LR-N04-0350, Request for Change to Technical Specifications to Eliminate Requirements for Hydrogen Recombiners and Primary Containment Hydrogen/Oxygen Concentration Analyzer and Monitor Channels Using the Consolidated Line Item.

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Request for Change to Technical Specifications to Eliminate Requirements for Hydrogen Recombiners and Primary Containment Hydrogen/Oxygen Concentration Analyzer and Monitor Channels Using the Consolidated Line Item.
ML042880479
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 10/01/2004
From: Brothers M
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H04-06, LR-N04-0350
Download: ML042880479 (16)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 ooi 12004 PSEG LR-N04-0350 NuclearLLC LCR H04-06 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS TO ELIMINATE REQUIREMENTS FOR HYDROGEN RECOMBINERS AND PRIMARY CONTAINMENT HYDROGEN/OXYGEN CONCENTRATION ANALYZER AND MONITOR CHANNELS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS HOPE CREEK GENERATING STATION DOCKET NO. 50-354 FACILITY OPERATING LICENSE NO. NPF-57 In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) hereby transmits a request for amendment of the Technical Specifications (TS) and supporting Bases for Hope Creek Generating Station.

The proposed amendment will delete the TS requirements related to hydrogen recombiners and primary containment hydrogenloxygen concentration analyzer and monitor channels. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the FederalRegister on September 25, 2003, as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed change, the requested confirmation of applicability and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. summarizes the regulatory commitments made in this submittal and Attachment 4 provides the existing TS Bases pages marked up to show the proposed changes.

I D 95-2168 REV. 7/99

Document Control Desk 00T 1 2004 LR-N04-0350 PSEG does not have specific schedule needs for this proposed change and processing can be pursued in accordance with the normal NRC review schedule for this type of request. PSEG requests implementation within 60 days of receipt of the approved amendment.

Should you have any questions regarding this request, please contact Mr. Robin Ritzman at (856) 339-1445.

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

Sincerely, Michael H. Brothers Vice President - Operations Attachments (4)

C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. D. Collins, Project Manager - Hope Creek Mail Stop 08C2 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Hope Creek (X24)

Mr. K.Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

ATTACHMENT 1 LCR H04-06 LR-N04-0350 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 ELIMINATION OF REQUIREMENTS FOR HYDROGEN RECOMBINERS AND PRIMARY CONTAINMENT HYDROGENIOXYGEN CONCENTRATION ANALYZER AND MONITOR CHANNELS Table of Contents I. INTRODUCTION ....................................... 1

2. DESCRIPTION ...................................... .1
3. BACKGROUND ....................................... 2
4. REGULATORY REQUIREMENTS AND GUIDANCE .................................... . 2
5. TECHNICAL ANALYSIS ................................... .. 2
6. REGULATORY ANALYSIS ..................................... 2 6.1 Hydrogen Monitoring ....................................... 2 6.2 Inerted Containment ....................................... 3
7. NO SIGNIFICANT HAZARDS CONSIDERATION ..................................... 3
8. ENVIRONMENTAL EVALUATION ..................................... 3
9. PRECEDENT........................................................................................................3
10. REFERENCES ....................................... 3

ATTACHMENT 1 LCR H04-06 LR-N04-0350 CHANGE TO TECHNICAL SPECIFICATIONS

1. INTRODUCTION The proposed License amendment deletes primary containment hydrogen/oxygen concentration analyzer and monitor channels from Technical Specification (TS)

Table 3.3.7.5-1 and from TS Table 4.3.7.5-1. The proposed License amendment also deletes TS 3/4.6.6.1, "Containment Hydrogen Recombiner Systems." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision I of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP). Hope Creek Generating Station has not adopted STS; however, NRC Regulatory Issue Summary 2000-06, "CLIIP for Adopting STS Changes for Power Reactors," permits adoption of CLIIP changes for Licensees that have not converted to STS, but have determined that the TSTF is applicable to their facility.

2. DESCRIPTION Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

TS 3/4.3.7.5 Accident Monitoring Instrumentation Revised TS 3/4.6.6.1 Containment Hydrogen Recombiner Systems Deleted The elimination of the TS 3/4.6.6.1 requirements above result in revision of TS Bases 314.6.6, "Primary Containment Atmosphere Control."

I

ATTACHMENT 1 LCR H04-06 LR-N04-0350

3. BACKGROUND The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), Revision 1 to TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking.
4. REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), Revision 1 to TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking.
5. TECHNICAL ANALYSIS PSEG has reviewed the model safety evaluation (SE) published on September 25, 2003 (68 FR 55416), and verified its applicability as part of the CLIIP. This verification included a review of the NRC staffs model SE, as well as the information provided to support Revision 1 to TSTF-447.

PSEG has concluded that the justifications presented in the TSTF proposal and the model SE prepared by the NRC staff are applicable to Hope Creek Generating Station and justify this amendment for the incorporation of the changes to the Hope Creek TS.

6. REGULATORY ANALYSIS A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), Revision 1 to TSTF-447, and the documentation associated with the 10 CFR 50.44 rulemaking.

As discussed in the model SE published in the Federal Register on September 25, 2003, (68 FR 55416) for this TS improvement, PSEG is making the following plant-specific verifications and commitments.

6.1 Hydrogen Monitoring PSEG has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed in Hope Creek Generating Station. PSEG is making a regulatory commitment to maintain this capability. The hydrogen monitoring function will be included in the Hope Creek Updated Final Safety Analysis Report. This regulatory commitment will be implemented in conjunction with the implementation of the proposed TS revision.

2

ATTACHMENT 1 LCR H04-06 LR-N04-0350 6.2 Inerted Containment Hope Creek Generating Station has an inerted containment. PSEG has verified that an oxygen monitoring system capable of verifying the status of the inert containment is installed in Hope Creek Generating Station.

PSEG is making a regulatory commitment to maintain this capability. The oxygen monitoring function will be included in the Hope Creek Updated Final Safety Analysis Report. This regulatory commitment will be implemented in conjunction with the implementation of the proposed TS revision.

7. NO SIGNIFICANT HAZARDS CONSIDERATION PSEG has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. PSEG has concluded that the proposed determination presented in the notice is applicable to Hope Creek Generating Station, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

B. ENVIRONMENTAL EVALUATION PSEG has reviewed the environmental evaluation included in the model SE published on September25, 2003 (68 FR 55416) as part of the CLIIP. PSEG has concluded that the NRC staffs findings presented in that evaluation are applicable to Hope Creek Generating Station and the evaluation is hereby incorporated by reference for this application.

9. PRECEDENT This application is being made in accordance with the CLIIP. PSEG is not proposing variations or deviations from the TS changes described in Revision 1 to TSTF-447 or the NRC staffs model SE published on September 25, 2003 (68 FR 55416).
10. REFERENCES Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003, (68 FR 55416).

3

ATTACHMENT 2 LCR H04-06 LR-N04-0350 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES Hope Creek Affected Page List Index Page xii The following Technical Specifications for Hope Creek Generating Station Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page 314.3.7.5, "Accident Monitoring Instrumentation" 314 3-85, 86, 87 314.6.6.1, "Containment Hydrogen Recombiner Systems" 3/4 6-54

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE Drywell Average Air Temperature .3/4 6-10 Drywell and Suppression Chamber Purge System .3/4 6-11 3/4.6.2 DEPRESSURIZATION SYSTEMS Suppression Chamber .3/4 6-12 Suppression Pool Spray .3/4 6-15 Suppression Pool Cooling .3/4 6-16 3/4.6.3 PRIMARY CONTAINMENT ISOLATION VALVES .3/4 6-17 Table 3.6.3-1 Primary Containment Isolation Valves... 3/4 6-19 3/4.6.4 VACUUM RELIEF Suppression Chamber - Drywell Vacuum Breakers .......... 3/4 6-43 Reactor Building - Suppression Chamber Vacuum Breakers ............................................. 3/4 6-45 3/4.6.5 SECONDARY CONTAINMENT Secondary Containment Integrity ........................ 3/4 6-47 Secondary Containment Automatic Isolation Dampers ...... 3/4 6-49 Table 3.6.5.2-1 Secondary Containment Ventilation System Automatic Isolation Dampers Isolation Group No. 19 ............... 3/4 6-50 Filtration, Recirculation and Ventilation System ....... 3/4 6-51 3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL Containment Hydrogen Recombiner Systems (Deleted) ...... 3/4 6-54 Drywell and Suppression Chamber Oxygen Concentration... 3/4 6-55 3/4.7 PLANT SYSTEMS 3/4.7.1 SERVICE WATER SYSTEMS Safety Auxiliaries Cooling System ...................... 3/4 7-1 Station Service Water System ........................... 3/4 7-3 Ultimate Heat Sink ..................................... 3/4 7-5 3/4.7.2 CONTROL ROOM EMERGENCY FILTRATION SYSTEM ............... 3/4 7-6 HOPE CREEK xii

TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION

1. Reactor Vessel Pressure 2 1 1,2,3 80
2. Reactor Vessel Water level 2 1 1,2,3 80
3. Suppression Chamber Water level 2 1 1,2,3 80
4. Suppression Chamber Water Temperature* 2 1 1,2,3 80
5. Suppression Chamber Pressure Deleted 2 1 1,2,3 80
6. Drywell Pressure 2 1 1,2,3 80
7. Drywell Air Temperature 2 1 1,2,3 80
8. Primary Containme t Hy rogen/Oxygen Concentration nlzrand C Monitory o 2 1 12,3 80
9. Sft e e Position Indicators 2/valve*; 1/valve** 1,2,3 80
10. Drywell Atmosphere Post-Accident Radiation Monitor 2 1 1,2,3 80
11. North Plant Vent Radiation Monitor # 1 1 1,2,3 81
12. South Plant Vent Radiation Monitor # 1 1 1,2,3 81
13. FRVS Vent Radiation Monitor # 1 1 1,2,3 81
14. Primary Containment Isolation Valve Position Indication ## 2/valve 1/valve 1,2,3 82
  • Average bulk pool temperature.
    • Acoustic monitoring and tail pipe temperature.
  1. High range noble gas monitors.
    1. One channel consists of the open limit switch, and the other channel consists of the closed limit switch.

HOPE CREEK 3/4 3-85 Amendment No. 71

Table 3.3.7.5-1 (Continued)

ACCIDENT MONITORING INSTRUMENTATION ACTION STATEMENTS ACTION 80 -

a. With the number of OPERABLE channels less than the Required Number of Channels shown in Table 3.3.7.5-1, restore the inoperable channel to OPERABLE status within 30 days, or immediately initiate actions in accordance with 6.9.2.
b. With the number of OPERABLE channels less than the Minimum Number of Channels shown in Table 3.3.7.5-1, (except for the Primary GentainvRet Hycdrzege.,'G:ygr. Analyzer lagd _..iter B..I the Drywell Atmosphere Post Accident Radiation Monitor) restore at least one inoperable channel to OPERABLE status within 7 days, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN eted within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
c. the number of OPERABLE Primary Containment Hydrogen/Oxyge oncentration Analyzer and Monitor channels less N than the Minimum Number of Channels requirement shown in Table 3.3.7.5-1, restore anc least one inoperable channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or t

> lastHOTSHUDOW bein wihinthenext 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and inCL }

d. With the number of OPERABLE Drywell Atmosphere Post Accident Radiation Monitor channels less than the Minimum Number of Channels requirement shown in Table 3.3.7.5-1, initiate action in accordance with ACTION 81, below.

ACTION 81 - With the number of OPERABLE accident monitoring instrumentation channels less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:

a. Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and
b. Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

ACTION 82 -

a. With the number of OPERABLE accident monitoring instrumentation channels less than the Required Number of Channels shown in Table 3.3.7.5-1, verify the valve(s) position by use of alternate indication methods. If the affected penetration is not isolated by either (i) a closed manual valve, (ii) a blind flange, or (iii) a deactivated automatic valve located outside primary containment, restore the inoperable channel(s) to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

HOPE CREEK 3/4 3-86 Amendment No. 71

TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS APPLICABLE CHANNEL CHANNEL OPERATIONAL INSTRUMENT CHECK CALIBRATION CONDITIONS

1. Reactor Vessel Pressure M R 1,2,3
2. Reactor Vessel Water Level M R 1,2,3
3. Suppression Chamber Water Level M R 1,2,3
4. Suppression Chamber Water Temperature M R 1,2,3
5. Suppression Chamber Pressure M R 1,2,3
6. Drywell Pressure M R 1,2,3
7. Drywell Air Temperature M R 1,2,3
8. Primary Containme t Hydrogen/Oxygen Concentration
9. Safety/Relief Valve Position Indicators M R 1,2,3
10. Drywell Atmosphere Post-Accident Radiation Monitor M R** 1,2,3
11. North Plant Vent Radiation Monitor# M R 1,2,3
12. South Plant Vent Radiation Monitor# M R 1,2,3
13. FRVS Vent Radiation Monitor# M R 1,2,3
14. Primary Containment Isolation Valve Position Indication M R 1,2,3
  • Using sample containing:
a. Five volume cent oxygen balance n ogen (oxygen analyze channel).
b. Five volume perc hydrogen, qgen balane ni0 (hydrogen analy r channel).
    • CHANNEL CALIBRATION sha ll consist of an electronic calibration of the channe, not including the detector for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.
  1. High range noble gas monitors.

HOPE CREEK 3/4 3-87

CONTAINMENT SYSTEMS 3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL CONTAINMENT HYDROGEN RECOMBINER SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.6.1 Two independent containment hydrogen recombiner systems shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.

ACTION:

With one containment hydrogen recombiner system inoperable, restore the inoperable system to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.6.1 Each containment hydrogen recombiner system shall be demonstrated OPERABLE:

a. At least once per 6 months by verifying during a recombiner system functional test that the minimum reaction chamber gas temperature increases to greater than or equal to 1150'F within 120 minutes and is maintained > 1150'F for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
b. At least once per 18 months by:
1. Performing a CHANNEL CALIBRATION of all recombiner control panel instrumentation and control circuits.
2. Verifying the integrity of all heater electrical circuits by performing a resistance to ground test within 30 minutes following the above required functional test. The resistance to ground for any heater phase shall be greater than or equal to e_maom The material originally contained in Section 3/4.6.6.1 was deleted with the issuance of Amendment No. . However, to maintain numerical continuity between the succeeding sections and existing station procedural references to those Technical Specification sections, 3/4.6.6.1 has been intentionally left blank HOPE CREEK 3/4 6-54

ATTACHMENT 3 LCR H04-06 LR-N04-0350 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by PSEG in this document.

Any other statements in this submittal are provided for information only purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Robin Ritzman at (856) 339-1445.

Regulatory Commitment Due Date/Event PSEG will maintain the hydrogen monitoring system Concurrent with capability of diagnosing beyond design basis accidents. implementation of the amendment PSEG will include the hydrogen monitoring function in the Concurrent with Hope Creek Updated Final Safety Analysis Report. implementation of the amendment PSEG will maintain the oxygen monitoring system capability Concurrent with of verifying the status of the inert containment. implementation of the amendment PSEG will include the oxygen monitoring function in the Concurrent with Hope Creek Updated Final Safety Analysis Report. implementation of the amendment

ATTACHMENT 4 LCR H04-06 LR-N04-0350 PROPOSED CHANGES TO TS BASES PAGES The following Technical Specifications Bases for Hope Creek Generating Station, Facility Operating License No. NPF-57, is affected by this change request:

Technical Specification Page Bases 3/4.6.6 B 3/4 6-14

CONTAINMENT SYSTEMS BASES 3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL Te OPERABILITY of the systems required for the detection and cotrol of hydrogen gas ensures that these systems will be available to maintain the hydrogen concentration within the primary containment below its flammable limit during post-LOCA conditions. Either containment hydrogen recombiner is capable of controlling the expected hydrogen generation associated with (1) zirconium-water reactions, (2) radiolytic decomposition of water and (3) corrosion of metals within containment. The hydrogen control system is consistent with the recommendations of Regulatory Guide 1.7, "Control of Combustible Gas Ca LOCA" Novemb 1978.

HOPE CREEK B 3/4 6-14 Amendment No. 133

INSERT 1 (LCO 3/4.6.6, PRIMARY CONTAINMENT ATMOSPHERE CONTROL BASES)

The primary containment oxygen concentration is maintained less than 4%

by volume to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

The primary containment oxygen concentration must be less than 4% by volume when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in OPERATIONAL CONDITION 1, since this is the condition with the highest probability of an event that could produce hydrogen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus.

Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. As long as reactor power is less than 15% of RATED THERMAL POWER, the potential for an event that generates significant hydrogen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

If oxygen concentration is 2 4% by volume at any time while operating in OPERATIONAL CONDITION 1, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to <

4% by volume within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time is allowed when oxygen concentration is 2 4% by volume because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

If oxygen concentration cannot be restored to within limits within the required completion time, the plant must be brought to an OPERATIONAL CONDITION in which the LCO does not apply. To achieve this status, plant must be in at least STARTUP within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

The primary containment must be determined to be inert by verifying that oxygen concentration is less than 4% by volume. The 7 day Frequency is based on the slow rate at which oxygen concentration can change and on other indications of abnormal conditions (which would lead to more frequent checking by operators in accordance with plant procedures). Also, this Frequency has been shown to be acceptable through operating experience.

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