LOCA, may result in the ECCS not being able to perform its intended safety function. The 7 day Completion Time is consistent with the recommendations provided in a reliability study (Ref. 12) that evaluated the impact on ECCS availability, assuming various components and subsystems were taken out of service. The results were used to calculate the average availability of ECCS equipment needed to mitigate the consequences of a LOCA as a function of allowed outage times (i.e., Completion Times).

B.1 and B.2 If the inoperable low pressure ECCS subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 and C.2 If the HPCI System is inoperable and the RCIC System is verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days. In this condition, adequate (continued)

JAFNPP B 3.5.1-6 Revision /¢

RCIC System B 3.5.3 BASES BACKGROUND overheating when other discharge line valves are closed. To (continued) ensure rapid delivery of water to the RPV and to minimize water hammer effects, the RCIC System discharge piping is kept full of water. The RCIC System is normally aligned to the CSTs. The height of water in the CSTs is sufficient to maintain the piping full of water up to the first isolation valve. The relative height of the feedwater line connection for RCIC is such that the water in the feedwater lines keeps the remaining portion of the RCIC discharge line full of water. Therefore, RCIC does not require a "keep full" system.

APPLICABLE The function of the RCIC System is to respond to transient SAFETY ANALYSES events by providing makeup coolant to the reactor. The RCIC System is not an Engineered Safeguard System and no credit is taken in the safety analyses for RCIC System operation.

The RCIC System satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii) (Ref. 3).

LCO The OPERABILITY of the RCIC System provides adequate core cooling such that actuation of any of the low pressure ECCS subsystems is not required in the event of RPV isolation accompanied by a loss of feedwater flow. The RCIC System has sufficient capacity for maintaining RPV inventory during an isolation event.

APPLICABILITY The RCIC System is required to be OPERABLE during MODE 1.

and MODES 2 and 3 with reactor steam dome pressure

> 150 psig, since RCIC is the primary non-ECCS water source for core cooling when the reactor is isolated and pressurized. In MODES 2 and 3 with reactor steam dome pressure s 150 psig, and in MODES 4 and 5, RCIC is not required to be OPERABLE since the low pressure ECCS injection/spray subsystems can provide sufficient flow to the RPV.

ACTIONS A.1 and A.2 If the RCIC System is inoperable during MODE 1, or MODE 2 or 3 with reactor steam dome pressure > 150 psig, and the HPCI System is verified to be OPERABLE, the RCIC System must be restored to OPERABLE status within 14 days. In this Condition, loss of the RCIC System will not affect the overall plant capability to provide makeup inventory at high reactor pressure since the HPCI System is the only high (continued)

JAFNPP B 3.5.3-2 Revision of

CAD System B 3.6.3.2 BASES (continued)

ACTIONS A.1 If one CAD subsystem is inoperable, it must be restored to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CAD subsystem is adequate to perform the oxygen control function. However, the overall reliability is reduced because a single active failure in the OPERABLE subsystem could result in reduced oxygen control capability.

The 30 day Completion Time is based on the low probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limit, the amount of time available after the event for operator action to prevent exceeding this limit, and the availability of the OPERABLE CAD subsystem and other hydrogen mitigating systems.

q ired Action A. s been modified by aN th enicates that OEB of LCO 3.0.4am not t usvisions applicable.a f o atlowed when one a poslt, a MODE change CAD tb Asub is inoperable. Thisral alnce is providedr becau o the low probability of t occurrence of a OCAL tha hyetdr genorol fuctogen a alten in amounts capaWle ofaernaehdrogthe flammabilitypait, the low probabildd y oft Prfailure of the OPERABL tig system, the amour omltime Tvaimale alr a postule LOCA for operator toa prevnt eceeing theY mmability limit, andie/

aalosso tydrogf ot n stems. I rolrogen mitigating B.1 and B.2 With two CAD subsystems inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen control capabilities are rovided by the Primary Containment Inerting Systeml. The 1 ohr Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. In addition, the alternate hydrogen control system capability must be verified once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter to ensure its continued availability. Both the initial verification and all subsequent verifications may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control system. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control system. If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two CAD subsystems (continued)

JAFNPP B 3.6.3.2-3 Revision x

AC Sources - Operating B 3.8.1 BASES APPLICABILITY b. Adequate core cooling is provided and containment (continued) OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 4 and 5 are covered in LCO 3.8.2, "AC Sources- Shutdown."

ACTIONS A. 1 To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the availability of the remaining offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. However, if a second offsite circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.

A.2 Required Action A.2, which only applies if the division cannot be powered from an offsite source, is intended to provide assurance that an event with a coincident single active failure of the associated EDG subsystem does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single division systems are not included). Redundant required features failures consist of inoperable features associated with a division redundant to the division that has no power from an offsite circuit.

The Completion Time for Required Action A.2 is intended to allow time for the operator to evaluate and repair any discovered inoperabilities. This Completion Time also allows an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. The division has no offsite circuit OPERABLE to supply its loads; and

b. A redundant required feature on the other division is inoperable.

(continued)

JAFNPP B 3.8.1-6 Revision /

INSERTS FOR PROPOSED TS BASES PAGES (MARKED-UP)

INSERT 3 (LCO 3.0.4 BASES)

LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

Page 1 of 4

INSERTS FOR PROPOSED TS BASES PAGES (MARKED-UP)

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE I to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment.

However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

Page 2 of 4

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INSERT 4 (SR 3.0.4 BASES)

SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance(s) not being met in accordance with LCO 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that Surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The provisions of SR 3.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, and MODE 3 to MODE 4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

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INSERT 8 (RCS SPECIFIC ACTIVITY BASES)

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

BWR4 INSERT 113 (LCO 3.5.1, ECCS - OPERATING BASES)

A Note prohibits the application of LCO 3.0.4.b to an inoperable HPCI System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable HPCI System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

BWR4 INSERT 2B (LCO 3.5.3, RCIC SYSTEM BASES)

A Note prohibits the application of LCO 3.0.4.b to an inoperable RCIC System. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable RCIC System and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

BWR4 INSERT 3B (LCO 3.8.1, AC SOURCES - OPERATING BASES)

A Note prohibits the application of LCO 3.0.4.b to an inoperable EDG subsystem. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable EDG subsystem and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Page 4 of 4

v t e Letter Sequence Request
TAC:MC7254, Increase Flexibility in Mode Restraints (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other: ML053000538
MONTHYEAR2005-10-20 [Table View]

JAFP-05-0084, Application for Technical Specifications (TS) Change Regarding Mode Change Limitations (TSTF-359) Using the Consolidated Line Item Improvement Process (CLIIP)

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JAFP-05-0084, Application for Technical Specifications (TS) Change Regarding Mode Change Limitations (TSTF-359) Using the Consolidated Line Item Improvement Process (CLIIP)

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