Text

Forwards Review Results of Limiting Conditions for Operation (Lco).Lcos Could Be Clarified to Improve Quality
	ML20128D738
Person / Time
Site:	Fort Calhoun
Issue date:	06/20/1985
From:	Butcher E; Office of Nuclear Reactor Regulation
To:	Andrews R; OMAHA PUBLIC POWER DISTRICT
References
	NUDOCS 8507050185
	Download: ML20128D738 (17)
	v • d • e

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June 20, 1985 Docket No. 50-285 Mr. R. L. Andrews Division Manager - Nuclear Production Omaha Public Power District 1623 Harney Street Omaha, Nebraska 68102

Dear Mr. Andrews:

As you know, a Technical Specification Improvement Project (TSIP) is underway within the Comission. As a part of the TSIP, project managers were requested to provide input. Ed Tourigny, the NRR Project Manager for Fort Calhoun, undertook a review of the Fort Calhoun Technical Specifications Limiting Conditions for Operations (LCOs) to determine if all the current LCOs had action statements and applicable operating modes associated with them. As a result of his review, he concluded that some LCOs could be clarified to improve the quality of the Fort Calhoun Station LCOs. A copy of his study was provided to the TSIP for use in their program. A copy is enclosed for your information.

Sincerely, 20rl;inald;;ned by i

Edward J. Butcher, Acting Chief Operating Reactors Branch No. 3 Division of Licensing

Enclosure:

As stated cc w/ enclosure:

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Mr. R. L. Andrews Omaha Public Power District Ft. Calhoun Station, Unit No. 1 Harry H. Voigt, Esquire LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 Mr. Jack Jensen, Chairman Washington County Board of Supervisors Blair, Nebraska 68023 Metropolitan Planning Agency ATTN: Dagnia Prieditis 7000 West Center Road Omaha, Nebraska 68107 Mr. Larry Yandell U.S. NRC Resident Inspector Post Office Box 309 Fort Calhoun, Nebraska 68023 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations C-E Power Systems 7910 Woodmont Avenue Bethesda, Maryland 20814 Regional Administrator USNRC, Region IV Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 i

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i pe" THE FORT CALHOUN STATION LIMITING CONDITIONS FOR OPERATION REVIEW March 1985 4

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. Introduction A review of the Fort Calhoun Technical Specification Limiting-Conditions for Operation (LCOs) was undertaken to determine if all the current LCOs had action statements and applicable operating modes associated with them. The review assumed that the current LCOs were adequate, and no comparison to the Combustion Engineering Standard Technical Specifications was made. Current LCOs included all amendments issued through Amendment Number 85 which was issued on October 11, 1984. The LCOs associated with radiological effluents in air and water (LCOs 2.9(1) and (2)) were not reviewed because a major updating of these LCOs is currently taking place.

Action statements are associated with LCOs to enable the licensee to detennine what action should be taken upon entering the LCO. The action ranges from correcting the situation within a specific time frame in that operating mode to placing the unit in cold shutdown within a specific time frame. The action staterent part of the review was further subdivided into two parts. One part dealt with the action statement being addressed in the LCO itself. The other part dealt with the action statement being addressed in the general requirements LCO. Basically, the general requirements LCO contains action statements that are applicable to a specific LCO when an action statement is ~

not addressed in that specific LCO or when the action statement associated with a specific LCO cannot be satisfied.

It should be noted that, for purposes of this review, a LCO is different than an action statement. A LCO is a condition; an action statement is what the licensee must do if the condition cannot be satisfied.

Applicable operating modes are associated with LCOs to enable the licensee to determine what mode a given LCO is in effect.

In the Fort Calhoun Station case, Table 1 illustrates the operating modes and their definitions. The Fort Calhoun Station operating modes are different from the operational modes contained in the Combustion Engineering Standard Technical Specifications.

LCO Action Statements Review Table 2 illustrates the LCOs that have action statements that are part of the LCO. Table 3 illustrates the LCOs that do not have action statements that are part of the LCO.

It should be noted that only the LC0 numbers are given in the Tables. The actual technical specifications must be referred to for the specific LC0 language.

The following paragraphs contain problems that were found with the LCOs.

In general, the problems are that the LCOs are really action statements.

Possible improvements are illustrated.

LCO 2.1.1(2) - RCS Operable Components - Hot Shutdown or 300*F 1 T 5154 cold i LCO 2.1.1.(2,)(a)(b) states that at least one of the loops shall be in identifies the reactor coolant loops that shall be operable and LCO 2.1.1(2) operation. However,LCO2.1.1(2)(c)containsanactionstatementdealing with an insufficient number of operable reactor coolant pumps. One improvement might be to delete LCO 2.1.1(2)(c) and the wording contained in this LCO 2.1.1.(2)(c) be made a part of LCOs 2.1.1(2)(a) and 2.1.1(2)(b).

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' LCO 2.1.1(3) - RCS Operable Components - Cold Shutdown or cold 1 3004 210*F 1 T LCO 2.1.1(3)(b) states that at least one decay heat removal loop must be in operation. However, LCO 2.1.1(3)(c) contains an action statement-if no coolant loop is in operation. An improvement might be to delete LC0 2.1.1(3)(c) and the wording contained in this LC0 be made a part of LC0 2.1.1(3)(b).

LCO 2.1.1(12) - RCS Pressure Isolation Valves LCO2.1.1(12)(a)requiresdemonstrationofpressureisolationvalveintegrity.

1 LC0 2.1.1(12)(b) provides conditions to remain in operation if the integrity of any valve cannot be demonstrated. However, LCO 2.1.1(12)(c) contains an action statement applicable if the first two LCOs cannot be met. An improvement might be to delete LC0 2.1.1(12)(c) and the wording contained in this LCO be made a part of the first two LCOs.

LCO 2.1.2(1) through (5) - RCS Heatup and Cooldown Rate LCOs 2.1.2(1) through 2.1.2(4) contain requirements for heatup and cooldown.

However, LCO 2.1.2(5) contains an action statement if any one of the four requirements cannot be met. AnimprovementmightbetodeleteLCO2.1.2(5) and.the wording contained in this LCO be made a part of the first four LCOs.

LCO 2.1.2(6) - Change of Heatup and Cooldown Figures i

No specific action statement is specified if this LCO is not met.

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addition, applying the general requirements LCO may not be appropriate. An improvement might be to add a statement to state:

"The provisions of Specification 2.0.1 are not applicable." Another improvement might be to add an action statement to comply with the specification within a certain time frame.

LCO 2.1.3(1) through (5) - RCS Radioactivity LCO 2.1.3(1) provides upper limits of coolant radioactivity. However, LCOs 2.1.3(2)through(5)provideactionstatementsifthelimitscannotbe satisfied. An improvement might be to delete LCOs 2.1.3(2) through (5) and the action statements be made a part of LCO 2.1.3(1).

LCO2.1.4(1)and(2)-RCSLeakageLimits LCOs 2.1.4(1) and (2) are action statements. An improvement for specification (1) might be to start off the specification with the words "The reactor coolant system leakage shall not exceed 1 gpm." An improvement for specification (2) might be to start off the specification with the words "The reactor coolant system leakage shall not exceed 10 gpm."

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. LCO 2.1.5(1) through (5) - Maximum Reactor Coolant Oxygen and Halogens Concentrations LCOs 2.1.5(1) through (5) are action statements. An improvment might be to state the specific LCO at the beginning of every specification. For example, the first sentence for specification (1) might read "The concentration of oxygen in the reactor coolant shall not exceed 0.1 ppm during power operation."

LCO 2.1.8 - RCS Vents LC0 2.1.8(1) contains operability requirements for the RCS Vents. However, LCOs 2.1.8(2) and 2.1.8(3) contain action statements if the operability requirements cannot be met. An improvement might be to delete LCOs 2.1.8(2) and 2.1.8(3) and make these action statements a part of LCO 2.1.8(1).

Unnumbered LCO - Refueling Operations, Irradiated Fuel Movement After Shutdown Page 2-38 of the technical specifications contains an unnumbered LCO. An improvement might be to number the LCO and add an action statement.

LCO 2.11 - Containment Building Crane and Fuel Storage Building Crane No action statements are specified if loads are carried over the RCS or Spent Fuel.

In addition, applying the general requirements LCO may not be appropriate. An improvement might be to add the following statement to the LCO:

"The provisions of Specification 2.0.1 are not applicable. When the requirements of this specification are not satisfied, immediately place the load in a safe condition."

LCO 2.12(1) - Control Room Temperature LCO 2.12(1) is an action statement. An improvement might be to start off the specification with the words "The control room air temperature shall not reach 120*F."

LCO 2.12(2) - Control Room Thermometer No action statement is specified if a thermometer is not in the control room.

In addition, applying the general requirements LCO may not be appropriate.

l An improvement might be to add the following statement to the LCO:

"The l

provisions of Specification 2.0.1 are not applicable.

Place a thermometer in the control room within "X" hours when the specification is not met."

LCO 2.12(3) - Plant Temperature Monitoring This LCO requires plant temperature monitoring of areas containing safety related instrumentation. No action statement is specified if this LCO is not met.

In addition, applying the general requirement LCO may not be appropriate.

1 An improvement might be to add the following statement to the LCO:

"The provisions of Specification 2.0.1 are not applicable.

If this specification is not met, take action within "X" hours to meet this specification."

LCO 2.16 - River Level LCOs 2.16(1) and (2) are action statements. An improvement might be to state the specific LCO as follows: " Reactor operation is permissible when' the Missouri River level is between 976 feet, 9 inches and 1009 feet.'t 4

LCO2.18-ShockSuppressors(Snubbers)

These LCOs require shock suppressors to be operable, provide conditions for removing a snubber for surveillance, and provide conditions for adding, l

changing or deleting snubbers. However, LC0 2.18(2) is an action statement dealing with one or more inoperable snubbers. An improvement might be to i

delete this LCO and make this action statement a part of LC0 2.18(1).

LCO 2.19 except 2.19(3), (4)b - Fire Protection System These LCOs address requirements for fire detection instrumentation and fire j

suppression systems. These LCOs contain action statements but the action statements do not address shutting down the plant. One may argue that the 9eneral requirement LCO on plant shutdown is then applicable.

It is not the intent to shut down the plant if these LCOs cannot be met. An improvement might be to add the following statement to these LCOs: "The provisions of e

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specification 2.0.1 are not applicable."

"* ^ LCO 2.20 - Steam Generator Coolant Radioactivity LCO2.20(1)providesconditionsforsecondarysystemradioactivity. However, LCO 2.20(2) contains an action statement if LCO 2.20(1) cannot be met. An improvement might be to delete LCO 2.20(2) and make this statement a part of LCO 2.20(1).

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i LCO Applicable Operation Modes Review l

Table 4 illustrates the LCOs where applicable operation modes are not stated l

or when it is unclear when the LCOs are in effect.

It should be noted that only the LCO numbers are given in the table; the actual technical specifications must be referred to for the specific LCO language. The following paragraphs identify the problems in more detail.

It should be noted that some LCOs specify "when the reactor is critical", "when fuel is in the reactor", "when the RCS is above 300*F", "during scheduled heat up and cooldowns," etc. instead of naming the actual modes. One may say that the modes are not specifically specified; however, these LCOs are not included in Table 4 because the operator still knows when these LCOs are applicable.

LCO 2.1.1(7), LCO 2.1.1(9) through (12) - RCS Operable Components l

LCOs 2.1.1(7), 2.1.1(9), and 2.1.1(10) deal with pressure testing. An improvement might be to add the following statement to these LCOs:

"This specification is in effect at all times." LCO 2.1.1(11) deals with starting a non-operating reactor coolant pump. An improvement might be to add the following statement to this LCO:

"This specification is in effect at all times." LCO 2.1.1(12) deals with RCS pressure isolation valves. An improvewent might be to amend this LCO to specify when it is in effect.

LCO 2.1.3 - Reactor Coolant Radioactivity These LCOs deal with reactor coolant radioactivity. An improv.ement might be to amend these LCOs to include the operating modes that the LCOs are in effect.

LCO 2.1.4 except 2.1.4(4), (5) - RCS Leakage Limits These LCOs deal with reactor coolant system leakage. An improvement might be to amend these LCOs to include the operating modes that the LCOs are in effect.

LCO 2.6(2) - Containment Internal Pressure This LCO deals with containment internal pressure. An improvement might be to amend this LCO to include the operating modes that the LCO is in effect.

LCO 2.11(2) - Loads Over Spent Fuel This LCO deals with not allowing material to be carried over spent fuel located in the spent fuel pool. This LCO could be amended to specify that the LCO is in effect whenever there are spent fuel assemblies located in the spent fuel pool. Spent fuel is currently in the pool and will remain there for the fores.ee-able future. Therefore, no change is suggested from a practical point of view.

LCO 2.12(1) - Control Room Air Temperature This LCO deals with not allowing the temperature in the control room to exceed 120'F. An improvement might be to amend this LCO to specify that the LCO is in effect at all times.

l LCO 2.13(1) - Nuclear Detector Cooling System This LCO deals with not allowing the concrete temperature to exceed 150*F.

An improvement might be to amend this LCO to specify that the LCO is in effect whenever the reactor is in service.

It should be noted that this is the same applicability used for the temperature detectors to be in service (LCO 2.13(2)).

In addition, the tem " reactor is in service" may lead to different interpretations.

A further improvement might be to define this tenn.

LCO 2.14 - ESF Instrumentation Settings This LCO deals with the engineered safety features system initiation instrumentation settings. An improvement might be to amend the LCO to specify when the LCO is in effect on a channel basis.

LCO 2.15 - Instrument Operating Requirements This LCO references tables dealing with operability for reactor protection system channels, engineered safety features channels, isolation channels, and other safety feature channels. An improvement might be to amend the LCO to specify when the LCO is in effect on a channel basis.

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E LC0 2.16 - River Level These LCOs address plant operation based on river level. An improvement might be to amend the LCOs to include the operating modes that the LCOs are in effect.

LCO 2.17 - Miscellaneous Radioactive Material Sources This LCO addresses miscellaneous radioactive material sources. An improvement might be to amend this LCO is in effect at all times.

A fr Md. cLt ;f LCO 2.19 - Fire Protection System These LCOs deal with the fire detection and suppression systems. An improvement might be to amend the LCOs to state that these systems must be operable whenever equipment protected by these systems must be operable.

LCO 2.20 - Steam Generator Coolant Radioactivity These LCOs deal with steam generator coolant radioactivity. An improvement might be to amend these LCOs to include the operating modes that the LCOs are~

in effect.

Other Problems LCO 2.0.1(1), (2) - General Requirements LCO The general requirements LCO contain action statements that must be used if (1) the action statement in a specific LCO cannot be met or (2) the specific LCO does not contain a specific action statement. The action statement is a three phased one: hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , subcritical and less than 300*F within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and cold shutdown within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The problem envisioned has to do with the phrase "subcritical and less than 300*F."

l The reactor must be subcritical in the hot shutdown condition. Therefore.

l repeating the subcritical requirement does not appear to be necessary for the l

second phase. The less than 300*F requirement does not have a temperature reference.

Is it T T

or T

? An improvement might be to modify thisLCOtodeleteg}d'ec8X8,phaseMdreplacethesecondphasewiththe H

words "Tcold < 300*F within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

- Action Statements Timing Inconsistencies i

Table 5 illustrates the results of an action statements timing review.

It should be noted that only the LCO numbers are given in the table. The actual technical specifications must be referred to for the specific LC0 language.

The times required to reach hot standby, hot shutdown, and cold shutdown are 1

i varied throughout the LCOs. The times required to reach hot standby are 6 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The times required to reach hot shutdown are 2, 4, 6 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

l In addition, some LCOs do not specify the time to reach hot shutdown. The times required to reach cold shutdown are 12, 24, 30 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

In addition, some LCOs do not specify the time to reach cold shutdown.

It is not good practice to have so many varied times to reach the hot and cold shutdown conditions j

from an operator's point of view. An improvement might be to adopt a standardized j

set of times to place the reactor in hot standby, hot shutdown, and cold shutdown, i

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8-Operating Mode " Dead Band" There currently exists an operating mode " dead band" in the technical specifications. The cold shutdown condition is in effect when T is less

-ifOhYeater ThehotshutdownconditionisineffectwhenTlEEm(RCS)isata than 210 F.

The " dead band" is when the reactor coolant sy than 515*F.

temperature in between; the operator does not know explicitly what LCOs are in effect. One improvement might be to define a mode to cover this " dead band". Another improvement might be to define what LCOs are in effect when the RCS is in this " dead band".

Summary As can be seen from the review contained in the previous pages, there is room for clarification in the Fort Calhoun Station LCOs. The objective is to have a specified and appropriate action statement for every LCO, and to know when a LCO is in effect. This is currently not the case and these inconsistencies can cause confusion and mistakes. The licensee may want to apply for technical specification changes to clarify the LCOs discussed in this review.

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-g-TABLE 1 Fort Calhoun Station Operating Modes PowerOperationCondition(OperatingMode1)

The reactor is in the power operation condition when it is critical and the neutron flux power range instrumentation indicttes greater than 2% of rated power.

HotStandbyCondition(OperatingMode2)

The reactor is considered to be in a hot standby condition if the average is critical, and the neutron flux pow $f9)ange instrumentation indicates less temperature of the reactor coolant (T is greater than 515'F, the reactor r

than 2% of rated power.

HotShutdownCondition(OperatingMode3)

The reactor is in a hot shutdown condition if the average temperature of the reactorcoolant(T

) is greater than 515'F and the reactor is suberitical 3

by at least the am8uRt defined in Paragraph 2.10.2.

ColdShutdownCondition(OperatingMode4)

The reactor coolant T less than 210 F and the reactor coolant is at shutdownboronconcen91Iton.

Refueling Shutdown Condition (Operating Mode 5)

The reactor coolant is at refueling boron concentration and T is less cold than 210*F.

TABLE 2 Limiting Conditions for Operation that have Action Statements.that are part of the LCO*.

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2.0.1(1) 2.4(1) 2.0.1(?)

2.4(2) 2.1.1(2) 2.7(2) 2.1.1(3) 2.8(1) through (12) 2.1.1(12) 2.10.2(1)through2.10.2(9) 2.1.2(1 through (5) 2.10.3(2)through2.10.3(4) 2.1.3(1 through (5) 2.10.4(1) through 2.10.4(5) 2.1.4(1 through (3) 2.12(1) 2.1.5(1) through (5) 2.12(4) 2.1.6(4) 2.15 2.1.6(5) 2.16(1) 2.1.7(1) 2.16(2) 2.1.8(1) through (3) 2.17 2.2(3) 2.18 2.3(2) 2.19(1) through (8) 2.20 2.21

Note - It should be recognized that, if the action statement that is part of the LCO cannot be met, then the general action statement must be used unless otherwise noted.

TABLE 3 Limiting Conditions for Operation that do not have Action Stat.elnents that are part of the LCO, and therefore, the general requirements LCO must be used unless otherwise noted.

2.1.1(1) 2.5(1 through (4) 2.1.1(4) through (11) 2.6(1 2.1.2(6) 2.6(2 2.1.4(4) 2.7(1) 2.1.4(5) 2.10.1(1)through(4) 2.1.6(1) through (3) 2.10.3(1) 2.2(1) 2.11(1) 2.2(2) 2.11(2) 2.3(1) 2.12(2) 2.3(3) 2.12(3) 2.13(1) s 2.13(2) 2.14 A

TABLE 4 LCOs where applicable modes are not stated or when it is unclear when the LCOs are in effect.

2.1.1(7) 2.1.1(9) through (12) 2.1.3 2.1.4 except 2.1.4(4), (5) 2.6(2) 2.11 2.12 2.13 2.14 2.15 2.16 2.17 2.19 2.20

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Action Statements Timing Inconsistencies i

LCO NUMBER ACTION STATEMENT TIMING LCO 2.0.1(1), (2) hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , subcritical and < 300*F within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in at least cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months LC02.1.1(2)(c) cold shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(reference mode is hot shutdown or cold i 515'F) 300'F < T LCO2.1.1(12)(c) cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3

LCO2.1.2(5)(c) cold shutdown within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 3

LCO 2.1.3(3), -(4) at least hot shutdown within T

< 536'F 1

within6hoursifnotfixedwitMinspecified -

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time interval or greater than a certain concentration LCO2.1.4(1) hot shutdown condition (no time specified) if not identified with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ', cold shutdown condition (no time specified) if not identified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LCO2.1.4(2) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , cold shutdown condition (no time specified) i LCO2.1.4(3) cold shutdown condition within the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if not fixed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1

LCO2.1.5(5) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months there-after if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 4

LCO2.1.6(4) rimary system must be depressurized and vented p(no mode specified nor any time specified)

LCO 2.1.6.a. b hot standby within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , if not fixed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; cold shutdown within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LCO2.1.7(1)(a),b hot shutdown within the following(a) hours 12 if not fixed.within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for (b)

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LCO2.1.8(2),(3) hot standby within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if-mot fixed within 30 days for (2) or within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for (3); cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months LCO2.2(3) hot shutdown condition in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if not fixed during the specified time; cold shutdown shall be initiated (no time specified to reach cold shutdown) if not fixed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months LCO2.3(2) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 'if not fixed within the specified time; cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if not fixed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months LCO2.4(1) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if not fixed within seven dayst cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if not fixed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months LCO2.4(2) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if not fixed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months LCO2.7(2) hot shutdown condition within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if not fixed in the specified time; cold shutdown condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LCO2.10.2(3) hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if not fixed within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months LCO2.10.2(4) hot shutdown within the specified hours if not fixed within the specified hours LCO2.10.2(5) hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if not fixed within one hour LCO2.10.2(7)c hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if not fixed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LCO2.10.2(9)a(iii) hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if specification 2.10.4(1) cannot be met fpowercan$be LCO2.10.2(9)c(ii)2 hot shutdown in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months j% within 15 minutes reduced to less than 10~

LCO2.10.4(1),(2),(3),(4) hot standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if not fixed within specified times

LCO2.12(1) hot shutdown condition (no time-specified) if not fixed within four hours LCO 2.12(4) cold shutdown condition within.24' hours if not fixed within seven days LCO 2.15 hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; cold shutdown within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LCO 2.16 cold shutdown condition (no time specified)

LCO 2.19(4)b(iii) hot standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if not fixed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; cold shutdown within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months LCO2.20(2) hot shutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months LCO 2.21 hot shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if not fixed within specified times

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ML20128D738

Text

Dear Mr. Andrews:

Enclosure:

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