ML20046C600

Rev 0 to Arkansas Nuclear One Unit One Shutdown Operations Protection Plan

ML20046C600
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/02/1993
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20046C596	List: ML20046C595 ML20046C600
References
PROC-930202, NUDOCS 9308110208
Download: ML20046C600 (80)

Text

{{#Wiki_filter:.c 1 Arkansas Nuclear One Unit One Shutdown Operations Protection Plan Revision 0 February 1,1993 l 1, i i 1 l Date: 2/'/PJ Reviewed By: // g82 m<avn ~ _ Operationgianager, Unit 1 M T Cu Date: a l i ' e.y3 Reviewed By: 1 Project Manager, Outages. Unit 1 t Date: 2 (/7] l Approved By:,. aQ, g g j/ Plant Manage OrJi. /1'

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Outage Management Nuclear Safety Philosophy Entergy Operations' safety philosophy for the conduct of shutdown operations is to e integrate nuclear safety into the planning, scheduling and implementation of outage activities. The key attribute of this process is the concept of Defense in Depth which includes; identification of shutdown risk as an element of the planning of outage activities, minimization of shutdown risk through the scheduling of activities, and providing systems, structures and components to provide a backup for key safety functions through redundant, alternate or diverse methods. Successful safe and efficient implementation of' outage activities depends on the dedication and teamwork among the outage team including contractors, and meticulous performance of outage activities. The follow 1ng i principles are used to assure the successful management of outages at Entergy Operations: Outage Management Strategy

• Planned outages are conducted to perform corrective maintenance, preventative maintenance, required surveillances, and plant modifications to allow the plant to operate safely until it's next planned outage, and for the remainder ofit's forty year operating license. Outage activities are selected consistent with this purpose to:

reduce radiation exposure, improve personnel safety, improve plant operation, and meet regulatory requirements. Lists of approved activities are developed in advance to allow adequate time for design, procurement, and pre-installation activities. The Entergy Operations goal for outage duration is to conduct the shortest possible outage, while accomplishing the outage scope with the highest level of both personnel and plant safety. NUMARC 91-06, " Guidelines for Industry Actions to Assess Shutdowm e Management" is used to assess and improve outage safety by minimizing shutdown risk. The key element of this approach is the concept of Defense in Depth. Defense in Depth is the concept of ensuring that the systems and altemates that perform key safety functions are available when needed, panicularly during high risk 1 evolutions The use of the Protected Train methodology, coupled with an l understanding of plant conditions and risk conditions, is a key element in minimizing shutdown risk.

• The recommendations contained in SOER 91-01 will be used to assure the safe conduct ofInfrequently Performed Tests and Evolutions. These recommendations include the use of: pre-test briefmgs, clear and concise test procedures, and the establishment of criteria for terminating the test.

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Outage Planning . Outage planning is the process of selecting and reviewing outage activities to establish scheduling requirements based on Technical Specification, operational, and implementation requirements; and shutdown risk considerations.

• Outage planning must include a review of Infrequently Performed Tests and Evolutions to ensure adequate precautions are taken. Management oversight during test review and performance, pre-shift briefings, and the establishment of test termination criteria are some of the measures employed to ensure proper test conduct.

Outage Scheduling e Outage scheduling is the process ofintegrating outage activities into a coordinated schedule which efliciently and safely accomplishes the outage scope within the restraints identified through outage planning.

• Key milestones are established to identify pre-outage activities, such as the scope freeze date, Design Change Package issue date, and work package issue date. These milestones will be established in advance to allow time for shutdown risk assessment, work implementation planning, and parts procurement.
• Input for the detailed outage schedule is prosided by past outage successes and a review of outage projects and scope, and the resources available. The schedule must take into account an assumed reserve of resources to deal with emergent issues. The reserve is based on past outage performance and management judgment of the potential for emergent work based on the planned outage activities. The detailed outage resource loading must consider the need for personnel to have a reasonable amount of time ofE
• The detailed outage schedule is developed to meet the Technical Specification, operational and implementation requirements in a manner that provides for Defense in Depth under all shutdown conditions. The minimum combination ofsafety equipment required to maintain critical safety functions is established for each phase of the outage. Projects representing special risk conditions will be scheduled during periods when the risk is minimized due to a combination of plant condition and equipment availability. Special emphasis will be given to the scheduling of work with the potential to adversely affect Shutdown Cooling, the availability of AC power sources, and periods when the combination of reactor inventory and decay heat load could result in a short time to boiling. An independent review of shutdown risk conditions and the equipment providing critical safety functions is performed as part of the final schedule approval.

Outage Implementation

• The outage organization will be structured to provide clear project responsibility and a clear reporting relationship for both pre-outage and outage activities. This organization and the project responsibilities will be communicated to all outage personnel. Outage management shift coverage will be simctured to provide outage oversight and decision making capability available on site when necessary. Clear communications through the use of scheduled outage meetings and management tours ofoutage work areas are used to keep the outage team informed, and to emphasize the importance of safe and eflicient outage conduct.
• While the completion of outage activities generally reduces the shutdown risk, as the plant is returned to a nomial operational alignment, the period just before plant restan presents a time of high activity with a heightened potential for personnel errors.

Continued management shift coverage, equivalent to that employed during the major portion of the outage, should be considered during this period and the startup testing period. This enhanced coverage may be beneficial until the unit reaches a stable point in the post-outage power ascension. Outage Critique e

• A comprehensive critique is used following each major planned outage to provide a mechanism for continued improvement. The nput for these critiques is stmetured to facilitate input from all levels of plant personnel. The critique items are tracked between outages and reviewed as part of the planning process for the next outage to ensure that corrective actions are taken. Critiques are shared between the plant sites to allow each plant to benefit from the lessons learned.

I Table of Contents i 1. Introduction 1 11. Terms and Definitions 2 111. Outage Risk Management Guidelines 5 A. General Requirements 5 1. Planning 5 2. Training 5 3. Implementation 6 4. Post Outage 7 B. Decay Heat Removal Equipment Requirements 8 C. Reactor Coolant System inventory Control Requirements 9 D. Electrical Power Distribution Requirements 11 E. Reactivity Control Requirements 12 F. Containment Requirements 13 IV. Minimum Equipment Requirements By RCS Condition 15 Condition 1 REACTOR VESSEL DEFUELED 15 Condition 2 FTC FLOODED > 23' ABOVE CORE l NO FUEL HANDLING IN PROGRESS FUEL IN REACTOR VESSEL 17 Condition 3 FTC FLOODED > 23' ABOVE CORE FUEL HANDLING IN PROGRESS FUEL IN REACTOR VESSEL 19 Condition 4 RCS INTACT RCS LEVEL > 375' FUEL IN REACTOR VESSEL 21 l

i Table of Contents (continued) Condition 5 RCS OPEN RCS LEVEL > 375' FTC NOT FLOODED FUELIN REACTOR VESSEL 23 Condition 6 RCS INTACT RCS LEVELS 375' (REDUCED lNVENTORY) FUEL IN REACTOR VESSEL 25 Condition 7 RCS OPEN RCS LEVEL s 375' (REDUCED INVENTORY) FUEL IN REACTOR VESSEL 28 V. Contingency Plans 31 A. Decay Heat Removal 31 RCS Decay Heat Removal 31 Spent Fuel Pool Cooling 31 B. Reactor Coolant System inventory Control 31 RCS Inventory Makeup 31 C. Electrical Power Distribution 31 Electrical Power 31 D. Reactivity Control 32 Emergency Boration 32 E. Containment 32 l t I Containment Closure 32 Containment Cooling 32 VI. References 33 APPROVAL FOR DEPARTURE FROM WE REQUIREMENTS OFWE SHUTDOWN OPERATIONS PROTECTION PLAN 34 OUTAGE SAFETY REVIEW GUIDELINES 35 s r +

I. Introduction Due to concerns over the risks associated with shutdown operations and realizing that proper management of outage activities can reduce both the likelihood and consequences of shutdown events, a set of unit specific guidelines by which to conduct outages and thereby maintain nuclear safety during shutdown operations has been developed. These guidelines are based on the " Defense in Depth" philosophy of outage management and are contained 1 in this document as Section 111. Section 11 is a list of some common terms and their definitions as they apply here, Section IV gives a set of minimum equipment requirements for the specific Reactor Cooiant System shutdown conditions. RCS Conditions are numbered from the Condition with the least risk to the most risk (1 is least; 7 is most), Section V is a list of planned contingencies, and Section VI is a list of References used in the preparation of this document. This document assumes the Reactor Coolant System is at Cold or Refueling Shutdown. Operating Procedures ensure safety requirements for higher j conditions are met. " Requirements" or " Required", as used in this document, is intended to mean available. Additional equipment " operability" requirements are contained in the i Unit One Plant Technical Specifications and are assured of being met by use of the unit Operating Procedures. The guidelines and minimum equipment requirements contained in this document provide guidance for scheduled, forced (unscheduled), and refueling outages. Attachment 1. Approval for Departure from the Requirements of the Shutdown Operations Protection Plan, is used to document SOPP deviations. i Deviations from guidelines containing a "should" require approval from the Duty Outage Manager or the Project Manager, Outages, Unit One. Deviations from l I guidelines containing a "shall" require approval from the Plant Manager, Unit One. I r -.,. ~.

II. Terms and Definitions AVAILABLE-The status of a system, structure or component that is in service or can be placed in service within a reasonably short period of time (consistent with its intended service) and can be reasonably expected to perform the intended functional need. This condition recognizes that app!! cable technical specification requirements or licensing / design basis assumptions may not be maintained. COrrrAINMENT CLOSURE - A containment condition where at least one integral barrier to the release of radioactive materialis provided. CONTAINMENT CLOSURE CONTROLS - Controls established by procedure OP-1015.002, Decay Heat Removal and LTOP System Control, to track any impaired Reactor Building penetration so that at least one barrier to the release of radioactive material can be quickly achieved in the event of a loss of decay heat removal. DECAY HEAT REMOVAL CAPABILITY - The ability to maintain Reactor Coolant System temperature and pressure and Spent Fuel Pool temperature below specified limits following a shutdown. DEFENSE IN DEPTH - For the purpose of managing risk during shutdown, defense in depth is the concept of: Providing systems, structures and components to ensure backup of key safety functions using redundant, alternate or diverse methods; Planning and scheduling outage activities in a manner that optimizes safety system availability; Providing administrative controls that support and/or supplement the above elements. DEFuELED - All fuel assemblies have been removed from the reactor vessel and placed in the spent fuel pool. INVENTORY CONTROL - Measures established to ensure that irradiated fuel assemblies remain covered with coolant to maintain heat transfer and shielding requirements. KEY MAINTENANCE PERSONNEL - Personnel who are performing, immediately supervising, or responsible for the correct performance of maintenance, repair, modification, or calibration of safety-related structures, systems, or components. 2

4 KEY SAFETY Fut4CTIOtis - During shutdown operations, the key safety functions are decay heat removal capability, inventory control, electrical power availability, reactiviy control, and containmeni closure capability. Mio LonP - Generic Letter 88-17 defines mid-loop as: "The condition that exists wbuever the Reactor Coolant System water level is lower than the top of the fiow area at the junction of the hot legs with the reactor vessel." For ANO-1, this is approximately elevation 371'. Restrictions placed on mid-loop operations by Generic Letter 88-17 are met on ANO-1 prior to entering reduced inventory (i.e., < elevation 375'). OPERABLE - The ability of a system to perform its specified function with all applicable Technical Specification requirements satisfied. PRESSURE RETAltalNG DEVICE - For the purposes of covering a steam generator manway, any device that impedes the flow of steam such that the pressure buildup inside the Reactor Coolant System could be greater than 0.4 psig. PROTECTED EOulPMErn / SYSTEMS - Equipment that is being relied upon to ensure a Key Safety Function is maintained available. REACTIVITY COtRROL - Measures established both to preclude inadvenent dilutions, criticalities, power excursions, or losses of shutdown margin, and to predict and monitor core behavior. REACTOR COOLAta SYSTEM liiTACT - See REACTOR COOLAt6 SYSTEM lt4TEGRITY. REACTOR COOLArn SYSTEM ltREGRITY - The ability of the Reactor Coolant System (RCS) pressure boundary to function as a principal safety barrier. Mole: The condition of the RCS, whether it is open or intact, depends on in what context it is being used. The following are some of the different definitions of "RCS Open" and to what they apply: 1. Tech Spec 3.6.2 requires that Containment Integrity be maintained when the RCS is open to the Reactor Building atmosphere and the requirements for a Refueling Shutdown a e not met. This "RCS Open" is interpreted to mean when the reactor vessel head is being removed or has been removed with fuelin the vessel. Ref: OP-1015.002, Decay Heat Removal and LTOP System Control. 2. For the purposes of Low Temperature Over-Pressurization, Decay Heat System suction valve Auto-Closure Interiocks, and RCS a

inventory makeup methods, "RCS Open" exists if any of the following conditions are met: A. Reactor Vessel head removed B. SG Primary manway removed C. SG Primary hand hole cover removed D. Pressurizer Code-Safety removed E. All CRD top closure assemblies removed (excluding RV level probe) F. Pressurizer manway removed Ref: OP-1015.002, Decay Heat Removal and LTOP System Control. 3. For the purpose of breaking the pressure boundary of an incore instrument in the bottom of the incore Tank,"RCS Open" means at least one Steam Generator Primary manway cover removed with no other pressure retaining device

• covering the manway, or the reactor vessel head is removed.

any device that impedes the flow of steam such that the l pressure buildup inside the Reactor Coolant System could be greater than 0.4 psig. Ref: Calculation 91 E-0052-01, Prevention of ANO-1 RCS Pressurization Due to the Loss of Decay Heat Removal. Unless otherwise specified, "RCS Open", as used in this document, means definition number 2 above. If the RCS is not "open", it is " intact". If the status of the RCS (open or intact) is unknown, the RCS will be considered " intact" for determining RCS makeup flowpath requirements and "open" for time to reach 200 F determination. _ REDUCED INVENTORY - The condition of the Reactor Coolant System when fuel is in the reactor vessel and the level is lower than three feet below the reactor vessel flange. At ANO-1, this level is conservatively defined as elevation 375' (1.5 feet below the vessel flange.) SHUTDOWN RISK ASSESSMENT TASK FORCE - A task force initiated to assess the risks associated with shutdown operations. It is comprised of representatives from Operations, Safety Analysis, System Engineering, Industry Events Analysis, Licensing, Operations Training, and Outage Scheduling. 4 \\ _-__--_a

r s t Ill. Outage Risk Management Guidelines A. GENERAL-1. PLANNING a. The outage schedule should be developed through interaction with involved organizations and disciplines to assure that the planning provides Defense in Depth throughout the outage. Activities in the outage schedule should be sufficiently detailed and organized to accurately convey the impact on complex evolutions, plant conditions, and equipment availability. b. The outage work scope and schedule should realistically match resources to activities. Additional resources should be available to meet anticipated changes, such as increases to the outage scope. c. Surveillance testing and preventative maintenance activities associated with key shutdown operations protection equipment or systems should be incorporated into the detailed outage schedule. A post-maintenance testing coordinator will be matrixed to the outage organization during outages to ensure all required post-maintenance testing is performed. I d. A detailed safety review of the outage schedule shall be performed by the Shutdown Risk Assessment Task Force for all planned outages. A review shall be performed prior to the outage and prior to any safety significant changes to the outage schedule l after the initial review. Major outage activities shall be controlled and implemented in accordance with the approved schedule. ~ Outage Safety Review Guidelines are provided as Attachment 2. Outage planning and execution should consider the potential e. introduction of hazards (e.g., fire, flooding, etc.) posed by the level and/or scope of activities in a given area of the plant and establish compensatory measures as appropriate. i 1 2. TRAINING j 1 Operator Training should be performed on the shutdown a. safety issues described herein. To the extent practicable, simulator training for shutdown conditions should also be performed. 5

,=. b. Plant personnel, including contractors and others temporarily assigned to support the outage, should be trained in areas that are applicable to their particular role in outage activities and that contribute to the safe conduct of the outage. Personnelwho may be required to implement a contingency c. plan should be familiar with the plan. 3. IMPI EMENTATION Operations personnel should verify the availability of the a. minimum required equipment for the current Reactor Coolant System Condition once per shift, and the availability of the minimum required equipment for the Reactor Coolant System Condition they will be entering prior to entering it. Section IV of this document contains those minimum equipment requirements. b. The current plant status, including the availability of key safety systems or equipment, should be communicated on a regular basis to oersonnel who may affect plant safety. Higher risk evolutions should also be conveyed including any appropriate precautions or compensatory actions necessary during these periods. Areas around protected systems and their power supplies c. should be controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. Special precautions should be taken and pre-job briefings should be conducted for activities taking place within these controlled areas. d. Key shutdown operations protection equipment that is removed from service for maintenance or testing should be returned to service as soon as the maintenance or testing is completed. When the equipment is returned to service, the availability of the equipment and/or system should be assured by post maintenance testing, monitoring of key parameters, verification of alignment and/or administrative control by Operations, as appropriate. Recognition that the performance of individuals will degrade e. without adequate rest after long periods of work has led to the establishment of a plant overtime policy. This policy is contained in Entergy Operations Management Manual, Volume 11, Station Directive A2.201, Overtime. At a minimum, these restrictions on working hours apply to Operations, Health Physics, and Key Maintenance Personnel. e,

f. The Outage Manager has the responsibility to monitor scheduled activities with respect to the initial schedule sequence and approve any significant variations. Any changes will follow the guidelines contained in this document. Any changes that deviate from these guidelines require the completion of Attachment 1, Approval for Departure from the Requirements of the Shutdown Operations Protection Plan. 4. Post OUTAGE a. A post-outage critique should be conducted that assesses outage performance from a safety perspective. The results of the critique should be used as a basis for improvements to planning and control of future outages. l l

r< B. DECAY HEAT REMOVAL EQUIPMENT REQUIREMENTS j 1. Work on systems used for decay heat removal (including spent fuel t cooling) and their attendant support systems should be scheduled in i detail and not allowed to float during the outage. Such work should be scheduled during periods of lowest decay heat to the extent possible. 2. Areas around protected systems and their power supplies should be controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. Special precautions should be taken and pre-job briefings should be conducted for activities taking place within these controlled areas. 3. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance. 4. When the Reactor Coolant System is intact, at least one Steam Generator should be kept available as a method of Decay Heat Removal. This should include the motor operated Emergency Feedwater Pump, its suction and discharge flowpaths from a supply of feedwater to the Steam Generator, and the associated Atmospheric Dump steam flowpath. 5. The Decay Heat System motor operated suction valves from the Reactor Coolant System (CV-1050, CV-1410 and CV-1404) should not be cycled unless the Fuel Transfer Canal is flooded, the Reactor Vessel is defueled, or the Steam Generators are capable of removing decay heat. t 6. Prior to starting a Decay Heat Removal pump after filling and venting the Decay Heat System, ensure there are no fuel handling operations in progress over the reactor vessel. The residual air in the system may degrade the visibility over the vessel for several minutes after starting the pump. During reduced inventory conditions, testing or maintenance that could 7. affect reactor decay heat removal should not be performed on any of the protected Decay Heat Removal systems. If work is required, a contingency plan shall be in place prior to removing the system from service. 8. Work on the Spent Fuel Cooling System should be done non-outage if possible. If work is required on the Spent Fuel Cooling System during the i outage, it should be done as early as possible in the outage and not after i fuel offload (when the heat load is the highest). If work is required after fuel offload, a contingency plan shall be in place prior to removing the system from service.

.i C. INVENTORY CONTROL REQulREMENTS The outage schedule shall delay, to the extent practical, going to reduced 1. RCS inventory conditions when decay heat load is high. Time spent in reduced inventory conditions shall be minimized. If extended operation in this condition is required (i.e., longer than seven days), an assessment. comparing the risks of performing a full core offload to the continued operation in reduced inventory should be performed. Operations crew briefings should be conducted prior to any activity that 2. could change Reactor Coolant System or Spent Fuel Pool inventory. When there is fuel in the reactor vessel, the screen cover should be in 3. place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) In addition, any maintenance s activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expeditious manner and the flowpath returned to service in a timely fashion. When the Fuel Transfer Canal is flooded and there is fuel in the reactor 4. vessel, the sump flowpath associated with the operable Decay Heat t Removal System shall be maintained available. Maintain the incore Instruments pressure boundaries in the bottom of the 5. incore Tankintact unless one of the following conditions exist: At least one Steam Generator primary manway cover is removed a. and there is no other pressure retaining device

• covering the manway, or b.

The Reactor Vessel Head is removed.

• any device that impedes the flow of steam such that the pressure buildup inside the Reactor Coolant System could be greater than 0.4 psig.

The Spent Fuel Cooling and Purification System should be aligned to take 6. suction from and return to the Spent Fuel Pool, and the fuel transfer tube isolation valve SF-45 closed (or the gate between the Spent Fuel Fool and ' a Fuel Tilt Pit installed) any time fuel transfer operations between the Reactor Building and Spent Fuel Pool have been completed or will be significantly delayed. The fuel transfer tube isolation valve SF-45 may be opened prior to Fuel Handling for Fuel Transfer Equipment or Operator checkouts provided the Fuel Transfer Canal in the Reactor Building is flooded to the appropriate level. 9

n. 1 i 7. A hose for use in providing emergency makeup water to the Unit 1 Spent i Fuel Pool from the Unit 2 Service Water connection in the Spent Fuel Pool area should be maintained available in the Spent Fuel Pool area. The i hose should have the appropriate connecting hardware and be of sufficient length to reach Unit One's Spent Fuel Pool. h l i t ) t T ? [ ~ 10 f r

D. ELECTRICAL POWER DISTRIBUTION REcutREMENTs 1. Both Emergency Diesel Generators should be available during any work that reduces the number of off-site power sources to less than two. Work on redundant vital electrical buses should be performed in series, not parallel. 2. Work should not be allowed on electrical buses associated with the operating Decay Heat Removal System. Work is allowed on electrical buses associated with the available standby Decay Heat Removal System provided the work will not de-energize the bus and the Reactor Coolant System level is > 375' elevation. Other work on electrical buses associated with the Decay Heat Removal System should be performed when the associated Decay Heat Removal System is not operating and not required to be operable. 3. Areas around protected systems and their power supplies should be controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. Special precautions should be taken and pre-job briefings should be conducted for activities taking place within these controlled areas. P 4. During reduced inventory conditions with high decay heat load (less than seven days after shutdown), both Emergency Diesel Generators and two off-site power sources should be maintained available. In addition, both vital electrical distribution trains shall be maintained operable. 5. During reduced inventory conditions or when important electrical components of redundant trains are out of service, testing or maintenance should not be allowed on equipment in the switchyard that could affect the power supplies to the plant. Special precautions, such as signs, physical barriers, pre-job briefings, etc. should be taken for activities near incoming and outgoing transmission lines. In addition, the dispatcher should be notified of reduced inventory conditions and requested to limit, to the extent practical, maintenance on equipment outside the switchyard that could affect power supplies to the plant switchyard.

4 E. REACTIVirY CONTROL REQulREMENTs 1. Reactor Coolant System boron concentration requirements for a misplaced fuel assembly shall be maintained while reloading fuel into the reactor vessel. ? 2. When the reactor vessel head is removed, the Reactor Coolant System boron concentration shall be maintained at not less than that required for Refueling Shutdown. 3. When there is fuel in the reactor vessel, at least one source range Nuclear Instrument shall be maintained available in the Control Room. l 4. Prior to draining the Fuel Transfer Canal and again when the canal has been drained to approximately three feet above the canal floor (shallow end), sample the Fuel Transfer Canal water to ensure the boron concentration is greater than the requirements for Refueling Shutdown. This is due to the potential for inadvertent boron dilution during decontamination activities. 5. Operations shall ensure all Reactor Coolant System dilution flowpaths are secured except as required for normal system makeup. This verification should include Hold Carding equipment that is not normally used during outages and shiftly crew briefs on untagged dilution flowpaths. 6. Two emergency boration paths should be maintained available to respond to a boron dilution event. These may be the same paths as the makeup flow paths as long as the boron concentration of the source is greater than that required for the current shutdown condition. 7. While making up to the Reactor Coolant System with Reactor Coolant Pumps off or otherwise raising Reactor Coolant System level, the boron concentration of the makeup water shall be greater than or equal to the concentration required for adequate shutdown margin. I i 12 1

I F. CONTAlf4 MENT REQulREMEf4Ts 1. When there is fuel in the reactor vessel, the capability to close containment within % the calculated time to reach 200 F shall be maintained per section 3.4 of OP-1015.002, Decay Heat Removal and LTOP System Control. This shall include staging of required tools and contingencies for the loss of AC power. i 2. With fuel in the reactor vessel, the containment equipment hatch should not be opened unless it can be closed - i.e., in place with a minimum of four bolts securing the hatch to the sealing surface - within % the calculated time to reach 200 F per section 3.4 of OP-1015.002, Decay Heat Removal and LTOP System Control. 1 3. With fuel in the reactor vessel, any penetration with maintenance or [ testing in progress should have the redundant isolation valve closed, or for penetrations without redundant isolation valves (including electrical penetrations), appropriate plugs or seating material should be available (preferably installed) and that penetration tracked as a penetration breach per procedure OP-1015.002, Decay Heat Removal and LTOP System Control. Specific exceptions are discussed in the referenced procedure. 4. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. 5. Additional Containment Closure controls are contained in OP-1015.002, Decay Heat Removal and LTOP System Control. 6. When there is fuelin the reactor vessel, maintain a minimum of one group of Reactor Building cooling fans available at all times - i.e., one of the four Reactor Building supply fans and an associated supply of cooling water. 7. When the temporary cover (Merrimac) is installed on the Emergency Escape Hatch opening, a specific individual shall be assigned responsibility for containment closure for this penetration. The following are three possible configurations at this hatch and the associated response times / actions for each: a.) Open Penetration through Merrimac or 4" Flanged Barrel Connection (No Foam Seal) The cables / lines must be disconnected or cut and a blank flange installed within % the calculated time to reach 200 F. This is consistent with the requirement for a containment breach. n

F. CONTAINMENT REQUIREMENTS 1. When there is fuel in the reactor vessel, the capability to close containment within % the calculated time to reach 200 F shall be maintained per section 3.4 of OP-1015.002, Decay Heat Removal and LTOP System Control. This shall include staging of required tools and contingencies for the loss of AC power. 2. With fuel in the reactor vessel, the containment equipment hatch should not be opened unless it can be closed - i.e., in place with a minimum of four bolts securing the hatch to the sealing surface - within % the calculated time to reach 200 F per section 3.4 of OP-1015.002, Decay Heat Removal and LTOP System Control. 3. With fuel in the reactor vessel, any penetration with maintenance or. testing in progress should have the redundant isolation valve closed, or for penetrations without redundant isolation valves (including electrical penetrations), appropriate plugs or sealing material should be available (preferably installed) and that penetration tracked as a penetration breach per procedure OP-1015.002, Decay Heat Removal and LTOP System Control. Specific exceptions are discussed in the referenced procedure. 4. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. 5. Additional Containment Closure controls are contained in OP-1015.002, Decay Heat Removal and LTOP System Control. 6. When there is fuelin the reactor vessel, maintain a minimum of one group of Reactor Building cooling fans available at all times - i.e., one of the four Reactor Building supply fans and an associated supply of cooling water. 7. When the temporary cover (Merrimac) is installed on the Emergency Escape Hatch opening, a specific individual shall be assigned responsibility for containment closure for this penetration. The following are three possible configurations at this hatch and the associatcd response times / actions for each: a.) Open Penetration through Merrimac or 4" Flanged Barrel Connection (No Foam Seal) The cables / lines must be disconnected or cut and a blank flange installed within % the calculated time to reach 200 F. This is consistent with the requirement for a containment breach. O

t b.) Penetrations through Merrimac and 4" Flanged Barrel Connections Foam Sealed it has been shown that the foam seals in the Merrimac and 4" penetrations will withstand 6 psi. Calculations show that it will take at least 2 hours after the onset of boiling to develop 6 psi in containment. Therefore, with foam seats, containment closure is f assured for 2 hours after boiling begins, with no additional actions, To ensure containment closure > 2 hours after the onset of boiling either the blank flanges on the Merrimac penetrations will have to i be installed or the outer door of the Emergency Escape Hatch closed. c.) Blank Flanges installed on Merrimac and 4" Flanged Barrel Penetrations Prior to containment reaching 25 psi, all cables / lines running through the outer door of the Emergency Escape Hatch will havs to be disconnected or cut and the outer door closed. The Merrimac is designed and tested to 25 psi. While containment pressures are not expected to exceed 25 psi fo!!owing a loss of decay heat, shutting the outer door of the hatch is a prudent and conservative action. t j u

IV. Minimum Equipment Requirements By RCS Condition This section lists the minimum required equipment for specific Reactor Coolant System Shutdown Conditions. The Shutdown Conditions identified in this section are based on three Reactor Coolant System variables: location of the fuel (any in the reactor vessel or all in the spent fuel pool), integrity of the Reactor Coolant System (open or intact), and the amount of inventory in the Reactor Coolant System / Fuel Transfer Canal. These Shutdown Conditions are numbered from the Condition with the lowest risk to shutdown operations (Condition 1 - Reactor Vessel Defueled) to the Condition with the highest risk (Condition 7 - Reduced Inventory, RCS Open, Fuelin the Reactor Vessel.) Shutdown Condition 1 REACTOR VESSEL DEFUELED ALL FUEL LOCATED IN THE SPENT FUEL POOL [V} A. Decav Heat Removal Ecujoment Recuirements - [ ] 1. Both Spent Fuel Pool Cooling Trains available. (Electrical power may be removed from one train of ICW or one spent fuel cooling pump as long as it can be returned to service within 8 hours.) B. Inventory Control Recuirements - [ ] 1. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Recuirements - [ ] 1. At least one Emergency Diesel Generator anc at least one off-site power supply with the ability to supply power to vital in-plant loads (e.g., Spent Fuel Pool Cooling, ICW.) D. Reactivity Control Recuirements - [ ] 1. Spent Fuel Pool boron concentration > Refueling Shutdown requirement. [ ] 2. An available emergency Spent Fuel Pool boration path. E. Containment Recuirements - None. Note: Operations tracks open containment penetrations for the entire duration of outages. However, with the reactor vesseldefueled, Containment Closure is not a shutdown risk concern. I5

^ ,e-p_ i F. Miscellaneous - ' [ ].1. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. Fuel transfer tube isolation valve SF-45 should be closed or the gate between the Spent Fuel Pool and the Fuel Tilt Pit installed (except when performing Fuel handling equipment or operator checkouts.) i 2. Do not perform any maintenance or testing on, and avoid system alignment chang'es that could cause perturbations to, the Spent Fuel Cooling System. t 3. Operations crew briefings should be conducted prior to any activity 3 that could change Spent Fuel Pool inventory. 4. If work is required on the Spent Fuel Cooling System during the outage, it should not be done after fuel offload (when the heat load is the highest). If work is required after fuel offload, a contingency plan shall be in place prior to removing the system from service. Performed By: Date: Time: Note: Send Copy of this checklist to the Shift Outage Manager if the outage table is manned. f e 1) + l Ib

Shutdown Condition 2 FTC FLOODED > 23' ABOVE CORE NO FUEL HANDLING IN PROGRESS l FUEL IN REACTOR VESSEL [4] A. Decav Heat Removal Eauinment Reauirements - 1 [ ] 1. One Decay Heat Removal Train operable. j [ ] 2. At least one Spent Fuel Pool Cooling Train available. l l B. Inventorv Control Reauirements - -i [ ] 1. Two available RCS inventory makeup flowpaths using any of the following: a. Reactor Building Spray pump recirculation from the Reactor Building sump, b. Decay Heat pump recirculation from the Reactor Building j sump. [ ] 2. An available Reactor Building sump suction flowpath associated with the operable Decay Heat Removal System. [ ] 3. A hose for use in providing emergency makeup water to the Unit 1 l I Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Recuirements - l [ ] 1. Three of the following five electrical power sources available. One l source must be'an EDG. (Circle all available.): a. Startup Transformer #1, l b. Startup Transformer #2, 3 c. Emergency Diesel Generator #1, j d. Emergency Diesel Generator #2, j Unit Auxiliary Transformer powered from the switchyard. e. [ ] 2. An operable vital electrical distribution train (AC and DC) associated with an operable Decay Heat Removal pump able to be powered from an available Emergency Diesel Generator. D. Reactivity Control Reouirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed (except l those used for performing routine inventory additions per approved [ procedures.) List below dilution flowpaths not tagged closed: [ ] 2. RCS boron concentration maintained greater than that required for Refueling Shutdown. [ ] 3. Two emergency boration paths available. [ ] 4. One source range Nuclear Instrument available. j i 17

E. Containment Reauirements - [ ] 1. Ensure containment closure can be accomplished prior to % the calculated time to reach 200 F in the event of a loss of Decay Heat Removal. - (Review current " time to reach 200 F" vs. Form 1015.0020, Containment Closure Determination Sheet, for all currently breached penetrations.) [ ] 2. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Two independent Core Exit Thermocouples available. [ ] 2. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. SF-45 should be closed when fuel transfer operations are complete or are significantly delayed. (SF-45 may be open during fuel transfer equipment and operator checkouts.) t 2. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change Reactor Coolant System or Spent Fuel Pool inventory. 3. The screen cover should be in place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) In addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expeditious manner and the flowpath returned to i service in a timely fashion. 4. When the Fuel Transfer Canal is flooded and there is fuel in the reactor vessel, the sump flowpath associated with the operable Decay Heat Removal System shall be maintained available. 5. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. i Performed Ily: Date: Time: Note: Send Copy or this checklist to the Shift Outage Managerif the outage table is rnanned. 18

Shutdown Condition 3 FTC FLOODED > 23' ABOVE CORE FUEL HANDUNG IN PROGRESS FUEL IN REACTOR VESSEL [$ A. Decav Heat Removal Ecutoment Recuirements - t i [ ] 1. One Decay Heat Removal Train operable. [ ] 2. Both Spent Fuel Pool Cooling Trains available. (Electrical power may be removed from one train of ICW or one spent fuel cooling pump as long as it can be retumed to service within 8 hours.) 8. Inventorv Control Recuirements - [ ] 1. Two available RCS inventory makeup flowpaths using any of the following: i Reactor Building Spray pump recirculation from the Reactor a. Building sump, b. Decay Heat pump recirculation from the Reactor Building sump. [ ] 2. An available Reactor Building sump suction flowpath associated with the operable Decay Heat Removal System. [ ] 3. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Reauirements - [ ] 1. Three of the following five electrical power sources available. One source must be an EDG. (Circle all available.): a. Startup Transformer #1, b. Startup Transformer #2, c. ' Emergency Diesel Generator #1, d. Emergency Diesel Generator #2, e. Unit Auxiliary Transformer powered from the switchyard. ~ [ ] 2. An operable vital electrical distribution train (AC and DC) associated with an operable Decay Heat Removal pump able to be powored from an available Emergency Diesel Generator. D. Reactivity Control Reouirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed. [ ] 2. RCS boron concentration maintained greater than that required for Refueling Shutdown. [ ] 3. RCS boron concentration maintained greater than that required for a Misplaced Fuel Assembly when performing a full core reload. [ ] 4. Both boric acid transfer pumps and an emergency boration flowpath available with at least 3500 gallons (41") of at least 8700 ppm boron in the Boric Acid Addition Tank. [ ] 5. Two source range Nuclear instruments available. 19

E. Containment Recuirements - [ ] 1. Containment Closed. [ ] 2. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Fuel Handling Area ventilation in operation with operable filters. [ ] 2. Spent Fuel Pool Area floor equipment hatch in place. [ ] 3. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. SF-45 should be closed when fuel transfer operations are complete or are significantly delayed. (SF-45 may be open during fuel transfer equipment and operator checkouts.) 2. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change Reactor Coolant System or Spent Fuel Pool inventory. 3. Prior to starting a Decay Heat Removal pump after filling and venting the Decay Hea't System, ensure there are no fuel handling operations in progress over the reactor vessel. The residual ' air in the system may degrade the visibility over the vessel for several minutes after starting the pump. 4. The screen cover shou;d be in place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) in addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expedi30us manner and the flowpath returned to service in a timely fashion. 5. When the Fuel Transfer Canal is flooded and there is fuel in the reactor vessel, the sump flowpath associated with the operable Decay Heat Removal System shall be maintained available. 6. Prior to opening' systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. Performed By: Date: Time: Note: Send Copy of this checklist to the Shift Outage Manager if the outage tabic is manned. 20

Shutdown Condition 4 RCS INTACT RCS LEVEL > 375' FUEL IN REACTOR VESSEL [$ A. Decav Heat Removal Ecoloment Recuirements - [ ] 1. Two of the following four reactor Decay Heat Removal Trains operable per procedure OP-1015.002, Attachment A (circle operable systems): a. "A" Decay Heat System, b. "B" Decay Heat System, c. "A" Loop Reactor Coolant System, d. "B" Loop Reactor Coolant System. [ ] 2. At least one Steam Generator available per Section Ill. B. 4. [ ] 3. At least one Spent Fuel Pool Cooling Train available. B. Inventorv Control Recuirements - [ ] 1. Two High Pressure injection pumps and flowpaths from the Borated Water Storage Tank to the RCS available. [ ] 2. One Reactor Building sump suction flowpath available. [ ] 3. Two independent loop 'B' hot leg level instruments available (except during ' alibration), or RCS filled and vented with a steam c bubble in the Pressurizer. [ ] 4. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Recuirements - [ ] 1. Three of the following five electrical power sources available. One source must be an EDG. (circle all available): a. Startup Transformer #1, b. Startup Transformer #2, c. Emergency Diesel Generator #1, d. Emergency Diesel Generator #2, e. Unit Auxiliary Transformer powered from the switchyard. [ ] 2. Both vital electrical distribution trains (AC and DC) operable. D. Reactivity Control Recuirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed (except those used for performing routine inventory additions per approved procedures.) List below dilution flowpaths not tagged closed: [ ] 2. RCS boron concentration maintained greater than that required by i f OP-1103.015 Reactivity Balance Calculation. 21 1

[ ] 3. Two emergency baration paths available. [ ] 4. One source range Nuclear Instrument available. E. Containment Reauirements - [ ] 1. Ensure containment closure can be accomplished prior to % the j calculated time to reach 200 Fin the event of a loss of Decay Heat Removal. (Review current " time to reach 200'F" vs. Form 1015.0020, Containment Closure Determination Sheet, for all currently breached penetrations.) [ ] 2. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Two independent Core Exit Thermocouples available. [ ] 2. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change Reactor Coolant System or Spent Fuel Poolinventory. 2. The Decay Heat System motor operated suction valves from the Reactor Coolant System (CV-1050, CV-1410 and CV-1404) should not be cycled unless the Fuel Transfer Canal is flooded, the Reactor Vessel is defueled, or the Steam Generators are capable of removing decay heat. 3. The screen cover should be in place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) In addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expeditious manner and the flowpath returned to service in a timely fashion. 4. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. Performed Hy: Date: Time: Note: Send Copy of this checklist to the Shift Outage Manager if the outage table is manned. 22

Shutdown Condition 5 RCS OPEN ~ RCS LEVEL > 375' FTC NOT FLOODED FUEL IN REACTOR VESSEL [$ A. Decav Heat Removal Eauinment Reauirements - [ ] 1. Both Decay Heat Removal Trains operable. [ ] 2. At least one Spent Fuel Pool Cooling Train available. B. Inventorv Control Reauirements - [ ] 1. Two available RCS inventory makeup flowpaths using either of the following: High Pressure injection Pumps from the Borated Water a. Storage Tank, b. Reactor Building Spray pumps from the Borated Water l l Storage Tank. [-] 2. One Reactor Building sump suction flowpath available. i [ ] 3. Two independent loop 'B' hot leg level instruments available (except during calibration.) [ ] 4. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. 1 C. Electrical Power Distribution Recuirements - l [ ] 1. Three of the following five electrical power sources available. One source must be an EDG. (circle all available): j a. Startup Transformer #1, b. Startup Transformer #2, c. Emergency Diesel Generator #1, r d. Emergency Diesel Generator #2, Unit Auxiliary Transformer powered from the switchyard. e. [ ] 2. Both vital electrical distribution trains (AC and DC) operable. D. Reactivity Control Recuirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed (except those used for performing routine inventory additions per approved i procedures.) List below dilution flowpaths not tagged closed: [ ] 2. RCS boron concentration maintained greater than that required by OP-1103.015, Reactivity Balance Calculation. [ ] 3. Two emergency boration paths available. [ [ ] 4. One source range Nuclear Instrument available. i e 23 i n-a,

.s E. Containment Reouirements - [ ] 1. Ensure containment closure can be accomplished prior to % the calculated time to reach 200 F in the event of a loss of Decay Heat Removal. (Review current " time to reach 200 F" vs. Form 1015.002C, Containment Closure Determination Sheet, for all currently breached penetrations.) [ ] 2. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Two independent Core Exit Thermocouples available. [ ] 2. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change Reactor Coolant System or Spent Fuel Pool inventory. 2. The Decay Heat System motor operated suction valves from the Reactor Coolant. System (CV-1050, CV-1410 and CV-1404) should not be cycled unless the Fuel Transfer Canal is flooded, the Reactor Vessel is defueled, or the Steam Generators are capable of removing decay heat. 3. The screen cover should be in place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) in addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expeditious manner and the flowpath returned to service in a timely fashion. 4. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. Performed By: Date: Time: Note: Send Copy of this checklist to the Shift Outage Manager if the outage table is manned. 24

i Shutdown Condition 6 RCS INTACT RCS LEVELS 375' (REDUCED INVENTORY) f FUEL IN REACTOR VESSEL j [4] A. Decav Heat Removal Eculoment Recuirements - [ ] 1. Both Decay Heat Removal Trains operable. [ ] 2. At least one Stesm Generator available per Section 111. B. 4. [ ] 3. At least one Spent Fuel Pool Cooling Train available. B. Inventorv Control Recuirements - [ ] 1. Two High Pressure Injection pumps and flowpaths from the Borated Water Storage Tank to the RCS available. [ ] 2. One Reactor Building sump suction flowpath available. [ ] 3. Two independent loop 'B' hot leg level instruments available. l [ ] 4. Tygon tube level indication available (manned when changing Reactor Coolant System level.) [ ] 5. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Recuirements - [ ] 1. Four of the following five electrical power sources available (circle all available): a. Startup Transformer #1, b. Startup Transformer #2, c. Emergency Diesel Generator #1, d. Emergency Diesel Generator #2, e. Unit Auxiliary Transformer powered from the switchyard. [ ] 2. Both vital electrical distribution trains (AC and DC) operable. [ ] 3. Dispatcher notified shiftly of reduced inventory conditions and requested to limit, to the extent practical, maintenance on equipment outside the switchyard that could affect power supplies to the plant switchyard. D. Reactivity Control Reouirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed (except those used for performing routine inventory additions per approved procedures.) List below dilution flowpaths not tagged closed: [ ] 2. RCS boron concentration maintained greater than that required by OP-1103.015, Reactivity Balance Calculation. [ ] 3. Two emergency boration paths available. [ ] 4. One source range Nuclear instrument available. 25

E. Containment Recuirements - [ ] 1. Maintain the Reactor Building equipment hatch closed unless the calculated time to reach 200 F is greater than or equal to 1 hour. [ ] 2. Ensure containment closure can be accomplished prior to the calculated time to reach 200 Fin the event of a loss of Decay Heat Removal. (Review current " time to reach 200 F" vs. Form 1015.002C, Containment Closure Determination Sheet, for all currently breached penetrations.) [ ] 3. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Two independent Core Exit Thermocouples available. [ ] 2. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. G. Additional Considerations for this RCS Condition - 1. Do not perform any maintenance or testing on any of the protected systems and avoid system alignment changes that could cause Decay Heat Removal System flow or Reactor Coolant System level perturbations. 2. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change Reactor Coolant System or Spent Fuel Pool inventory. 3. The Decay Heat System motor operated suction valves from the Reactor Coolant System (CV-1050, CV-1410 and CV-1404) should i not be cycled unless the Fuel Transfer Canal is flooded, the Reactor Vessel is defueled, or the Steam Generators are capable of removing decay heat. 4. Time spent in reduced inventory conditions shall be minimized. If extended operation in this condition is required (i.e., longer than r seven days), an assessment comparing the risks of performing a full core offload to the continued operation in reduced inventory should be performed. 5. The screen cover should be in place covering the containment l sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed shall be minimized.) In addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be performed in an expeditious manner and the flowpath returned to service in a timely fashion. 26

6. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. P Performed By: Date: Time: Note: Send Copy of this checklist to the Shift Outage Manager if the outage table is inanned. l l l t 27 i [

Shutdown Condition 7 RCS OPEN RCS LEVELS 375' (REDUCED INVENTORY) FUEL IN REACTOR VESSEL [y A. Decav Heat Removal Eculoment Recuirements - [ ] 1. Both Decay Heat Removal Trains operable. [ ] 2. At least one Spent Fuel Pool Cooling Train available. B. Inventerv Control Recuirements - [ ] 1. Two available RCS inventory makeup flowpaths using any of the following: a. High Pressure injection Pumps from the Borated Water Storage Tank, b. Reactor Building Spray pumps from the Borated Water Storage Tank. [ ] 2. One Reactor Building sump suction flowpath available. [ ] 3. Two independent loop 'B' hot leg level instruments available. [ ] 4. Tygon tube level indication available (manned when changing Reactor Coolant System level.) [ ] 5. A hose for use in providing emergency makeup water to the Unit 1 Spent Fuel Pool from the Unit 2 Service Water connection is available in the Spent Fuel Pool area. C. Electrical Power Distribution Recuirements - [ ] 1. Four of the following five electrical power sources available (circle all available): a. Startup Transformer #1,. b. Startup Transformer #2, c. Emergency Diesel Generator #1, d. Emergency Diesel Generator #2, e. Unit Auxiliary Transformer powered from the switchyard. [ ] 2. Both vital electrical distribution trains (AC and DC) operable. [ ] 3. Dispatcher notified shiftly of reduced inventory conditions and requested to limit, to the extent practical, maintenance on equipment outside the switchyard that could affect power supplies to the plant switchyard. D. Reactivity Control Recuirements - [ ] 1. Reactor Coolant System dilution flowpaths tagged closed (except those used for performing routine inventory additions per approved procedures.) List below dilution flowpaths not tagged closed: o 28

t [ ] 2. RCS boron concentration maintained greater than that required by OP-1103.015, Reactivity Balance Calculation. [ ] 3. Two emergency boration paths available. [ ] 4. One source range Nuclear Instrument available. E. Containment Recuirements - [ ] 1. Maintain the Reactor Building equipment hatch closed unless the calculated time to reach 200 F is greater than or equal to 1 hour. [ ] 2. Ensure containment closure can be accomplished prior to the calculated time to reach 200 Fin the event of a loss of Decay Heat Removal. (Review current " time to reach 200 F" vs. Form l 1015.0020, Containment Closure Determination Sheet, for all l currently breached penetrations.) [ ] 3. One Reactor Building Cooling fan and an associated supply of cooling water available. F. Miscellaneous - [ ] 1. Two independent Core Exit Thermocouples available. i [ ] 2. Protected systems and power supplies controlled by physical barriers with signs that require plant personnel to contact the Control Room prior to entry. i G. Additional Considerations for this RCS Condition - 1. Do not perform any maintenance or testing on any of the protected systems and avoid system alignment changes that could cause Decay Heat Removal System flow or Reactor Coolant System level perturbations. 1 2. Operations crew briefings should be conducted prior to any activity that could affect Decay Heat Removal System performance or change' Reactor Coolant System or Spent Fuel Pool inventory. 3. The Decay Heat System motor operated suction valves from the Reactor Coolant System (CV-1050, CV-1410 and CV-1404) should not be cycled unless the Fuel Transfer Canal is flooded, the Reactor Vessel is defueled, or the Steam Generators are capable i of removing decay heat. 4. Time spent in reduced inventory conditions shall be minimized. If extended operation in this condition is required (i.e., longer than seven days), an assessment comparing the risks of performing a full core offload to the continued operation in reduced inventory should be performed. 5. The screen cover should be in place covering the containment sump. (The ends of the screen cover may be removed to perform sump inspections, etc., but the amount of time they are removed [ shall be minimized.) In addition, any maintenance activities performed on the sump suction flowpaths should only remove one flowpath from service at a time. Such maintenance should be 29

P performed in an expeditious manner and the flowpath returned to service in a timely fashion. 6. Prior to opening systems inside containment, ensure containment breaches are considered that are not readily apparent, e.g., steam generator secondary side manway removed with an associated main steam safety valve removed. Performed By: Date: Time: Note: Send Copy of this checklist to the Shift Outage Managerif the outage table is manned. f 4 l L D r

V. Contingency Plans Contingency Plans should be developed for situations where the system availability drops below the planned defense-in-depth and should be available when entering the higher risk evolution for which they were developed. The personnel required to implement the contingency plan should be identified and familiar with the plan. A. Decay Heat Removal 1. REACTOR COOLANT SYSTEM DECAY HEAT REMOVAL - Reactor Coolant System Decay Heat Removal contingencies are covered in Abnormal Operating Procedure OP-1203.028, Loss of Decay Heat Removal System. ~ 2. SPENT FUEL POOL COOLING - Due to the large amount of time required to heat the Spent Fuel Pool to high temperatures, the contingency plan for the loss of Spent Fuel Cooling is to supply emergency makeup water to the Spent Fuel Pool from either unit's Service Water System. B. Reactor Coolant System inventory Control i 1. REACTOR COOLANT SYSTEM INVENTOPY MAKEUP - Reactor Coolant System inventory makeup contingencies are covered in Abnormal Operating Procedure OP-1203.028, Loss of Decay Heat Removal System. Small routine Reactor Coolant System level adjustments are covered in Operating Procedure OP-1103.011, Draining and N2 Blanketing of the RCS. C. Electrical Power Distribution 1. ELECTRICAL POWER - A minimum of three of the five sources of electric power to the vital electrical distribution trains will be maintained available during all outage conditions (except when the core is offloaded), therefore additional electrical power contingencies have not been developed. l l 31

3 i However, if AC power source availability drops below the planned availability, a contingency plan for the use of temporary or alternate AC power should be implemented. D. Reactivity Control 1. EMERGENCY BORATION - Instructions for the addition of boron to the Reactor Coolant System, when it is being cooled by the Decay Heat Removal System, and to the Spent Fuel Pool Cooling System are contained in procedure OP-1104.003, Chemical Addition. E. Containment 1. CONTAINMENT CLOSURE - Containment Closure contingencies are contained in procedure OP-1015.002, Decay Heat Removal and LTOP System Control. if the outage desk is manned, upon notification from the Control Room, the Shift Outage Manager shall notify the Reactor Building Coordinator to activate containment closure. 2. CONTAINMENT COOLING - VSF-1E, using chilled water from VCH-1C, will be used for the Reactor Building cooling contingency. Note: The Reactor Building Purge willhave to be secured and the damper position changedif this contingencyis needed. f e h 32

L; VI. References Generic Letter 82-12 Nuclear Plant Staff Working Hours Generic Letter 83-14 Definition of " Key Maintenance Personnel", (Clarification of Generic Letter 82-12) Generic Letter 87-12 Loss of Residual Heat Removal (RHR) While the Reactor Coolant System is Partially Filled Generic Letter 88-17 Loss of Decay Heat Removal NUREG 1410 Loss of Vital AC Power and the Residual Heat Removal System During Mid-Loop Operations at Vogtle Unit 1 on March 20,1990 INPO 92-005 Guidelines for the Management of Planned Outages at Nuclear Power Stations, June,1992 INPO Document Guidance for Managing Shutdown Safety NUMARC 91-06 Guidelines for Industry Action to Assess Shutdown Management, December,1991 Entergy Operations Mgmt Manual, Volume 11, Station Directive A2.201, Overtime OP-1000.143 Control of infrequently Performed Tests or Evolutions OP-1015.002 Decay Heat Removal and LTOP System Control OP-1102.015 Filling and Draining the Fuel Transfer Canal OP-1103.002 Filling and Venting the Reactor Coolant System OP-1103.011 Draining and N2 Blanketing of the RCS OP-1103.015 Reactivity Balance Calculation OP-1104.003 Chemical Addition OP-1104.006 Spent Fuel Cooling System OP-1203.028 Loss of Decay Heat Removal System OP-1502.004 Refueling Shuffle ANO-92-00487 Memorandum, Eaton to Vandergrift,

Subject:

ANO-1 Loss of Decay Heat Containment Closure ANO-92-00445 Memorandum documenting calculation of time to reach 6 psiin containment after the onset of boiling ~ Calculation 91 E-0052-01 Prevention of ANO-1 RCS Pressurization Due 13 the Loss of Decay Heat Removal, Rev 0 ULD-O-TOP-09 Design Configuration Documentation Project, Upper Level Document / Loss of Decay Heat Removal, Rev A Arkansas Nuclear One 1R10 Shutdown Operations Protection Plan i GPU Nuclear, TMI-1,9R Outage Safety Review Toledo Edison, Davis Besse, Seventh Refueling Outage Safety Review 33

,1 ATTACHMENT 1 APPROVAL FOR DEPARTURE FROM THE REQUIREMENTS OF THE SHUTDOWN OPERATIONS PROTECTION PLAN The intent of the Shutdown Operations Protection Plan is to document a set of unit specific guidelines and minimum equipment requirements by which to conduct outages and thereby maintain nuclear safety _ during shutdown operations. Approval for departure from requirements contained ' in the Shutdown Operations Protection Plan is obtained by filling out this Attachment and obtaining the appropriate signatures. Deviations from guidelines containing a "should" require approval from the Duty Outage Manager or the Project Manager, Outages, Unit One. Deviations from guidelines containing a "shall" require approval from the Plant Manager, Unit One. This approval does DQ1 allow the deviation from Unit One Technical SpecificeGons. 1. Description of departure - what specific requirement will not be satisfied? 2. Why is this departure necessary? 3. Estimated duration departure will be in effect? 4. Will compensatory measures be taken? If not, why not? If so, what are they? / / Originator Date Supervisor Review Date / Approved By:

• Date Duty Outage Manager, Project Manager (Outages) or Plant Manager 34 f

o e j ATTACHMENT 2 I OUTAGE SAFETY REVIEW GulDELINES 1) Prior to the outage and prior to any safety significant changes to the outage schedule after the initial review, the schedule should be critically reviewed by personnel knowledgeable in management expectations for outage nuclear safety and plant operations. The review should not be conducted schly by those directly involved in the development and preparation of the outage schedule. 1 l 2) The outage safety review should assure the adequacy of the Defense in i Depth provided for the duration of the outage and consistency with management's shutdown safety policy. This review should also include a detailed examination of the. outage schedule, including system interactions, support system availability, and the impact of temporarily installed equipment. 3) The outage safety review should ensure that higher risk evolutions are clearly identified in the schedule, and that contingency plans and mitigating procedures have been developed and are adequate. 35

F-I I I I 1R11 OVERVIEW I I I I I PRESENTATION TO NRC I I I I I JULY 19,1993 I I l e I L.

I l I I AGENDA i I 1. INTRODUCTION AND Jim Fisicaro/ l OPENING COMMENTS Jim Vandergrift II. PAST OUTAGE PERFORMANCE / Jim Vandergrift CURRENT OUTAGE EMPHASIS III. OUTAGE ORGANIZATION Jim Vandergrift IV. SHUTDOWN OPERATIONS Danny Roderick l PROTECTION PLAN V. OUTAGE RISK ASSESSMENT Danny Roderick AND MANAGEMENT (ORAM) VI. IR11 OUTAGE SCOPE Tom Brown l AND SCHEDULE l VII. RADIATION PROTECTION EMPHASIS Tom Brown l VIII. CONCLUDING REMARKS Jim Vandergrift I I I I I

l I l I I. INTRODUCTION AND I OPENING COMMENTS I I I I I t I Jim Fisicaro g Jim Vandergrift l l I i I a I I

I I I I II. PAST OUTAGE I PERFORMANCE / I CURRENT OUTAGE I EMPHASIS I I i I I Jim Vandergrift I I I I I I

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I I .I I III. OUTAGE I ORGANIZATION 'I I .I I

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I I AND-I Plant Manager Jim Vandergrift I OUTAGE MANAGER TOM BROWN l l l I l ASST DUTAGE MANAGERS SHIFT OUTAGE MANAGERS OUTAGE SUPPORT DANNY RODERICK JOE CLEMENTS JOHN SELVA PHIL HARRIS ~ STEVE PULLIN RANDALL WALTEPS ~ l I PEACTOR BUILDING C00RD'S APEA COORDINATORS SITE BUSINESS SERVICES INTEGRATED CONTRACT PROJECT COORDINATORS DESIGN ENGINEERING SCHEDULING MAINTENANCE DRAWING CONTROL I OPERATIONS DOCUMENT CONTPOL i HEALTH PHYSICS /DECON LICENSING I I I I

I I I ANO-1 OUTAGE I IMPROVEMENTPLAN I I I Shutdown Safety I I Long Range Plan I I I Dose Reduction I I I I I lI I I

I I I I IV. SHUTDOWN I OPERATIONS I PROTECTION PLAN I I I I l I I Danny Roderick I I I I I I

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I I I I V. OUTAGE RISK I ASSESSMENT AND I MANAGEMENT (ORAM) I I I I I I I Danny Roderick I I I I I I t

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I i Purpose of ORAM-11P I I Validates initial Outage I Schedule I g Timely / accurate assessment y of emergent work I Post outage assessment I capability I I I I I I I I

1 i I g Safety Reviews I l Outage Scheduling Lessons Learned i g Backbone Requirements I Shutdown Operations j l Protection Plan ORAM '11F g I ExternalIndependent Assessments I Operations Support Shift l Multi-Discipline Task Force g Plant Safety Committee I WorkerAwareness l Postings Control of Work g Effective Communications I i l

I I 'I VI. 1R11 OUTAGE SCOPE I AND SCHEDULE I I I I i I I I Tom Brown I I I 1 I I I

I I 1R11 Major Work Scope Items I . acs I 9 L I Refueling In core Shuffle I Reactor Head Cable Replacement I Reactor Cavity Seal Plate I Insulation Replacement Reactor Coolant Pumps I "C&D" Seal Changeouts "D" Pump Alignment I . Stearn Generators 'I 20% Eddy Current Testing 80 Preventative Sleeves I Tube Plug Repair I . Turbine Generator I Refurbish 2 Throttle and Govenor Valves Crawl Through Inspections I I

I I Cross Under Piping Repair Generator End Turn Vibration Repairs . Modifications I 30 DCPs/LCPs l 18 PCs I . Maintenance 706 Corrective Maintenance Job Orders I 465 Preventative Maintenance Job Orders I . Plant H' eat Exchangers Eddy Current Testing Condenser Turbine Coolers High and Low Pressure Feedwater Heaters I ISI Inspections 317 Locations I . Complete Isometeric Update Walkdowns I . Com.plete Electrical Drawing Update Project I . Complete GL 89-10 MOV Testing I I

I I 1R11 DCP's 85-1092 Volts / Hertz & Generator Stator Ground Pmtection 86-1069* Fuel Handling Modifications 89-1022 Switch Gear / Cable Modification for S4.ation Black Out S9-1060 Upgrade ANO-1 Appendix "A" Fire Barriers I 90-1024 T40 A&B High Level Dump Valve Repairs 90-1051 Black Battery Addition 90-1061* Containment Cranes 91-1012 Gears on CV 2613 Actuator on CV-2617,2619,2663, and 2676 91-1013 Decay Heat Removal Vortex Monitonng 91-1015 CV-2630 & 2680 Gears CV-2625/2675 Act. MOD 91-1016 GammaMetnes Cable Support I 91-5001 RadCal Probe Flange Assembly 91-5011 Disc / Gears CV-1206,1234 Actuator MOD CV-1206 92-1007 Millstone Relay Replacement B5/B6 92-1 011 PZR Spray Thermal Stratification /CV-1416 Replacement 92-1016 Replace Agastat Seq. Timers w/ Solid State 92-1020 RCP Snubber Replacement 92-1030* Reactor Cavity Seal Plate 92-5005A RCS Insulation Replacement 92-5012 Steam Generator Manway Lugs I 92-5018 ISO Update Project Generated Modifications 92-5021 Modify EFW Ring Header Supports 92-5029 Replace Various MechanicalSnubbers 92-5031 S/G Primary & See Side Pipe Modifications 92-5038 MOVAT Electrical Calculation Review Modifications 92-5040 Cat.1 Iso Update Ears 92-263,268,494,495,&502 93-1003 161/22 KV Voh Regulator 93-5009* Reactor Head Cabling Replacement I I

m M M M M M M M M M M M M I 1993 EARLY EARLY SEP I OCT START FINISH 6 13 20 27 4 11 18 7SEP93 0:00 $MAINGENEAATdRBAEAKERSOPEN i i m j ). l / l 75EP93 0:00 BSEP93 20: Sg n. (SUNN ARY) l i H BREAVERS OPEN TO COLD SHUTD0WN _ 7SEP93_18_:0_0 tiSEP93 17:59 (St; MARY) RCS CLE P-EARLY BORATICN/H202 FLUSH IEFUE[ LNG _ 8StP9 u t:

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SUMMARY

) SEC SYS AVAIL WOFK WINDOW i i 11SEP93 22-00 10CT93 21:59 I INAIN TUABINE PROJECT ACTIVITY 12SEP93 4: 00 30SEP93 3: 59 I '-'l'AGB"S/G EDDY CURRENT P DJECT (MW TO NW) l(SUNNARY) RCh LEVEL <375' 12SEP93 10: 00 14SEP93 14:59 l (T11CEO INVENTORY 11 (hARY) PREP 3 FOR FUEL HANDLING 17SEP93 2:00 195EP93 2 59 _19SEP93 3:00 26SEP93 22-59 M (StmARY) SW / DH SYS ISOLATION G NAINTENANCE ._195EP93 5: 00 26SEP93 5: 59 I I( ARY) RD TRAIN / K-4A EDG MAI TENANCE _195EP93 19JO 26SEP93 5:59 m (SUNN ARY) FUEL SHUFFLE / VERIFICATIGN SEQUENCE _25SEP93 3:00 26SEP93 11: 59 SUNNARY) K-4 A ( D) EDG OPERABILITY TESTING 25SEP93 3:00 30SEP93 10: 59 I I (SJNNARYI K-4B OOS (*B" E'NER DIESEL GEN) NAINT 275EP93 0:00 10CT93 12: 59 (SUN *ARY1 Ax VESSEL HEAD T IN3TALLATION SEQUENCE (SUNNARY) K-48 (GREEN) EDG OPERABILITY fTESTING 30SEP93 11: 00 10CT93 19: 59 10CT93 __ 5: 00 20CT93 18: 59 (SUNNARY) RCS LEVEL <3 (AE00CED INVENTORY f 2) 30CT93 3: 00 40CT93 2:59 E1305.06 ENGINEEREC SAFEGUARDS TE ST 40CT93 3:00 50CT93 16: 59 ISU"N AR Y) PAEPS FOR AND RCS FILL G VENT _40CT93 15: 00 50CT93 14: 59 PEWORN FEEDWATER CLEANUP 50CT93 17: 00 110CT93 2 59 ISUNN ARV) PRE FOR AND RCS HE AfLP M 90CT93 7:00 90CT93 16: 59 (SUNN ARY) CONTAINNENT INTEGRITY E T ABLISHNENT l 110CT93 3:00 140CT93 22-59 (Sl*ARY1 HOT UTDOWN TESTING,fDURING STARTUP) ; 140CT93 23: 00 180CT93 5: Sg IStmAAY) CRIT /wEps F0h LDw p0WER puyS'ICS TEST M l I _i_80CT93 6:00 190CT93 19: 59 (SLMARY) FHEPS FOR AND TURO ROLL TO ON-LINE 190CT93 20: 00 190CT93 19: 59 ENERAT BEAKERS CLOSE / TUFUINE ON-LINE $ i ~ EdU S% UU$N _ _, $ F*** E!;itRGY OPERATIONS INC / ANO AS OF: 16 JULY 1993 ~ ~ " " ' " '

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U-1 REFUELING OUTAGE NASTER SEP 93 NANAGEMENT

SUMMARY

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aus man sua em use sum man man aus uma man man sua man aus uma man ANO-1 Long Rangc Otutage Plan Summary 1R11 1E12 1R13 1E14 1E15 Fall 1993 Spring 1995 Fall 1996 Spring 1998 Fall 1999 Duration (days) 44 52 44 42 42 ALABA 300 250 225 225 190 l _(_ Man-Rem)_ ElectricalTrain Work odd even odd even odd Red Green Red Green Red EDG Work Both Both A* B* A" Service Water Work Loop 1 Loop 2 and Loop 1 Loop 2 Loop 1 Return ~ Decay Neat Work A Both A B A Turbine Generator Work Generator NP LP-A LP-B FW POMP Bepair LP-B Generator Reactor Woak Shuffle Offload Shuffle Shuffie Shuffle Startup Transformer Work Sut1 sus 2 Sut1 sus 2 Sut1 Beactor Building Work South Cavity North Cavity South Cavity North Cavity South Cavity ILRT No Yes No Yes No ~0TSG 20% ECT, 20% ECT, 20X ECT, 20x ECT 20% ECT Plug Removal Plug Bem.t Sec. Plug Removal Side Insp RCPs

• D' Seall*C' Seal
• D* Motor / Seal

'C' Motor / Seal 'A' Motor / Seal

• B* Motor / Seal Pressurizer Inspect Neater Repair Insulation Replacement
• B* StG-South

'A' StG-North BCS South RCS North RCS South Cavity Cavity Cavity Cavity Cavity Assumes Black Diesel will allow on-line EDG maintenance. ~

I I I I VII. RADIATION 'I PROTECTION I EMPHASIS I I I I I I I Tom Brown I I I I I

I I t I Dose Reduction I Initiatives I I H2O2 Addition I I Early Boration I 1 I Dose Budgeting I

I ALARA Updates I

Decon Plan I I Modifications I I I

I I I VIII. CONCLUDING I REMARKS I I 4 I I I I I I Jim Vandergrift I I I I I I

D> Dl I: Il 1 1 l l I l l I 1 i i i i ENTERGY OPERATIONS, INC. Route 3, Box 137G g m Russellville, Arkansas 72801 3 = ENTERGY Tel. 501-964-5000 An Entergy Company s El u I , _ _ _}}