Text

Issuance of Amendment No. 322 Technical Specification Changes Related to Revised Fuel Handling Accident Analysis and Adoption of Technical Specification Improvements Consistent with NUREG-1432
	ML20240A280
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/30/2020
From:	Thomas Wengert; Plant Licensing Branch IV
To:	; Entergy Operations
	Wengert T
References
	EPID L-2019-LLA-0188
	Download: ML20240A280 (57)
	v • d • e

October 30, 2020 ANO Site Vice President Arkansas Nuclear One Entergy Operations, Inc.

N-TSB-58 1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT 2 - ISSUANCE OF AMENDMENT NO. 322 RE: TECHNICAL SPECIFICATIONS CHANGES RELATED TO REVISED FUEL HANDLING ACCIDENT ANALYSIS AND ADOPTION OF TECHNICAL SPECIFICATIONS IMPROVEMENTS CONSISTENT WITH NUREG-1432 (EPID L-2019-LLA-0188)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 322 to Renewed Facility Operating License No. NPF-6 for Arkansas Nuclear One, Unit 2 (ANO-2). The amendment consists of changes to the technical specifications (TSs) in response to your application dated August 29, 2019.

The amendment modifies multiple TSs for ANO-2 to address non-conservative TS Applicability statements associated with the movement of fuel assemblies. The amendment also modifies these TSs and related TSs to gain greater consistency with NUREG-1432, Revision 4, Standard Technical Specifications Combustion Engineering Plants.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosures:

1. Amendment No. 322 to NPF-6

2. Safety Evaluation cc: Listserv

ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368 ARKANSAS NUCLEAR ONE, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 322 Renewed License No. NPF-6

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Operations, Inc. (the licensee), dated August 29, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-6 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications

3. This amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jennifer L. Dixon-Herrity Jennifer L. Dixon-Herrity Date: 2020.10.30 08:10:35 -04'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-6 and the Technical Specifications Date of Issuance: October 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 322 RENEWED FACILITY OPERATING LICENSE NO. NPF-6 ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368 Replace the following pages of Renewed Facility Operating License No. NPF-6 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 1-3 1-3 3/4 1-4 3/4 1-4 3/4 3-25 3/4 3-25 3/4 3-26 3/4 3-26 3/4 3-26a 3/4 3-26a 3/4 3-27 3/4 3-27 3/4 3-28 ---

3/4 4-2 3/4 4-2 3/4 4-2a 3/4 4-2a 3/4 7-17 3/4 7-17 3/4 7-17a 3/4 7-17a 3/4 8-5 3/4 8-5 3/4 8-7 3/4 8-7 3/4 8-10 3/4 8-10 3/4 9-1 3/4 9-1 3/4 9-2 3/4 9-2 3/4 9-4 3/4 9-4 3/4 9-6 3/4 9-6 3/4 9-9 3/4 9-9 3/4 9-10 3/4 9-10

3 (4) EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) EOI, pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) EOI, pursuant to the Act and 10 CFR Parts 30 and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to conditions specified in the following Commission regulations in 10 CFR Chapter I; Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level EOI is authorized to operate the facility at steady state reactor core power levels not in excess of 3026 megawatts thermal. Prior to attaining this power level EOI shall comply with the conditions in Paragraph 2.C.(3).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 322, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

Exemptive 2nd paragraph of 2.C.2 deleted per Amendment 20, 3/3/81.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following issuance of the renewed license or within the operational restrictions indicated.

The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission.

2.C.(3)(a) Deleted per Amendment 24, 6/19/81.

Renewed License No. NPF-6 Amendment No. 322

DEFINITIONS CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be:

a. Analog channels - The injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.

b. Bistable channels - The injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.

c. Digital computer channels - The exercising of the digital computer hardware using diagnostic programs and the injection of simulated process data into the channel to verify OPERABILITY.

The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

SHUTDOWN MARGIN 1.13 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all control element assemblies are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn.

IDENTIFIED LEAKAGE 1.14 IDENTIFIED LEAKAGE shall be:

a. Leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or

c. Reactor coolant system leakage through a steam generator to the secondary system (primary to secondary leakage).

ARKANSAS - UNIT 2 1-3 Amendment No. 157,220,255,266, 319, 322

REACTIVITY CONTROL SYSTEMS BORON DILUTION LIMITING CONDITION FOR OPERATION 3.1.1.3 The flow rate of reactor coolant through the Reactor Coolant System (RCS) shall be 2000 gpm whenever a reduction in RCS boron concentration is being made.

APPLICABILITY: ALL MODES.

ACTION:

With the flow rate of reactor coolant through the RCS < 2000 gpm, immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM or boron concentration of LCO 3.1.1.1, LCO 3.1.1.2, or LCO 3.9.1, as applicable.

SURVEILLANCE REQUIREMENTS 4.1.1.3 The flow rate of reactor coolant through the RCS shall be determined to be 2000 gpm within one hour prior to the start of and in accordance with the Surveillance Frequency Control Program during a reduction in the RCS boron concentration by either:

a. Verifying at least one reactor coolant pump is in operation, or

b. Verifying that at least one low pressure safety injection pump or containment spray pump is in operation as a shutdown cooling pump and supplying 2000 gpm through the RCS.

ARKANSAS - UNIT 2 3/4 1-4 Amendment No. 126,255,315, 322

TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION MINIMUM CHANNELS APPLICABLE ALARM/TRIP MEASUREMENT INSTRUMENT OPERABLE MODES SETPOINT RANGE ACTION

1. AREA MONITORS

a. Spent Fuel Pool Area Monitor 1 Note 1 1.5 x 10-2 R/hr 10 101 R/hr 13

b. Containment High Range 2 1, 2, 3, & 4 Not Applicable 1 - 107 R/hr 18

2. PROCESS MONITORS

a. Containment Purge and Exhaust Isolation 1 Note 3 2 x background 10 - 106 cpm 16

b. Control Room Ventilation Intake Duct Monitors 2 Note 2 2 x background 10 - 106 cpm 17,20,21

c. Main Steam Line Radiation Monitors 1/Steam Line 1, 2, 3, & 4 Not Applicable 10 104 mR/hr 19 Note 1 - With fuel in the spent fuel pool or building.

Note 2 - MODES 1, 2, 3, 4, and during movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

Note 3 - Applicable during:

a. PURGE of the Containment Building or,

b. Containment Building continuous ventilation operations when moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies in the Containment Building.

ARKANSAS - UNIT 2 3/4 3-25 Amendment No. 63,130,145,206,231,255, 322

TABLE 3.3-6 (Continued)

TABLE NOTATION ACTION 13 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 16 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, complete the following:

a. If moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies within the Containment Building, secure the Containment Purge System or suspend the movement of recently irradiated fuel assemblies and movement of new fuel assemblies over recently irradiated fuel assemblies within the Containment Building.

b. If a Containment PURGE is in progress, secure the Containment Purge System.

c. If continuously ventilating the Containment Building, verify the associated SPING monitor operable or perform the applicable ACTION(s) of the Offsite Dose Calculation Manual; otherwise, secure the Containment Purge System.

ACTION 17 - In MODE 1, 2, 3, or 4, with no channels OPERABLE, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months initiate and maintain operation of the control room emergency ventilation system (CREVS) in the recirculation mode of operation or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

ACTION 18 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, (1) either restore the inoperable channel to OPERABLE status within 7 days or (2) prepare and submit a Special Report to the NRC within 30 days following the event, outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status. With both channels inoperable, initiate alternate methods of monitoring the containment radiation level within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in addition to the actions described above.

ACTION 19 - With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirements, initiate the preplanned alternate method of monitoring the appropriate parameter(s), within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and:

1) either restore the inoperable Channel(s) to OPERABLE status within 7 days of the event, or

2) prepare and submit a Special Report to the NRC within 14 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

ARKANSAS - UNIT 2 3/4 3-26 Amendment No. 63,130,145,206,231, 255,301, 322

TABLE 3.3-6 (Continued)

TABLE NOTATION ACTION 20 - In MODE 1, 2, 3, or 4 with the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, within 7 days restore the inoperable channel to OPERABLE status or initiate and maintain the CREVS in the recirculation mode of operation. Otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN in the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

ACTION 21 - During movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies with one or two channels inoperable, immediately place one OPERABLE CREVS train in the emergency recirculation mode or immediately suspend the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

ARKANSAS - UNIT 2 3/4 3-26a Amendment No. 301, 322

TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS MODES IN WHICH CHANNEL CHANNEL CHANNEL SURVEILLANCE INSTRUMENT CHECK CALIBRATION FUNCTIONAL TEST REQUIRED

1. AREA MONITORS

a. Spent Fuel Pool Area Monitor SFCP SFCP SFCP Note 1

b. Containment High Range SFCP SFCP Note 4 SFCP 1, 2, 3, & 4

2. PROCESS MONITORS

a. Containment Purge and In accordance with Note 2 Note 3 Note 3 Exhaust Isolation applicable Notes

b. Control Room Ventilation SFCP SFCP SFCP Note 6 Note 5 Intake Duct Monitors

c. Main Steam Line SFCP SFCP SFCP 1, 2, 3, & 4 Radiation Monitors Note 1 - With fuel in the spent fuel pool or building.

Note 2 - Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to initiating Containment PURGE operations and in accordance with the Surveillance Frequency Control Program during Containment PURGE or continuous ventilation operations.

Note 3 - Within 31 days prior to initiating Containment PURGE operations and in accordance with the Surveillance Frequency Control Program during Containment continuous ventilation operations when moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies in the Containment Building.

Note 4 - Acceptable criteria for calibration are provided in Table II.F.1-3 of NUREG-0737.

Note 5 - MODES 1, 2, 3, 4, and during movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

Note 6 - When the Control Room Ventilation Intake Duct Monitor is placed in an inoperable status solely for performance of this Surveillance, entry into associated ACTIONS may be delayed up to 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

ARKANSAS - UNIT 2 3/4 3-27 Amendment No. 63,130,145,206,231,255,315, 322 Next Page is 3/4 3-36

REACTOR COOLANT SYSTEM HOT STANDBY LIMITING CONDITION FOR OPERATION 3.4.1.2 a. The reactor coolant loops listed below shall be OPERABLE:

1. Reactor Coolant Loop (A) and at least one associated reactor coolant pump.

2. Reactor Coolant Loop (B) and at least one associated reactor coolant pump.

b. At least one of the above Reactor Coolant Loops shall be in operation.*

APPLICABILITY: MODE 3.

ACTION:

a. With less than the above required reactor coolant loops OPERABLE, restore the required loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With no reactor coolant loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1 and immediately initiate corrective action to return the required loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.2.1 At least the above required reactor coolant pumps, if not in operation, shall be determined to be OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.2.2 At least one cooling loop shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

All reactor coolant pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1, and (2) core outlet temperature is maintained at least 10 °F below saturation temperature.

ARKANSAS - UNIT 2 3/4 4-2 Amendment No. 24,29,315, 322

REACTOR COOLANT SYSTEM SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.1.3 a. At least two of the coolant loops listed below shall be OPERABLE:

1. Reactor Coolant Loop (A) and its associated steam generator and at least one associated reactor coolant pump.

2. Reactor Coolant Loop (B) and its associated steam generator and at least one associated reactor coolant pump.

3. Shutdown Cooling Loop (A) #.

4. Shutdown Cooling Loop (B) #.

b. At least one of the above coolant loops shall be in operation.*

APPLICABILITY: Modes 4 and 5.

ACTION:

a. With less than the above required coolant loops OPERABLE, immediately initiate corrective action to return the required coolant loops to OPERABLE status as soon as possible and initiate action to make at least one steam generator available for decay heat removal via natural circulation. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

b. With no coolant loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1 or LCO 3.1.1.2, as applicable, and immediately initiate corrective action to return the required coolant loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required shutdown cooling loop(s) shall be determined OPERABLE per the INSERVICE TESTING PROGRAM.

4.4.1.3.2 The required reactor coolant pump(s), if not in operation, shall be determined to be OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.3.3 The required steam generator(s) shall be determined OPERABLE by verifying the secondary side water level to be 23% indicated level in accordance with the Surveillance Frequency Control Program.

4.4.1.3.4 At least one coolant loop shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

All reactor coolant pumps and decay heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1 or LCO 3.1.1.2, as applicable, and (2) core outlet temperature is maintained at least 10 °F below saturation temperature.

The normal or emergency power source may be inoperable in Mode 5.

ARKANSAS - UNIT 2 3/4 4-2a Amendment No. 24,29,233,301,305, 315,322

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation and air conditioning systems shall be OPERABLE. (Note 1)

APPLICABILITY: MODES 1, 2, 3, 4, or during movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

ACTION:

MODES 1, 2, 3, and 4

a. With one control room emergency air conditioning system (CREACS) inoperable, restore the inoperable system to OPERABLE status within 30 days.

b. With one control room emergency ventilation system (CREVS) inoperable for reasons other than ACTION d, restore the inoperable system to OPERABLE status within 7 days.

c. With one CREVS inoperable for reasons other than ACTION d and one CREACS inoperable, restore the inoperable CREVS to OPERABLE status within 7 days and restore the inoperable CREACS to OPERABLE status within 30 days.

d. With one or more CREVS inoperable due to an inoperable CRE boundary:

1. Immediately initiate action to implement mitigating actions, and

2. Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

3. Restore the CRE boundary to OPERABLE status within 90 days

e. With two CREVS inoperable for reasons other than ACTION d (Note 2):

1. Immediately initiate action to implement mitigating actions, and

2. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify LCO 3.4.8, "Specific Activity," is met, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore at least one CREVS to OPERABLE status.

f. With two CREACS inoperable (Note 2), restore at least one CREACS to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

With ACTIONS a, b, c, d, e, and/or f not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

Note 1: The control room envelope (CRE) boundary may be open intermittently under administrative controls.

Note 2: ACTION e is not applicable if the second CREVS is intentionally made inoperable.

ACTION f is not applicable if the second CREACS is intentionally made inoperable.

ARKANSAS - UNIT 2 3/4 7-17 Amendment No. 206,219,255,288, 301,304,322

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION AND AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION During Movement of Irradiated Fuel Assemblies or Movement of New Fuel Assemblies over Irradiated Fuel Assemblies

g. With one CREACS inoperable, restore the inoperable system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation; otherwise, suspend all activities involving the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

h. With one CREVS inoperable, restore the inoperable system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode of operation; otherwise, suspend all activities involving the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

i. With one CREVS inoperable for reasons other than ACTION d and one CREACS inoperable:

1. restore the inoperable CREVS to OPERABLE status within 7 days or immediately place the CRE in the emergency recirc mode of operation, and

2. restore the inoperable CREACS to OPERABLE status within 30 days or immediately place the OPERABLE system in operation;

3. otherwise, suspend all activities involving the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

j. With both CREACS inoperable, immediately suspend all activities involving the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

k. With both CREVS inoperable or with one or more CREVS inoperable due to an inoperable CRE boundary, immediately suspend all activities involving the movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

ARKANSAS - UNIT 2 3/4 7-17a Amendment No. 206,219,255,281, 288,304, 322

ELECTRICAL POWER SYSTEMS SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and

b. One diesel generator with:

1. A day fuel tank containing a minimum volume of 300 gallons of fuel,

2. A fuel storage system, and

3. A fuel transfer pump.

APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend the movement of recently irradiated fuel assemblies, the movement of new fuel assemblies over recently irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

SURVEILLANCE REQUIREMENT 4.8.1.2 The above required A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for Requirement 4.8.1.1.2a.5.

ARKANSAS - UNIT 2 3/4 8-5 Amendment No. 149,255, 322

ELECTRICAL POWER SYSTEMS A.C. DISTRIBUTION - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, the following A.C. electrical busses shall be OPERABLE:

1 - 4160 volt Emergency Bus 1 - 480 volt Emergency Load Center Bus 4 - 480 volt Motor Control Center Busses 2 - 120 volt A.C. Vital Busses APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

With less than the above complement of A.C. busses OPERABLE, immediately suspend the movement of recently irradiated fuel assemblies, the movement of new fuel assemblies over recently irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

SURVEILLANCE REQUIREMENTS 4.8.2.2 The specified A.C. busses shall be determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power availability.

ARKANSAS - UNIT 2 3/4 8-7 Amendment No. 227,315,322

ELECTRICAL POWER SYSTEMS DC SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.4 As a minimum, the following DC electrical equipment and bus shall be energized and OPERABLE:

1 - 125-volt DC bus, and 1 - 125-volt battery bank and charger supplying the above DC bus.

APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

a. With the required battery charger inoperable:

i. Restore battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and ii. Verify battery float current 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With the requirements of ACTION a not met or with the above complement of DC equipment and bus otherwise inoperable, immediately suspend the movement of recently irradiated fuel assemblies, the movement of new fuel assemblies over recently irradiated fuel assemblies, and any operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

SURVEILLANCE REQUIREMENTS 4.8.2.4.1 The above required 125-volt D.C. bus shall be determined OPERABLE and energized in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power availability.

4.8.2.4.2 The above required 125-volt battery bank and charger shall be demonstrated OPERABLE per Surveillance Requirements 4.8.2.3.1, 4.8.2.3.2, and 4.8.2.3.3; however, while each of these Surveillance Requirements must be met, Surveillance Requirements 4.8.2.3.2 and 4.8.2.3.3 are not required to be performed.

ARKANSAS - UNIT 2 3/4 8-10 Amendment No. 94,227,297,315, 322

3/4.9 REFUELING OPERATIONS BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1 The boron concentration of the reactor coolant system and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of following reactivity conditions is met:

a. Either a Keff of 0.95 or less, which includes a 1% k/k conservative allowance for uncertainties, or

b. A boron concentration of 2500 ppm, which includes a 50 ppm conservative allowance for uncertainties.

APPLICABILITY: MODE 6*.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving positive reactivity changes and initiate and continue boration at 40 gpm of 2500 ppm boric acid solution until Keff is reduced to 0.95 or the boron concentration is restored to 2500 ppm, whichever is the more restrictive. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.1.1 The more restrictive of the above two reactivity conditions shall be determined prior to:

a. Removing or unbolting the reactor vessel head, and

b. Withdrawal of any CEA in excess of 3 feet from its fully inserted position within the reactor pressure vessel.

4.9.1.2 The boron concentration of the reactor coolant and the refueling canal shall be determined by chemical analysis in accordance with the Surveillance Frequency Control Program.

Only applicable to the refueling canal when connected to the RCS.

ARKANSAS - UNIT 2 3/4 9-1 Amendment No. 82,169,255,315, 322 Correction Letter dated 10/24/95,

REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2 As a minimum, two source range neutron flux monitors shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room.

APPLICABILITY: MODE 6.

ACTION:

a. With one or more of the above required monitors inoperable, immediately suspend positive reactivity additions.

AND Suspend movement of fuel, sources, and reactivity control components within the reactor vessel.1

b. With both of the above required monitors inoperable, determine the boron concentration of the reactor coolant system at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of:

a. A CHANNEL CHECK in accordance with the Surveillance Frequency Control Program,

b. A CHANNEL FUNCTIONAL TEST in accordance with the Surveillance Frequency Control Program, and

c. A CHANNEL FUNCTIONAL TEST within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to the initial start of the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies.

Note 1: Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition.

ARKANSAS - UNIT 2 3/4 9-2 Amendment No. 315, 322

REFUELING OPERATIONS CONTAINMENT BUILDING PENETRATIONS LIMITING CONDITION FOR OPERATION 3.9.4 The containment building penetrations shall be in the following status:

a. The equipment door is capable* of being closed,

b. A minimum of one door in each airlock is capable* of being closed, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. Closed* by a manual or automatic isolation valve, blind flange, or equivalent, or

2. Capable* of being closed by an OPERABLE containment purge and exhaust isolation system.

APPLICABILITY: During movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies within the Containment Building.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies in the Containment Building. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.4.1 Each of the above required containment penetrations shall be determined to be in its above required conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to the start of and in accordance with the Surveillance Frequency Control Program during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies in the Containment Building.

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls. Administrative controls shall ensure that appropriate personnel are aware that when containment penetrations, including both personnel airlock doors and/or the equipment door are open, a specific individual(s) is designated and available to close the penetration following a required evacuation of containment, and any obstruction(s) (e.g., cables and hoses) that could prevent closure of an airlock door and/or the equipment door be capable of being quickly removed.

ARKANSAS - UNIT 2 3/4 9-4 Amendment No. 166,203,230,315, Next page is 3/4 9-6 322

REFUELING OPERATIONS COMMUNICATIONS LIMITING CONDITION FOR OPERATION 3.9.5 Direct communications shall be maintained between the control room and personnel at the refueling station.

APPLICABILITY: During movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vessel.

ACTION:

When direct communications between the control room and personnel at the refueling station cannot be maintained, suspend movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.5 Direct communications between the control room and personnel at the refueling station shall be demonstrated within one hour prior to the start of and in accordance with the Surveillance Frequency Control Program during movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vessel.

ARKANSAS - UNIT 2 3/4 9-6 Amendment No. 315, 322

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION SHUTDOWN COOLING - ONE LOOP LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one shutdown cooling loop shall be in operation.

APPLICABILITY: MODE 6.

ACTION:

a. With less than one shutdown cooling loop in operation, except as provided in b.

below, suspend operations involving an increase in the reactor decay heat load or that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b. The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.8.1 A shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at a flow rate of 2000 gpm in accordance with the Surveillance Frequency Control Program.

ARKANSAS - UNIT 2 3/4 9-9 Amendment No. 25,104,315, 322

REFUELING OPERATIONS WATER LEVEL - REACTOR VESSEL LIMITING CONDITION FOR OPERATION 3.9.9 At least 23 feet of water shall be maintained over the elevation corresponding to the top of irradiated fuel assemblies seated within the reactor pressure vessel.

APPLICABILITY: During movement of fuel assemblies within the Containment Building.

ACTION:

With the requirements of the above specification not satisfied, suspend all operations involving movement of fuel assemblies within the Containment Building. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.9 The water level shall be determined to be at least its minimum required depth within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of and in accordance with the Surveillance Frequency Control Program thereafter during movement of fuel assemblies within the Containment Building.

ARKANSAS - UNIT 2 3/4 9-10 Amendment No. 167,315, 322

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 322 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-6 ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368

1.0 INTRODUCTION

By application dated August 29, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19241A264), Entergy Operations, Inc. (the licensee),

requested changes to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 2 (ANO-2).

The proposed license amendment would modify multiple TSs for ANO-2 to address non-conservative TS Applicability statements associated with the movement of fuel assemblies.

The licensee stated that these changes are necessary due to the previous adoption of the alternative source term (AST), which included an update to the ANO-2 fuel handling accident (FHA) analysis. This update created a new requirement to address the movement of new (unirradiated) fuel assemblies over irradiated fuel assemblies.

In addition to the above proposed changes, the licensee also proposed to modify the TSs affected by the updated FHA analysis to gain further consistency with NUREG-1432, Revision 4, Standard Technical Specifications Combustion Engineering Plants, Volume 1, Specifications (ADAMS Accession No. ML12102A165), improved standard technical specifications (STSs). These proposed changes are most closely associated with previous changes made to NUREG-1432, which incorporated the following Technical Specifications Task Force (TSTF) Travelers:

TSTF-51, Revision 2, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations, dated November 1, 1999 (ADAMS Accession No. ML993190284).

TSTF-272, Revision 1, Refueling Boron Concentration Clarification, dated December 21, 1999 (ADAMS Accession No. ML993630256).

TSTF-286, Revision 2, Operations Involving Positive Reactivity Additions, dated July 6, 2000 (ADAMS Accession No. ML003730788).

Enclosure 2

TSTF-471, Revision 1, Eliminate Use of Term Core Alterations in ACTIONS and Notes, dated December 7, 2006 (ADAMS Accession No. ML062860320).

TSTF-571-T, Revise Actions for Inoperable Source Range Neutron Flux Monitor, dated October 4, 2018 (ADAMS Accession No. ML17346A587).

2.0 REGULATORY EVALUATION

2.1 Background The U.S. Nuclear Regulatory Commission (NRC, the Commission) staff evaluated the licensees proposed changes to the ANO-2 TSs to address non-conservatisms that resulted from the licensees implementation of Amendment No. 293 to Renewed Facility Operating License No. NPF-6 for ANO-2 dated April 26, 2011 (ADAMS Accession No. ML110980197). ANO-2 Amendment No. 293 allowed the licensee to implement revised TSs based on the AST per Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67, Accident source term. As part of Amendment No. 293, the NRC staff evaluated the licensees updated FHA analysis and found it to be acceptable. The updated FHA analysis is provided in Attachment 3 to the application for Amendment No. 293 dated March 31, 2010 (ADAMS Accession No. ML100910241). The NRC staff also evaluated the licensees proposed changes to the ANO-2 TSs to implement several TSTFs affected by the updated FHA analysis to gain further consistency with NUREG-1432, Revision 4.

2.1.1 Updated FHA Analysis The NRC staffs evaluation of the updated FHA analysis is provided in Section 3.3.2 of the safety evaluation (SE) related to Amendment No. 293. Before the AST was implemented, the licensees FHA analysis indicated that only part of a single fuel assembly (i.e., 60 rods) that was dropped would be damaged. In order to address the most limiting case in the updated FHA analysis, as described in Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, dated July 2000 (ADAMS Accession No. ML003716792), the licensee assumed the amount of fuel damaged to be that which is contained in two irradiated fuel assemblesthe dropped assembly and the impacted assembly (i.e., a total of 472 rods). This change, more specifically the assumption that the impacted assembly could be damaged during an FHA as well as the dropped assembly, introduced a non-conservatism in the licensees TSs. To address this non-conservatism, TS statements that address the movement of fuel assemblies would now need to include the movements of all fuel (i.e., new fuel as well as irradiated fuel) over irradiated fuel assemblies.

To date, the licensee has been mitigating this non-conservatism using provisions in its refueling and operating procedures consistent with NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, dated December 29, 1998 (ADAMS Accession No. ML031110108). Changes proposed in this license amendment request (LAR) address this non-conservatism by revising TS statements to include the movement of new and irradiated fuel over irradiated fuel.

2.1.2 TSTF-51 and TSTF-471 TSTF-51 and TSTF-471 allow licensees to remove references to the term core alterations from their TSs. As described in TSTF-471, the term core alterations was determined to be unnecessarily restrictive and was approved for deletion from several TSs. By letter dated October 4, 2018, the NRC staff determined that licensees can submit LARs to adopt TSTF-51

and TSTF-471, provided that the LARs include information sufficient for the NRC staff to evaluate the submittal. Specifically, licensees were requested to provide information describing their evaluations of recently irradiated fuel, demonstrating that after sufficient radioactive decay has occurred (from the time of shutdown), the radiological doses resulting from an FHA remain below applicable limits and acceptance criteria. For ANO-2, the term recently, as applied to irradiated fuel assemblies, is defined in TS Bases Section 3/4 3.3.1, Radiation Monitoring Instrumentation, as fuel that has occupied part of a critical reactor core within the previous 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months . In its updated FHA analysis, the licensee assumed that spent fuel will have remained in the reactor core for at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months after shutdown before being handled.

Upon reviewing the updated FHA analysis, the NRC staff concluded that the exclusion area boundary, low population zone, and control room doses estimated by the licensee for the FHA meet the applicable accident dose criteria.

Additionally, in the letter dated October 4, 2018, licensees were requested to provide certain information to aid the NRC staff in reviewing LARs proposing the removal of the term core alterations from TSs. The licensee provided the following discussion in Section 3.0 of its LAR dated August 29, 2019:

NRC letter dated October 4, 2018. . ., required (in part) that licensees applying for adoption of TSTF-51 describe any limitations or controls that would prevent the movement of unirradiated fuel assemblies, sources, or reactivity control components capable of damaging a fuel assembly located within the core prior to the time period defined as recently. For ANO-2, consistent with the assumptions of the updated FHA analysis performed in support of the adoption of AST, recently is defined as less than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months post-shutdown. Following this 100-hour period, an FHA cannot result in the release of radioactivity from the site that would exceed 10 CFR 50.67 limits, assuming no containment. The 100-hour post-shutdown assumption is governed by ANO-2 TS 3.9.3.a, which requires the reactor to be subcritical for at least 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months prior to moving irradiated fuel within the reactor vessel. The updated FHA analysis, which assumes a fuel assembly drop including the weight of a control rod and the hoist grapple, bounds the drop of any other component which could be manipulated within the core. In addition, a review of the required refueling preparations following shutdown does not support a condition that would permit the manipulation of fuel, sources, or reactivity control components within the core in less than 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months (~4 days) post-shutdown. For example, the schedule for the fall 2018 ANO-2 refueling outage included nearly 6 full days of normal activities from reactor shutdown to a condition where the refueling canal was flooded and the upper guide structure removed, allowing access to the core internals.

Furthermore, the TSTF-51 Reviewers Note requests that licensees adopting the use of the term recently in TSs related to handling irradiated fuel adopt commitments that serve as guidelines in the assessment of systems removed from service during movement of irradiated fuel. In of the LAR, the licensee provided the following related Regulatory Commitments for continuing compliance, concurrent with the implementation of the amendment request:

During the movement of irradiated or recently irradiated fuel assemblies, availability of ventilation and radiation monitoring systems that aid in minimizing offsite dose consequences in the event of a fuel handling accident will be considered.

During the movement of irradiated or recently irradiated fuel assemblies, methods will be established that permit prompt closure of the containment building in the event of a fuel handling accident.

Based on the above discussion, the NRC staff concludes that the licensee has provided the information requested in the NRCs letter dated October 4, 2018, regarding the adoption of TSTF-51 and TSTF-471 and that the licensees commitments are consistent with the commitments proposed by the TSTF-51 Reviewers Note.

2.1.3 TSTF-286 The proposed changes would adopt NRC-approved generic changes in TSTF-286, Revision 2, which were approved for incorporation into the STSs by the NRC staff in a letter dated July 6, 2000, as modified by the NRC. TSTF-286, Revision 2, revises required actions to suspend operations involving positive reactivity additions and limiting conditions for operation (LCOs) notes to prevent operations involving a reduction in reactor coolant system (RCS) boron concentration. The proposed changes would limit the introduction into the RCS of reactivity more positive than that required to meet the required shutdown margin (SDM) or refueling boron concentration, as applicable. TSTF-286 provides a model for licensees seeking to revise their plant TSs and clarify limits on the introduction of reactivity such that the required SDM or refueling boron concentration will be satisfied.

The ANO-2 SDM provides enough subcritical reactivity margin to ensure that (1) the reactor can be made subcritical from all operating conditions, (2) the reactivity transients associated with postulated accident conditions are controllable within acceptable limits, and (3) the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition.

The SDM definition assumes that all control element assemblies (CEAs) are fully inserted into the reactor core except for the single assembly of the highest reactivity worth, which is assumed to be fully withdrawn. In Modes 1, 2, 3, and 4, ANO-2 TS 3.1.1.1, Shutdown Margin - Tavg

[average coolant temperature] > [greater than] 200 °F [degrees Fahrenheit], specifies that the required SDM be greater than or equal to () that specified in the core operating limits report (COLR). In Modes 1 and 2, ANO-2 TS 3.1.3, Control Element Assemblies, ensures that the minimum SDM is maintained by limiting the insertion of the CEAs. Small reactivity changes due to RCS coolant inventory management and temperature control are also considered in specifying SDM, including moderator temperature coefficient effects as allowed by ANO-2 TS 3.1.1.4, Moderator Temperature Coefficient. In Mode 5, the ANO-2 TS 3.1.1.2, Shutdown Margin - Tavg [less than or equal to] 200 °F, specifies that the required SDM be greater than or equal to that specified in the COLR. In Mode 6, the reactor subcriticality margin is ensured by the limit on the boron concentration of all filled portions of the RCS and the refueling canal that have direct access to the reactor vessel.

The LAR would modify the ANO-2 TSs to permit the addition of positive reactivity and changes to the RCS boron concentration as long as the change preserves the margin to core criticality as defined by the SDM and refueling boron concentration limit specifications. The limit specifications for the SDM and refueling boron concentration are given in ANO-2 TSs 3.1.1.1, 3.1.1.2, and 3.9.1, Boron Concentration, respectively, with the SDM limit values specified in the COLR.

2.1.4 TSTF-272 TSTF-272 clarified STS 3.9.1 and the TS Bases to state that boron concentration limits do not apply to the refueling canal and refueling cavity when these areas are not connected to the RCS. STS 3.9.1 limits the boron concentrations of the RCS, the refueling canal, and the refueling cavity during refueling to ensure that the reactor remains subcritical during MODE 6.

When the refueling canal and refueling cavity are isolated from the RCS, no potential for dilution exists. Therefore, in this condition, it is not necessary to place a limit on the boron concentration in the refueling canal and the refueling cavity. The STS Applicability is revised with a Note stating that the limits only apply to the refueling canal and refueling cavity when connected to the RCS.

2.1.5 TSTF-571-T TSTF-571-T revises the required actions for an inoperable source range neutron flux monitor (SRM) to prohibit the movement of fuel assemblies, sources, and reactivity control components when an SRM is inoperable. A provision was included to allow such movement if it is needed to repair the SRM. The proposed changes ensure that no actions are taken that could alter the core reactivity when an SRM is inoperable. By letter dated October 4, 2018, the NRC staff concluded that the adoption of TSTF-571-T would resolve the concern discussed above.

2.2 Proposed Technical Specifications Changes The proposed TS changes evaluated in this SE are in the following ANO-2 TS sections:

TS 1.12, Core Alteration TS 3.1.1.3, Boron Dilution TS 3.3.3.1, Radiation Monitoring Instrumentation TS 3.4.1.2, [RCS] Hot Standby TS 3.4.1.3, [RCS] Shutdown TS 3.7.6.1, Control Room Emergency Ventilation and Air Conditioning System TS 3.8.1.2, [Electrical Power Systems] Shutdown TS 3.8.2.2, A.C. Distribution - Shutdown TS 3.8.2.4, DC Sources - Shutdown TS 3.9.1, [Refueling Operations] Boron Concentration TS 3.9.2, [Refueling Operations] Instrumentation TS 3.9.4, [Refueling Operations] Containment Building Penetrations TS 3.9.5, [Refueling Operations] Communications TS 3.9.8.1, [Refueling Operations] [Shutdown Cooling and Coolant Circulation]

Shutdown Cooling - One Loop TS 3.9.9, [Refueling Operations] Water Level - Reactor Vessel In Section 2.4, Description of the Proposed Change, of the enclosure to its application dated August 29, 2020, the licensee provided generic examples of the nature of the proposed changes (e.g., based on the updated FHA analysis, incorporation of related TSTFs, consistency with STSs, editorial change, etc.). On page 7 of 37 of the enclosure to the application, the licensee provided a tabulation of each TS affected by this LAR, with a cross-reference to the types of changes affecting each TS. In addition, in Attachment 1 to the enclosure, the licensee provided a markup of each proposed TS page, identifying the proposed change and the basis for the change.

The licensee proposed the following specific changes to the ANO-2 TSs. Proposed TS additions are shown in bold and italicized font. Proposed TS deletions are shown in strikeout.

2.2.1 Proposed Revision to ANO-2 TS 1.12 The term CORE ALTERATION and its associated definition would be deleted, as shown below:

CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATION shall not preclude completion of movement of a component to a safe conservative position.

2.2.2 Proposed Revision to ANO-2 TS 3.1.1.3 and SR 4.1.1.3 The licensee proposed the following changes to ANO-2 TS 3.1.1.3 and Surveillance Requirement (SR) 4.1.1.3:

LIMITING CONDITION FOR OPERATION 3.1.1.3 The flow rate of reactor coolant through the Rreactor Ccoolant Ssystem (RCS) shall be 2000 gpm [gallons per minute] whenever a reduction in Reactor Coolant System boron concentration is being made.

ACTION:

With the flow rate of reactor coolant through the RCSreactor coolant system

< 2000 gpm, immediately suspend all operations that would cause introduction of coolant into the RCS withinvolving a reduction in boron concentration less than required to meet the SDM or boron concentration of LCO 3.1.1.1, LCO 3.1.1.2, or LCO 3.9.1, as applicableof the Reactor Coolant System.

SURVEILLANCE REQUIREMENTS 4.1.1.3 The flow rate of reactor coolant through the RCSreactor coolant system shall be determined to be 2000 gpm within one hour prior to the start of and in accordance with the Surveillance Frequency Control Program [SFCP] during a reduction in the Reactor Coolant System boron concentration by either:

a. Verifying at least one reactor coolant pump is in operation, or

b. Verifying that at least one low pressure safety injection pump or containment spray pump is in operation as a shutdown cooling pump and supplying 2000 gpm through the RCSreactor coolant system.

2.2.3 Proposed Revision to ANO-2 TS 3.3.3.1 The licensee proposed the following changes to ANO-2 TS 3.3.3.1:

In ANO-2 TS Table 3.3-6, Radiation Monitoring Instrumentation, for Instrument 2.a, Containment Purge and Exhaust Isolation, the APPLICABLE MODES column would be revised as: 5 & 6Note 3.

Note 2 in TS Table 3.3-6 would be revised as shown below and new Note 3 would be added:

Note 2 - MODES 1, 2, 3, 4, and during movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

Note 3 - Applicable during:

a. PURGE of the Containment Building or,

b. Containment Building continuous ventilation operations when moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies in the Containment Building.

The Table Notation for Action 16 in ANO-2 TS Table 3.3-6 would be revised as follows:

ACTION 16 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, complete the following:

a. If performing CORE ALTERATIONS or moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies within the Containmentreactor Bbuilding, secure the Ccontainment Ppurge Ssystem or suspend CORE ALTERATIONS and the movement of recently irradiated fuel assemblies and movement of new fuel assemblies over recently irradiated fuel assemblies within the Containmentreactor Bbuilding.

b. If a Ccontainment PURGE is in progress, secure the Ccontainment Ppurge Ssystem.

c. If continuously ventilating the Containment Building, verify the associated SPING monitor operable or perform the applicable ACTION(s)S of the Offsite Dose Calculation Manual, Appendix 2, Table 2.2-1;, otherwiser, secure the Ccontainment Ppurge Ssystem.

The Table Notation for Action 21 in ANO-2 TS Table 3.3-6 would be revised as follows:

ACTION 21 - During movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies with one or two channels inoperable, immediately

place one OPERABLE CREVS [control room emergency ventilation system] train in the emergency recirculation mode or immediately suspend the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

In ANO-2 TS Table 4.3-3, Radiation Monitoring Instrumentation Surveillance Requirements, for Instrument 2.a, Containment Purge and Exhaust Isolation, the CHANNEL CALIBRATION column entry would be revised as: SFCPNote 3 and the MODES IN WHICH SURVEILLANCE REQUIRED column entry would be revised as: In accordance with applicable Notes 5 & 6 In ANO-2 TS Table 4.3-3, Notes 2, 3, and 5 would be revised as follows:

Note 2 - Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to initiating Ccontainment PURGEpurge operations and in accordance with the Surveillance Frequency Control Program during Ccontainment PURGEpurge or continuous ventilation operations.

Note 3 - Within 31 days prior to initiating Ccontainment PURGEpurge operations and in accordance with the Surveillance Frequency Control Program during Ccontainment continuous ventilationpurge operations when moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assemblies in the Containment Building.

Note 5 - MODES 1, 2, 3, 4, and during movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

2.2.4 Proposed Revision to ANO-2 TS 3.4.1.2 The licensee proposed the following changes to ANO-2 TS 3.4.1.2:

LIMITING CONDITION FOR OPERATION 3.4.1.2 a. The reactor coolant pumps listed below shall be in OPERABLEoperable:

ACTION:

a. With less than the above required reactor coolant loops OPERABLEoperable, restore the required loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With no reactor coolant loop in operation, suspend all operations that would causeinvolving introduction of coolant into the RCS with a reduction in boron concentration less than required to meet SDM of LCO 3.1.1.1of the Reactor Coolant System and immediately initiate corrective action to return the required loop to operation.

TS 3.4.1.2.b Footnote*

All reactor coolant pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction of coolant into the RCSdilution of the reactor coolant withsystem boron concentration less than required to meet SDM of LCO 3.1.1.1, and (2) core outlet temperature is maintained at least 10 °F below saturation temperature.

2.2.5 Proposed Revision to ANO-2 TS 3.4.1.3 The licensee proposed the following changes to ANO-2 TS 3.4.1.3:

ACTION:

b. With no coolant loop in operation, suspend all operations that would cause involving a reduction introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1 or LCO 3.1.1.2, as applicable, of the Reactor Coolant System and immediately initiate corrective action to return the required coolant loop to operation.

TS 3.4.1.3.b Footnote*

All reactor coolant pumps and decay heat removal pumps may be de-energized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided (1) no operations are permitted that would cause introduction of coolant intodilution of the RCS-reactor coolant system with boron concentration less than required to meet SDM of LCO 3.1.1.1 or LCO 3.1.1.2, as applicable, and (2) core outlet temperature is maintained at least 10°F below saturation temperature.

2.2.6 Proposed Revision to ANO-2 TS 3.7.6.1 The licensee proposed the following changes to ANO-2 TS 3.7.6.1:

APPLICABILITY: MODES 1,2,3,4, or during movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

ACTION:

During MovementHandling of Irradiated Fuel Assemblies or Movement of New Fuel Assemblies over Irradiated Fuel Assemblies

g. With one CREACS [control room emergency air conditioning system]

inoperable, restore the inoperable system to OPERABLE status within 30 days or immediately place the OPERABLE system in operation; otherwise, suspend all activities involving the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

h. With one CREVS inoperable, restore the inoperable system to OPERABLE status within 7 days or immediately place the control room in the emergency recirc mode of operation; otherwise, suspend all activities involving the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

i. With one CREVS inoperable for reasons other than ACTION d and one CREACS inoperable:

3. otherwise, suspend all activities involving the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

j. With both CREACS inoperable, immediately suspend all activities involving the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

k. With both CREVS inoperable or with one or more CREVS inoperable due to an inoperable CRE boundary, immediately suspend all activities involving the movementhandling of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies.

2.2.7 Proposed Revision to ANO-2 TS 3.8.1.2 The licensee proposed the following changes to ANO-2 TS 3.8.1.2:

APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

With less than the above minimum required A.C. [alternating current] electrical power sources OPERABLE, immediately suspend all operations involving the movement of recently irradiated fuel assembliesCORE ALTERATIONS, the movement of new fuel assemblies over recently irradiated fuel assemblies, orand operations involving positive reactivity additions that could result in loss of required SDM or boron concentrationchanges.

2.2.8 Proposed Revision to ANO-2 TS 3.8.2.2 The licensee proposed the following changes to ANO-2 TS 3.8.2.2:

APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

With less than the above complement of A.C. busses OPERABLEand energized, immediately suspend core alterations, the movement of recently irradiated fuel assemblies, the movement of new fuel assemblies over recently irradiated fuel assemblies, and any operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

2.2.9 Proposed Revision to ANO-2 TS 3.8.2.4 The licensee proposed the following changes to ANO-2 TS 3.8.2.4:

APPLICABILITY: MODES 5 and 6, or during movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies.

ACTION:

b. With the requirements of ACTION a not met or with the above complement of DC equipment and bus otherwise inoperable, immediately suspend core alterations, the movement of recently irradiated fuel assemblies, the movement of new fuel assemblies over recently irradiated fuel assemblies, and any operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

2.2.10 Proposed Revision to ANO-2 TS 3.9.1 The licensee proposed the following changes to ANO-2 TS 3.9.1:

LIMITING CONDITION FOR OPERATION 3.9.1 With the reactor vessel head unbolted or removed, Tthe boron concentration of the reactor coolant system and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of following reactivity conditions is met:

APPLICABILITY: MODE 6*.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at 40 gpm of 2500 ppm [parts per million] boric acid solution until Keff is reduced to 0.95 or the boron concentration is restored to 2500 ppm, whichever is the more restrictive. The provisions of Specification 3.0.3 are not applicable.

Applicability Footnote*

The reactor shall be maintained in MODE 6 when the reactor vessel head is unbolted or removedOnly applicable to the refueling canal when connected to the RCS.

2.2.11 Proposed Revision to ANO-2 TS 3.9.2 and SR 4.9.2 The licensee proposed the following changes to ANO-2 TS 3.9.2:

ACTION:

a. With one or more of the above required monitors inoperable, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity additions changes.

AND Suspend movement of fuel, sources, and reactivity control components within the reactor vessel.1 SURVEILLANCE REQUIREMENTS 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of:

c. A CHANNEL FUNCTIONAL TEST within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to the initial start of the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies CORE ALTERATIONS.

Note 1: Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition.

2.2.12 Proposed Revision to ANO-2 TS 3.9.4 and SR 4.9.4.1 The licensee proposed the following changes to ANO-2 TS 3.9.4 and SR 4.9.4.1:

APPLICABILITY: During CORE ALTERATIONS or movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies within the Ccontainment Building.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies in the Ccontainment Building. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.4.1 Each of the above required containment penetrations shall be determined to be in its above required conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to the start of and in accordance with the Surveillance Frequency Control Program during CORE ALTERATIONS or movement of recently irradiated fuel assemblies or movement of new fuel assemblies over recently irradiated fuel assemblies in the Ccontainment Building.

2.2.13 Proposed Revision to ANO-2 TS 3.9.5 and SR 4.9.5 The licensee proposed the following changes to ANO-2 TS 3.9.5 and SR 4.9.5:

APPLICABILITY: During CORE ALTERATIONS movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vessel.

ACTION:

When direct communications between the control room and personnel at the refueling station cannot be maintained, suspend movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vessel all CORE ALTERATIONS. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.5 Direct communications between the control room and personnel at the refueling station shall be demonstrated within one hour prior to the start of and in accordance with the Surveillance Frequency Control Program during movement of irradiated fuel assemblies or movement of new fuel assemblies over irradiated fuel assemblies in the reactor pressure vesselCORE ALTERATIONS.

2.2.14 Proposed Revision to ANO-2 TS 3.9.8.1 The licensee proposed the following changes to ANO-2 TS 3.9.8.1:

ACTION:

a. With less than one shutdown cooling loop in operation, except as provided in b. below, suspend all operations involving an increase in the reactor decay heat load or that would cause introduction of coolant into the RCS with a reduction in boron concentration less

than required to meet the boron concentration of LCO 3.9.1 of the Reactor Coolant System. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b. The shutdown cooling loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1 during the performance of CORE ALTERATIONS.

2.2.15 Proposed Revision to ANO-2 TS 3.9.9 and SR 4.9.9 The licensee proposed the following changes to ANO-2 TS 3.9.9 and SR 4.9.9:

LIMITING CONDITION FOR OPERATION 3.9.9 At least 23 feet of water shall be maintained over the elevation corresponding to the top of irradiated fuel assemblies seated within the reactor pressure vessel.

APPLICABILITY: During movement of fuel assemblies or CEAs within the Containment Building the reactor pressure vessel while in MODE 6, except during latching and unlatching of CEAs.

ACTION:

With the requirements of the above specification not satisfied, suspend all operations involving movement of fuel assemblies or CEAs within the Containment Buildingthe pressure vessel. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.9 The water level shall be determined to be at least its minimum required depth within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of and in accordance with the Surveillance Frequency Control Program thereafter during movement of fuel assemblies within the Containment Buildingor CEAs.

2.2.16 Proposed Deletion of ANO-2 TS Page 3/4 3-28 Page 3/4 3-28 would be deleted and removed from the ANO-2 TSs.

2.3 Regulatory Requirements and Guidance Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect

the health and safety of the public. The NRCs regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, Technical specifications.

The regulation in 10 CFR 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must include in the application a summary statement of the bases or reasons for such specifications, other than those covering administrative controls. However, per 10 CFR 50.36(a)(1), these TS bases shall not become part of the technical specifications.

The regulation in 10 CFR 50.36(b) states, in part:

Each license authorizing operation of a . . . utilization facility . . . will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation in 10 CFR 50.36(c)(2)(i) states, in part, that, When [an LCO] of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action [also known as Required Actions or Actions] permitted by the [TSs] until the condition can be met.

The regulation in 10 CFR 50.36(c)(3), Surveillance requirements, requires TSs to include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The NRC staffs guidance for review of TSs is contained in Section 16, Revision 3, Technical Specifications, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, dated March 2010 (ADAMS Accession No. ML100351425).

NUREG-1432 contains a template (i.e., STSs) for Combustion Engineering plants that the NRC staff has found to include the necessary information for compliance with 10 CFR 50.36. The STSs are revised through approval of various TSTF travelers, which licensees may adopt by demonstrating that they meet the technical basis described in the model SEs corresponding to each traveler. In the LAR, the licensee proposed to adopt the following TSTF travelers:

TSTF-51-A, Revision 2, which relates to the revised containment requirements during handling irradiated fuel and core alterations, dated July 31, 2003 (ADAMS Accession No. ML040400343). The NRC staff approved TSTF-51 in a letter dated November 1, 1999. TSTF-51 removed the defined term core alterations from the STSs. TSTF-51 provides an acceptable method for changing the TSs to remove references to the term core alterations. This change facilitates refueling operations without impacting the initial conditions or mitigation of any design accident or transient.

TSTF-272, Revision 1, which relates to the refueling boron concentration clarification, dated November 30, 1999 (ADAMS Accession No. ML993540010). The NRC staff

approved TSTF-272 in a letter dated December 21, 1999. TSTF-272 revised STS 3.9.1 to clarify that boron concentration limits do not apply to the refueling canal and refueling cavity when these areas are not connected to the RCS.

TSTF-286-A, Revision 2, which relates to the operation involving positive reactivity additions, dated July 31, 2003 (ADAMS Accession No. ML20106F133). The NRC staff approved TSTF-286 in a letter dated July 6, 2000. TSTF-286 revised the LCO Actions and Notes that require suspension of operations involving positive reactivity additions or preclude reduction in boron concentration by placing a limit on positive reactivity addition to within the TS-required shutdown limit. The LAR would adopt NRC-approved generic changes in TSTF-286, Revision 2, that were approved for incorporation into the STSs by the NRC staff in a letter dated July 6, 2000, as modified by the NRC. This TSTF revises required actions to suspend operations involving positive reactivity additions and LCO notes to prevent operations involving a reduction in RCS boron concentration. The proposed changes limit the introduction into the RCS of reactivity more positive than that required to meet the required SDM or refueling boron concentration, as applicable.

TSTF-286 provides a model for licensees seeking to revise their plant TSs and clarify limits on the introduction of reactivity such that the required SDM or refueling boron concentration will be satisfied.

TSTF-471-A, which relates to the elimination of the use of the term core alterations in Actions and Notes, dated December 18, 2006 (ADAMS Accession No. ML19101A215).

The NRC staff approved TSTF-471 in a letter dated December 7, 2006. TSTF-471 corrected an oversight related to the implementation of TSTF-51. TSTF-51 was intended to delete any reference to the term core alterations in the TSs. Following TSTF-51 implementation, other places in the TSs were noted where the term continued to exist. TSTF-471 (1) eliminated the term core alteration from these remaining references and (2) removed the requirement to Suspend Core Alterations from several specific STS sections on electrical and refueling operations related to the plant Refueling mode of operations. TSTF-471 provides an acceptable method for changing the TSs to remove reference to the phrase Core Alterations. This change facilitates refueling operations without impacting the initial conditions or mitigation of any design accident or transient.

TSTF-571-T, which relates to the revised actions for an inoperable SRM (see pages 6 to 30 of the letter dated August 9, 2018 (ADAMS Accession No. ML18221A561).

TSTF-571-T revises the Required Actions for an inoperable SRM to prohibit the movement of fuel assemblies, sources, and reactivity control components when an SRM is inoperable. A provision is included to allow such movement if it is needed to repair the SRM.

3.0 TECHNICAL EVALUATION

3.1 NRC Staff Evaluation of Changes 3.1.1 Revision to ANO-2 TS 1.12 The term CORE ALTERATION and its associated definition would be deleted. The NRC staff finds the change acceptable because the term will no longer be used in the ANO-2 TSs upon NRC staff approval of this LAR.

3.1.2 Revision to ANO-2 TS 3.1.1.3 Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the licensees proposed changes to this TS, including the proposed adoption of TSTF-286, Revision 2.

3.1.3 Revision to ANO-2 TS 3.3.3.1 ANO-2 TS 3.3.3.1 controls radiation monitoring instrumentation. The Applicability and Actions in ANO-2 TS 3.3.3.1 are reflected in ANO-2 TS Table 3.3-6. The APPLICABLE MODES column is revised to add Note 3, which describes two options for applicability of containment purge and exhaust isolation radiation monitoring instrumentation:

a. PURGE of the Containment Building, or

b. Containment Building continuous ventilation operations when moving recently irradiated fuel assemblies or moving new fuel assemblies over recently irradiated fuel assembles in the Containment Building.

The Table Notation for Action 16 of ANO-2 TS Table 3.3-6 would be revised to delete core alterations and to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. Additionally, editorial changes would be made to Action 16 as described in Item 10 in the discussion of differences (DOD) section of the LAR.

The NRC staff finds these changes acceptable because they are consistent with TSTF-51 and supported by the licensees updated FHA analysis.

Note 2 of ANO-2 TS Table 3.3-6, which describes the Applicability of the control room ventilation intake duct monitors, would be revised to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. The Table Notation for Action 21 of ANO-2 TS Table 3.3-6 would be revised to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. In the DOD section of the LAR, the licensee explains that the term recently, as it relates to fuel movement, should not be applied to items involving the CREVS because during its FHA analysis, the licensee determined that the dose to control room personnel is not acceptable without crediting the filtration capability of the CREVS. Therefore, the control room ventilation intake duct monitors are required to be operable during all fuel movement, regardless of time after shutdown. The NRC staff finds this change acceptable because it is more restrictive than TSTF-51 and supported by the licensees updated FHA analysis.

The SRs in ANO-2 TS 3.3.3.1 are reflected in TS Table 4.3-3. The channel calibration surveillance for the containment purge and exhaust isolation would be revised to add Note 3, which includes the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. Additionally, existing Note 5 would be revised to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated assemblies, as discussed above for Note 2 of TS Table 3.3-6. The NRC staff finds these changes acceptable because they are consistent with, or more restrictive than, TSTF-51; they are supported by the licensees updated FHA analysis; or they are otherwise editorial in nature.

3.1.4 Revision to ANO-2 TS 3.4.1.2 Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the licensees proposed changes to this TS, including the proposed adoption of TSTF-286, Revision 2.

3.1.5 Revision to ANO-2 TS 3.4.1.3 Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the licensees proposed changes to this TS, including the proposed adoption of TSTF-286, Revision 2.

3.1.6 Revision to ANO-2 TS 3.7.6.1 The Applicability statement in ANO-2 TS 3.7.6.1 would be revised to include the movement of irradiated fuel assemblies and the movement of new fuel assemblies over irradiated fuel assemblies. ANO-2 TS 3.7.6.1 Action subheading would be revised to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. ANO-2 TS 3.7.6.1 Actions g, h, i, j, and k would be revised to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. The NRC staff finds that these changes are acceptable because they address the non-conservatism introduced with the licensees updated FHA analysis.

3.1.7 Revision to ANO-2 TS 3.8.1.2 The Applicability statement for TS 3.8.1.2 would be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The Action statement for TS 3.8.1.2 would be revised to delete the term core alterations. The Action statement would also be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The term immediately would be added and the phrase all operations would be deleted for consistency with the STS. The NRC staff finds these changes acceptable because they are consistent with TSTF-51 and TSTF-471 and are supported by the licensees updated FHA analysis.

Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the additional changes proposed to this TS associated with the proposed adoption of TSTF-286, Revision 2.

3.1.8 Revision to ANO-2 TS 3.8.2.2 The Applicability statement for TS 3.8.2.2 would be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The Action statement for TS 3.8.2.2 would be revised to delete the term core alterations. The Action statement would also be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The NRC staff finds these changes acceptable because they are consistent with TSTF-51 and TSTF-471 and are supported by the licensees updated FHA analysis.

Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the additional changes proposed to this TS associated with the proposed adoption of TSTF-286, Revision 2.

3.1.9 Revision to ANO-2 TS 3.8.2.4 The Applicability statement in TS 3.8.2.4 would be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The Action statement for TS 3.8.2.4 Action b. would be revised to delete core alterations. The Action statement for TS 3.8.2.4 Action b. would also be revised to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. The NRC staff finds these changes acceptable because they are consistent with TSTF-51 and TSTF-471 and are supported by the licensees updated FHA analysis.

Refer to Section 3.1.17 of this SE for the NRC staffs evaluation of the additional changes proposed to this TS associated with the proposed adoption of TSTF-286, Revision 2.

3.1.10 Revision to ANO-2 TS 3.9.1 3.1.10.1 Changes to ANO-2 TS LCO 3.9.1 and Applicability Footnote The following changes were proposed to ANO-2 TS LCO 3.9.1 and the Applicability Footnote *:

Change 1: Deletion of the phrase, With the reactor vessel head unbolted or removed, from LCO 3.9.1, and deletion of Applicability Footnote *, which specifies that The reactor shall be maintained in MODE 6 when the reactor vessel head is unbolted or removed.

The licensee indicated that the Applicability Footnote

of LCO 3.9.1 is a repeat of the TS definition of Mode 6, which states in ANO-2 TS Table 1.1, Operational Modes, of Section 1.0, Definitions, the following:

6. REFUELING** < 0.95 ... < 140 0F

- Reactor vessel head unbolted or removed and fuel in the vessel.

Since no other Mode 6-related ANO-2 TSs or the STS in NUREG-1432, Revision 4, include this redundant information, the licensee proposed to remove the Footnote

from the TS 3.9.1 Applicability. In addition, the similar phrase, With the reactor vessel head unbolted or removed, in LCO 3.9.1 is also proposed to be deleted. The NRC staff finds that the deletion of this redundant information is an administrative change that does not change the current TS requirements and, therefore, concludes that the proposed removal of the Footnote

from the Applicability and the deletion of the phrase from TS LCO 3.9.1 are acceptable.

Change 2: Change of the phrase reactor coolant in LCO 3.9.1 to reactor coolant system.

The proposed change in LCO 3.9.1 from reactor coolant to reactor coolant system is proposed to maintain consistency with other ANO-2 TSs and the STS. The NRC staff finds that the change is an administrative change that does not change the TS requirements and, therefore, is acceptable.

Change 3: A new Footnote

to the Applicability for TS 3.9.1 which states that Only applicable to the refueling canal when connected to the RCS, is proposed.

The NRC staff determined that the proposed addition of the Footnote

is consistent with Insert 1 in the Applicability of equivalent TS 3.9.1 in TSTF-272, Revision 1, dated November 30, 1999, with a minor difference (i.e., without adoption of the phrase, reactor cavity). The licensee clarified this on page 17 of the enclosure to the LAR stating that the ANO-2 TSs and procedures, with respect to RCS and boron concentrations, refer only to the refueling channel, and the reactor cavity is assumed to be enveloped within the meaning of refueling canal. At ANO-2 there is no separation between the refueling canal and the reactor cavity. In addition, the equivalent STS LCO 3.9.1 contains these terms (the refueling canal and the reactor cavity) in brackets, as the TS language would be site-specific. Based on the above discussion, the reactor cavity phrase is omitted from the proposed adoption of the STS and the TSTF-272 equivalent TS 3.9.1. The NRC staff finds that this difference (the omission of reactor cavity in the added Applicability Footnote *) is editorial and that the added Footnote

continues to meet the intent of TSTF-272. Therefore, the addition of the new Footnote

to LCO 3.9.1 is acceptable.

3.1.10.2 Changes to ANO-2 TS 3.9.1 Action The following change was proposed to ANO-2 TS 3.9.1 Action:

The phrase, CORE ALTERATIONS, would be deleted from the Action of LCO 3.9.1.

Core alterations involve the movement or manipulation of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel.

Core alterations could involve the addition of fuel assemblies to the reactor and the withdrawal of control rods, resulting in positive reactivity additions. With the proposed deletion of immediately suspending core alterations, the current Action of TS 3.9.1 still requires the immediate suspension of positive reactivity changes and to initiate action to restore boron concentration to within the limits in LCO 3.9.1. Suspension of positive reactivity changes would prohibit addition of non-borated water or fuel assemblies to the reactor and the withdrawal of control rods, which could reduce the SDM. Therefore, the current Action with the proposed deletion of the phrase, core alterations, would continue to ensure that the requirements of boron concentration limits are met to avoid criticality. The NRC staff also determined that the proposed deletion is consistent with the Action of equivalent TS 3.9.1 in TSTF-471, Revision 1, which deleted original Required Action A.1 that requires the operator to immediately suspend core alterations when the boron concentration is not within the limits in LCO 3.9.1. Finally, the changes are consistent with STS 3.9.1 in NUREG-1432, Revision 4. Therefore, the NRC staff finds that the proposed changes are acceptable.

3.1.11 Revision to ANO-2 TS 3.9.2 3.1.11.1 Changes to ANO-2 TS 3.9.2 Action a.

The following changes were proposed to TS 3.9.2 Action a.:

Change 1: The phrase one or more would replace the word one in the phrase one of the above required monitors inoperable.

The corresponding Condition of Required Action A of STS 3.9.2 in TSTF-471 refers to only one monitor being inoperable when applying these required actions. On page 18 of the enclosure to the LAR, the licensee clarified that the STS usage rules require entry into all Conditions, which may apply at a given time, while the ANO-2 STS usage rules require entry into those actions that specifically meet the described plant condition. Therefore, if both ANO-2 monitors were operable, Action a. may not necessarily be entered, as it currently addresses a single monitor being inoperable. However, the intent of the STS is that the required actions such as suspension of positive reactivity additions should be performed when one or both monitors are inoperable. To ensure the intent of TSTF-472 and that the STS is appropriately adopted, the licensee proposed to add the phase or more. The revised ANO-2 TS 3.9.2 Action a. would state, in part, With one or more of the above required monitors inoperable. . . . The NRC staff finds that the change meets the intent of the corresponding STS 3.9.2 in TSTF-472 and, therefore, concludes that the change is acceptable.

Change 2: The phrase all operations involving CORE ALTERATIONS or would be deleted and the phrase positive reactivity changes would be changed to positive reactivity additions.

The NRC staff determined that the proposed deletion of the phrase all operations involving CORE ALTERATIONS or is consistent with STS 3.9.2 in TSTF-471, which removed the phrase CORE ALTERATIONS from Required Action A.1 and revised the phase to positive reactivity additions. Since Required Action A.1 of STS 3.9.2 in TSTF-471 would prohibit positive reactivity additions in the core, including suspension of operations that would cause dilution of the boron concentration of the coolant in the RCS, Required Action A.2 of STS 3.9.2 that requires suspension of the boron dilution operation is included in Required Action A.1 and is not adopted in ANO-2 TS 3.9.2. The NRC staff finds that the licensees approach of only adopting the bounding Required Action A.1 meets the intent of TSTF-471 and, therefore, is acceptable.

Change 3: The phrase AND Suspend movement of fuel, sources, and reactivity control components within the reactor vessel1 would be added as the second action of Action a.

Following incorporation of TSTF-286 and TSTF-471 into LCO 3.9.2, the NRC staff raised a concern with the Required Actions in the nuclear instrumentation specification when one SRM is inoperable. The concern (stated on pages 9 to 10 in TSTF-571) indicates that during the movement of fuel assemblies, sources, and reactivity control components with one SRM inoperable, there is the potential for the operable SRM to become effectively decoupled from the core reactivity condition (hereafter referred to as decouple-effect). For example, if one SRM is inoperable, and certain strategically located fuel assemblies are removed, then the operable SRM may no longer be capable of monitoring the reactivity condition of fuel assemblies that are located in the far half of the core. Therefore, the changes made in TSTF-286 and TSTF-471 may create a situation in which an increase in reactivity in part of the reactor core might not be detected.

In addressing the NRCs concern regarding the decouple-effect, the licensee added the requirement to suspend movement of fuel, sources, and reactivity control components within the reactor vessel. The NRC staff finds that the addition of this requirement for one or more required SRMs inoperable would avoid the reactivity change and adequately address the NRC staffs concern regarding the decouple-effect in TSTF-571 and, therefore, is acceptable.

Change 4: The statement Note 1: Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range

neutron flux monitor or to complete movement of a component to a safe condition, would be added as Note 1 to the added second action of ACTION a.

While the added Note 1 would modify the second action of Action a. by allowing fuel assemblies, sources, and reactivity control components to be moved if necessary to restore an inoperable SRM, the first action, which requires immediately suspending positive reactivity additions, remains effective. The first action of Action a. would prohibit the positive reactivity changes in the core, including the dilution of the boron concentration of the coolant in the RCS.

Also, the location and or movement of core components would not affect the initiation of, or mitigation of, a boron dilution event. The licensee clarified on page 12 of the enclosure to the LAR that based on the ANO-2 Safety Analysis Report (SAR), Section 15.1.4.3, if a boron dilution event in Mode 6 was assumed to occur, the event would unlikely result in an inadvertent core criticality, because significant action time is available for operator detection (an increase in RCS or canal level, drop in other inventories) and response (isolate source and/or borate the RCS) before SDM would be significantly challenged. In addition, the licensee stated that all CEAs could be removed without resulting in criticality based on Mode 6 boron concentration and that the ANO-2 plant procedures would normally not allow the removal of multiple CEAs from the core during refueling outages. Since (1) sufficient action time is available for operator to detect and terminate the boron dilution event before the SDM would be significantly challenged and (2) the removal of all CEAs from the core would not result in criticality based on Mode 6 boron concentration, the NRC staff finds that reasonable assurance is provided that the proposed Note 1 added to the second action of Action a., with the proposed first action of Action

a. requiring immediately suspending positive reactivity additions, would meet the intent of the current TS 3.9.2 requirement to continue minimizing positive reactivity changes within the core, while providing the ability to safely restore the SRM capability and, therefore, the proposed Note 1 is acceptable.

3.11.1.2 Change to ANO-2 SR 4.9.2.c.

The following change was proposed to ANO-2 SR 4.9.2.c. in TS 3.9.2:

The phrase prior to the initial start of CORE ALTERATIONS would be deleted and would be replaced with the phrase prior to the initial start of the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies.

The NRC staff determined that the replacement testing condition prior to the initial start of the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies specified in SR 4.9.2.c. is not required by the corresponding SR of STS 3.9.2 in TSTF-471 and is, therefore, more restrictive than the STS in TSTF-471.

Also, the deletion of the phrase core alterations is consistent with the intent of TSTF-471, which removes the phrase core alterations from the TSs. As for the replacement phrases referencing to the movement of recently irradiated fuel and new fuel, the NRC staff finds that this adequately reflects the updated ANO-2 FHA analysis, which assumes, as stated in Section 2.3, Reason for the Proposed Change, in the enclosure to the LAR, the drop of new (unirradiated) fuel assembly onto irradiated fuel assemblies as part of the dose consequence analysis.

The NRC staff reviewed the proposed SR 4.9.2.c. and finds that it is acceptable because (1) it is more restrictive than the corresponding SR of STS 3.9.2 in TSTF-471, (2) the deletion of the phrase CORE ALTERATIONS is consistent with the intent of TSTF-471, and (3) the phrase replacing CORE ALTERATIONS adequately reflects the updated ANO-2 FHA analysis.

3.1.12 Revision to ANO-2 TS 3.9.4 and SR 4.9.4.1 ANO-2 TS 3.9.4 Applicability and Action statement and SR 4.9.4.1 would be revised to delete core alterations and to include the movement of recently irradiated fuel assemblies or the movement of new fuel assemblies over recently irradiated fuel assemblies. Additionally, editorial changes are proposed to the Applicability and SR as described in Item 14 in the DOD section of the LAR. The NRC staff finds these changes acceptable because they are consistent with TSTF-471, supported by the licensees updated FHA analysis, or otherwise editorial in nature.

3.1.13 Revision to ANO-2 TS 3.9.5 and SR 4.9.5 The purpose of ANO-2 TS 3.9.5 is to require communications between the control room and fuel handling personnel in the containment building when on-loading or off-loading the core. ANO-2 TS 3.9.5 Applicability and Action statements and SR 4.9.5 would be revised to delete core alterations and to include the movement of irradiated fuel assemblies or the movement of new fuel assemblies over irradiated fuel assemblies. The licensee describes this change in Item 7 of the DOD section of the LAR. This TS is unique to the ANO-2 TSs when compared to the STS; therefore, this change is not directly addressed by TSTF-51 or TSTF-471. However, the deletion of core alterations is consistent with the NRCs intent in approving these TSTFs.

Additionally, the licensee has omitted the use of the word recently in its proposed TSs because, as described by the licensee, communications between the control room and fuel handlers during fuel on-loading and off-loading is important regardless of time after shutdown.

The NRC staff finds these changes acceptable because they meet the intent of TSTF-51 and are supported by the licensees update FHA analysis.

3.1.14 Revision to ANO-2 TS 3.9.8.1 The licensee proposed to delete the term all from Action a. in TS 3.9.8.1. This term is unnecessary because suspend all operations involving an increase in the reactor decay heat load or a reduction in boron concentration of the Reactor Coolant System has the same meaning as suspend operations involving an increase in the reactor decay heat load or a reduction in boron concentration of the Reactor Coolant System. Specifically, each version requires any operation involving an increase in the reactor decay heat load or a reduction in boron concentration of the RCS to be suspended. This is also true in the proposed change suspend operations involving an increase in the reactor decay heat load or that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1. Proposed Action a. in TS 3.9.8.1 has the same meaning with or without the term all and the deletion of this term does not change the TS requirement in TS 3.9.8.1. Therefore, the NRC staff finds that the deletion of the term all from the Action in TS 3.9.8.1 is acceptable.

The licensee proposed to revise TS 3.9.8.1 Action a. to include the acronym RCS. The use of the acronym RCS in place of Reactor Coolant System does not change any of the technical requirements in TS 3.9.8.1. Therefore, the NRC staff finds that the proposed change is acceptable.

The STSs have two LCOs related to shutdown cooling and coolant circulation.

STS LCO 3.9.4, Shutdown Cooling (SDC) and Coolant Circulation - High Water Level, is applicable in Mode 6 with water level greater than or equal to 23 feet above the top of the reactor vessel flange and requires one SDC loop to be in operation. STS LCO 3.9.5,

Shutdown Cooling (SDC) and Coolant Circulation - Low Water Level, is applicable in Mode 6 with water level less than 23 feet above the top of the reactor vessel flange and requires two SDC loops to be operable and one SDC loop to be in operation. When no SDC loop is in operation, both STS 3.9.4 Required Action A.1 and STS 3.9.5 Required Action B.1 require suspending operations involving a reduction in reactor coolant boron concentration. TSTF-286 modified these Required Actions so that they now require suspending operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1. Additionally, STS 3.9.4 has an LCO note that allows the required SDC loop to be removed from operation for less than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period provided that no operations are permitted that would cause reduction of the RCS boron concentration. This LCO note is modified by TSTF-286 to allow the required SDC loop to be removed from operation for less than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period provided that no operations are permitted that would cause introduction into the RCS with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

ANO-2 TS 3.9.8.1, Shutdown Cooling - One Loop, is applicable in Mode 6 and requires that at least one SDC loop be in operation which ensures that sufficient coolant circulation is maintained through the reactor core to minimize the effects of a boron dilution event and prevent boron stratification. Current ANO-2 TS 3.9.8.1 Action a. suspends all operations involving an increase in the reactor decay heat load or a reduction in boron concentration of the RCS when the LCO is not met and Action b. allows the SDC loop to be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period during the performance of core alterations.

TSTF-286 modified Required Actions in STSs 3.9.4 and 3.9.5 to allow boron reductions provided that boron concentration requirements are maintained and modified the LCO note in STS 3.9.4 to allow the SDC loop to be removed from operation for a limited time period provided that boron concentration requirements are maintained. ANO-2 TS 3.9.8.1 Action a. is similar to these STSs in that a reduction in boron concentration is not allowed when the LCO is not met.

The proposed ANO-2 TS 3.9.8.1 Action a. precludes an increase in the reactor decay heat load or a reduction in boron concentration less than that required to ensure that continued core criticality margins will be maintained. During conditions in which Action a. may be required, the following various activities for unit operation must be continued: RCS inventory must be maintained and RCS temperature must be controlled. These activities involve addition to the RCS of cooler water and may involve inventory makeup from sources that are at boron concentrations less than the current RCS concentration, but limit the introduction of reactivity more positive than that required to meet the required boron concentration of LCO 3.9.1. These activities do not need to be precluded in the ANO-2 TSs to ensure that, for the worst-case overall effect on the core, there would still be assurance that the required boron concentration is maintained.

ANO-2 TS 3.9.8.1 Action a. provides the NRC staff the assurance that the initial assumptions of the most limiting accident safety analyses applicable in Mode 6 are still maintained, while acknowledging that necessary routine plant operations may still be taken by adding cooler water to the RCS to lower the current temperature and that makeup sources are of borated water at boron concentrations less than the current RCS boron concentration. These routine plant operations are part of plant procedures and this ensures that the overall effect on core reactivity is properly monitored and that the TS-required refueling boron concentration is maintained.

Therefore, the NRC staff finds that the proposed change to TS 3.9.8.1 Action a. is acceptable and will continue to meet 10 CFR 50.36(c).

Proposed ANO-2 TS 3.9.8.1 Action b. ensures that no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1 when the SDC loop is removed from operation. Currently, TS 3.9.8.1 Action b. does not consider any effects on the boron concentration in the RCS when removing the SDC loop from operation. The proposed change to Action b. provides the NRC staff the assurance that the overall effect on core reactivity is properly monitored and that the TS-required refueling boron concentration is maintained. In addition, as discussed in Section 2.1.2 of this SE, the proposed deletion of core alterations is consistent with the intent of TSTF-51 and TSTF-471. Therefore, based on the foregoing, the NRC staff finds that the proposed change to TS 3.9.8.1 Action b. is acceptable and will continue to meet 10 CFR 50.36(c).

3.1.15 Revision to ANO-2 TS 3.9.9 and SR 4.9.9 ANO-2 TS 3.9.9 provides controls for reactor vessel water level during refueling operations.

The Applicability and Action statements and SR 4.9.9 would be revised to remove CEAs. The Applicability and Action statements and SR 4.9.9 would also be revised to include editorial changes as described in Item 15 in the DOD section of the LAR. Removing the references to CEAs is supported by the NRC staffs evaluation for removing the references to core alterations in the TSs as described in TSTF-471 because the movement of CEAs falls within the definition of a core alteration. Additionally, the removal of CEAs is consistent with the removal of core alterations from STS 3.9.6 as described in TSTF-51. The NRC staff finds these changes acceptable because they are consistent with TSTF-471 and TSTF-51 or are otherwise editorial in nature.

3.1.15.1 Change to ANO-2 LCO 3.9.9 The following change was proposed to ANO-2 LCO 3.9.9:

The phrase elevation corresponding to the would be added before top of irradiated fuel assemblies.

The NRC staff determined that this change would clarify that the proper water level is established prior to initiating refueling of the reactor core following a defueled condition. During a defueled condition in an outage, there is no fuel in the core and, based on the current LCO wording, verifying 23 feet of water over the top of irradiated fuel assemblies would not be possible. The NRC staff finds that adding the phrase elevation corresponding to the before top of irradiated fuel assemblies would remove this ambiguity and enhance the clarity of the current LCO statement and, therefore, the change is acceptable.

3.1.15.2 Changes to ANO-2 TS 3.9.9 Applicability and Action and SR 4.9.9 The following changes were proposed to ANO-2 TS 3.9.9 Applicability and Action statements and SR 4.9.9:

Change 1: The phrase within the reactor pressure vessel in the Applicability and Action statement would be replaced by the phrase within the Containment Building, which would also be added to the end of SR 4.9.9, after the phrase fuel assemblies.

The NRC staff determined that the changes clarify that the required water level should be met even when fuel is being moved in other areas of the refueling canal, not just in the reactor vessel, and, therefore, finds that the changes are acceptable.

Change 2: The phrase while in Mode 6 would be deleted from the Applicability statement.

The NRC staff determined that since fuel assemblies cannot be accessed within the reactor until Mode 6 has been achieved (per the TS Definition for Mode 6, which states, in part, reactor vessel head removed), referencing this mode of operation in the Applicability statement is redundant, and that the proposed deletion would remove this redundancy. Therefore, the NRC staff finds that the deletion of while in Mode 6 is acceptable.

Change 3: The phrase or CEAs would be removed from ANO-2 TS 3.9.9 Applicability and Action statements and SR 4.9.9.

The current ANO-2 TS 3.9.9 Applicability and Action statements and SR 4.9.9 refer to the movement of CEAs instead of the pre-TSTF-51 STS wording of core alterations. The NRC staff determined that the proposed change to delete the references to CEAs meets the intent of TSTF-51, because TSTF-51 deleted the references to core alterations, which included the movement of CEAs in its definition. Therefore, the NRC staff finds that the changes are acceptable.

3.1.16 Revision to ANO-2 TS Page 3/4 3-28 ANO-2 TS page 3/4 3-28 would be deleted. This page is blank. A Note would be added to the footer of TS page 3/4 3-27 stating that the Next Page is 3/4 3-36. The NRC staff determined that these changes are administrative in nature and do not change the TS requirements.

Therefore, the NRC staff finds these changes to be acceptable.

3.1.17 Revision to ANO-2 TSs to Reflect the Adoption of TSTF-286, Revision 2 The licensee requested changes to the TSs for ANO-2 to revise TS Actions that currently require suspending all operations involving any positive reactivity additions and to revise TS footnotes that preclude any reduction in boron concentration. The proposed changes would allow the introduction of reactivity as long as the TS required SDM or refueling boron concentration is properly maintained. The proposed changes are consistent with TSTF-286 except where noted below. The licensee provided plant-specific differences between the proposed changes and TSTF-286 as part of the LAR.

TSTF-286, Revision 2, revises the following in the STSs: (1) various required actions that require suspension of operations involving positive reactivity additions and (2) various TS LCO notes precluding reduction in boron concentration. The revised TSs for ANO-2 would limit the introduction of positive reactivity into the RCS to that which would maintain the TS required SDM or refueling boron concentrations, as applicable. Additionally, the Actions that require the suspension of positive reactivity changes will have TS Bases additions that clarify the intent to preclude a loss of required SDM.

The justification given in TSTF-286 is that the changes provide the flexibility necessary to provide for continued safe reactor operations, while also limiting any potential for excess positive reactivity addition to the core. The Actions and TS Notes that preclude positive reactivity changes and/or reduction in boron concentration ensure that either no power

increases will be experienced or that continued core criticality margins will be maintained.

During conditions in which these Actions may be required, the following various activities for unit operation must be continued: RCS inventory must be maintained and RCS temperature must be controlled. These activities involve addition to the RCS of cooler water and may involve inventory makeup from sources that are at boron concentrations less than the current RCS concentration, but limit the introduction of reactivity more positive than that required to meet the required SDM or boron concentration, as applicable. These activities do not need to be precluded in the TSs to ensure that, for the worst-case overall effect on the core, there would still be assurance that the required SDM is maintained.

The licensee employs two independent reactivity control systems: the control element drive system and the chemical and volume control system. The control element drive system controls short-term reactivity changes and is used for rapid shutdown of the reactor. The chemical and volume control system is used to compensate for long-term reactivity changes by adjusting the soluble boron concentration in the RCS and can make the reactor subcritical without the benefit of the control element drive system. In Modes 1 and 2, both systems are used to compensate for the reactivity effects from fuel and coolant temperature changes in the RCS during power operation from full load to no load conditions. In Modes 3, 4, and 5, the chemical and volume control system is used to compensate for reactivity effects from core temperature and reactor poisons, such as xenon. In Mode 6, the chemical and volume control system is used to maintain the boron concentration within the required limits.

In Modes 1 through 4, the minimum required SDM is assumed as an initial condition for the reload safety analyses to ensure that the safety limits will not be exceeded for normal operation and anticipated operational occurrences, assuming that the highest worth CEA remains stuck out following a reactor scram. The main steam line break at the end of reactor core life with average coolant temperature at no load operating temperature and boron dilution accidents are the most limiting events to establish the minimum SDM value for LCOs 3.1.1.1 and 3.1.1.2 and the minimum boron concentration requirement of LCO 3.9.1, respectively. For main steam line break accidents, if LCO 3.1.1.1 is not met, there is potential to exceed the departure from nucleate boiling ratio limit and the Actions of LCO 3.1.1.1 are necessary to restore compliance with the LCO. For the boron dilution accident, if LCO 3.1.1.2 or LCO 3.9.1 are not met, the minimum required time assumed for operator action to terminate dilution may no longer be sufficient, and the Actions of LCO 3.1.1.2 or LCO 3.9.1 are necessary to restore compliance with the LCO.

As stated in the TS Bases for LCOs 3.1.1.1 and 3.1.1.2, a sufficient SDM ensures that: (1) the reactor can be made subcritical from all operating conditions, (2) the reactivity transients associated with postulated accident conditions are controllable within acceptable limits, and (3) the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition. As stated in the proposed TS Bases for refueling boron concentration in the RCS and refueling canal in LCO 3.9.1, limitations on reactivity conditions during refueling ensure that: (1) the reactor will remain subcritical during fuel handling operations and (2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel. Since the proposed changes will not alter the limits established in these specifications, the NRC staff finds that the proposed changes will have no effect on the licensees ability to shut down and maintain the reactor in a subcritical condition.

The changes specified in TSTF-286, Revision 2, ensure that, under the specified plant conditions for each operating mode, unplanned power increases or reductions in the margin to core criticality are precluded. The proposed revision to existing TS footnotes and the addition of

wording to the TS Actions would allow the small reactivity variations that result from the temperature or boron concentration fluctuations associated with normal RCS inventory management or temperature control. These normal activities are permitted to be performed while maintaining the minimum SDM requirement of LCOs 3.1.1.1 and 3.1.1.2 and the minimum boron concentration requirement of LCO 3.9.1.

ANO-2 plant-specific adoption of TSTF-286, as modified by the NRC staff, provides the NRC staff the assurance that the initial assumptions of the most limiting accident safety analyses are still maintained, while acknowledging that necessary routine plant operations may still be taken by adding cooler water to the RCS to lower the current temperature and that makeup sources are of borated water at boron concentrations less than the current RCS boron concentration.

These routine plant operations are part of plant procedures and this would ensure that the overall effect on core reactivity is properly monitored and that the TS required SDM or the required refueling boron concentration is maintained. Therefore, the NRC staff finds the following proposed ANO-2 TSs, described above in Sections 2.2.4, 2.2.5, 2.2.7, 2.2.8, and 2.2.9 of this SE, to be acceptable.

TS 3.4.1.2 Action b.

TS 3.4.1.2 Footnote

TS 3.4.1.3 Action b. and Footnote

TS 3.4.1.3 Footnote

TS 3.8.1.2 Action TS 3.8.2.2 Action TS 3.8.2.4 Action b.

In the LAR, the licensee provided justification for changes that are (1) variations from TSTF-286, Revision 2 and (2) consistent with TSTF-286, Revision 2. Where plant-specific design would dictate differences, the licensee provided plant-specific justification for any differences or exceptions, as discussed below. The proposed TS changes are applicable to ANO-2.

(a) The proposed change revises the LCO, Action, and SR in ANO-2 TS 3.1.1.3, and are described in Section 2.2.2 of this SE.

The licensee proposed to revise the LCO, Action, and SR in ANO-2 TS 3.1.1.3 to include the acronym RCS, consistent with that proposed in TSTF-286, Revision 2. The use of the acronym RCS in place of Reactor Coolant System does not change any of the technical requirements in TS 3.1.1.3. The NRC staff finds that there is reasonable assurance that TS 3.1.1.3 will continue to meet 10 CFR 50.36(c) and, therefore, the proposed change to use the acronym RCS is acceptable.

The STSs do not have an STS related to Boron Dilution. TS 3.1.1.3 is specific to ANO-2 and is intended to verify that mixing flow is available whenever a reduction in RCS boron is being performed. The LCO minimum RCS flow rate provides adequate mixing, prevents stratification, and ensures that reactivity changes will be gradual during boron concentration reductions in the RCS. The reactivity change rate associated with boron concentration reductions will be within the capability of operator recognition and control.

The current Action in ANO-2 TS 3.1.1.3 immediately suspends all operations involving a reduction in boron concentration of the RCS when the minimum LCO RCS flow rate is not met.

TSTF-286 modified Required Actions in STS 3.4.5, RCS Loops - Mode 3, STS 3.4.6, RCS

Loops - Mode 4, STS 3.4.7, RCS Loops - Mode 5, Loops Filled, and STS 3.4.8, RCS Loops

- Mode 5, Loops not Filled, to allow boron reductions provided that SDM requirements are maintained. The Action in ANO-2 TS 3.1.1.3 is similar to these STS in that a reduction in boron concentration is not allowed when the LCO is not met.

The proposed Action in ANO-2 TS 3.1.1.3 would preclude a reduction in boron concentration and ensure that either no power increases will be experienced or that continued core criticality margins will be maintained. During conditions in which this Action may be required, the following activities for unit operation must be continued: RCS inventory must be maintained and RCS temperature must be controlled. These activities involve addition to the RCS of cooler water and may involve inventory makeup from sources that are at boron concentrations less than the current RCS concentration, but limit the introduction of reactivity more positive than that required to meet the required SDM or boron concentration, as applicable. These activities do not need to be precluded by the ANO-2 TSs to ensure that, for the worst-case overall effect on the core, there would still be assurance that the required SDM is maintained.

The proposed Action in ANO-2 TS 3.1.1.3 provides the NRC staff the assurance that the initial assumptions of the most limiting accident safety analyses are still maintained, while acknowledging that necessary routine plant operations may still be taken by adding cooler water to the RCS to lower the current temperature and that makeup sources are of borated water at boron concentrations less than the current RCS boron concentration. These routine plant operations are part of plant procedures and this would ensure that the overall effect on core reactivity is properly monitored and that the TS-required SDM or the required refueling boron concentration are maintained. Therefore, the NRC staff finds the proposed changes to the TS 3.1.1.3 Action acceptable. Additionally, the NRC staff finds that there is reasonable assurance that the remedial Action in TS 3.1.1.3 will continue to meet 10 CFR 50.36(c).

(b) The proposed change revises the LCO and Action a. in ANO-2 TS 3.4.1.2, as described in Section 2.2.4 of this SE.

ANO-2 TS 1.6 defines the terms Operable - Operability. Defined terms are capitalized throughout the ANO-2 TSs to alert the TS users that they can find the definition for the term in TS Section 1.0. The licensee proposes to capitalize the term operable in the LCO and Action a. for TS 3.4.1.2 since that term is defined in TS Section 1.0. The NRC staff finds that this proposed change is editorial because it does not change any TS requirement but only indicates that the term is defined in TS Section 1.0. Therefore, the NRC staff finds that the proposed change to the TS 3.4.1.2 LCO and Action a. is acceptable and that there is reasonable assurance that the LCO and the remedial Action a. in TS 3.1.1.3 will continue to meet 10 CFR 50.36(c).

(c) The proposed change revises the Action in ANO-2 TS 3.8.1.2 and is described in Section 2.2.7 of this SE.

The licensee proposes to delete the term all from the Action in TS 3.8.1.2. This term is unnecessary because suspend all operations involving positive reactivity changes has the same meaning as suspend operations involving positive reactivity changes. Specifically, each version requires any operation involving positive reactivity changes to be suspended. This is also true in the proposed change; the proposed Action has the same meaning with or without the term all and the deletion of this term does not change the TS requirement in TS 3.8.1.2.

Therefore, the NRC staff finds that the deletion of the term all from the Action in TS 3.8.1.2 is

acceptable and that there is reasonable assurance that the Action in TS 3.8.1.2 will continue to meet 10 CFR 50.36(c).

The licensee proposes the addition of the Completion Time immediately to the TS 3.8.1.2 Action. The addition of the Completion Time immediately clarifies that the TS 3.8.1.2 Action should be taken without delay. This is consistent with the Completion Times in TSTF-286, Revision 2, Required Actions A.2.3 and B.3 in STS 3.8.2, AC Sources - Shutdown.

With less than the minimum required A.C. electrical power sources stated in the LCO, the minimum required diversity of A.C. power sources is unavailable and TS 3.8.1.2 requires suspending operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This Action is required to ensure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that that would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration but provides acceptable margin to maintaining subcritical operation. This Action minimizes the probability of the occurrence of postulated events. The Completion Time of immediately is consistent with the required times for Actions requiring prompt attention. Therefore, the NRC staff finds that the addition of the Completion Time immediately in the TS 3.8.1.2 Action is acceptable.

(d) The proposed change would revise the Action in ANO-2 TS 3.8.2.2 and is described in Section 2.2.8 of this SE.

The licensee proposes to delete the terms and energized and any from the Action in TS 3.8.2.2.

Currently, the Action in ANO-2 TS 3.8.2.2 is entered when there is less than the minimum required A.C. electrical busses stated in the LCO, operable and energized. In the Action, the term and energized eliminates the use of this Action when the LCO is not met and the A.C.

electrical bus/busses is/are de-energized. No applicable Action exists in TS 3.8.2.2 when the LCO is not met and the A.C. electrical bus/busses is/are de-energized and, therefore, the licensee is required to enter and follow the remedial actions in TS LCO 3.0.3. TS LCO 3.0.3 specifies actions for placing the unit in cold shutdown (Mode 5).

Currently, TS 3.8.2.2 is Applicable in Mode 5 (cold shutdown) and Mode 6 (refueling). When TS LCO 3.8.2.2 is not met and the A.C. electrical busses are de-energized, TS LCO 3.0.3 is entered but its actions do not place the unit in a mode in which the specification does not apply, nor does it require any remedial action which addresses the inoperable A.C. electrical busses, nor does it minimize the probability of the occurrence of postulated events.

By deleting the term and energized from the Action in TS 3.8.2.2, the revised TS 3.8.2.2 provides remedial actions to address the unavailability of required A.C. electrical busses when the LCO is not met (i.e., fewer than the minimum A.C. electrical busses required by the LCO are operable) and the remaining operable A.C. electrical bus/busses is/are energized or de-energized.

The proposed Action in TS 3.8.2.2 immediately suspends operations involving positive reactivity additions that could result in the loss of required SDM or boron concentration. This Action minimizes the occurrence of a postulated boron dilution event while in Mode 5 and/or 6.

Removal of the term any does not alter the intent of this Action because the Action continues to require all operations involving positive reactivity addition to be suspended. In addition,

immediately suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to ensure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that that would be required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration but provides acceptable margin to maintaining subcritical operation. Therefore, the NRC staff finds that the removal of the terms and energized and any from the Action in TS 3.8.2.2 is acceptable and that there is reasonable assurance that the Action in TS 3.8.2.2 will continue to meet 10 CFR 50.36(c).

3.2 TS Bases Changes In accordance with 10 CFR 50.36(a)(1), the licensee submitted TS Bases changes that correspond to the proposed TS changes for information only. The licensee will make supporting changes to the TS Bases in accordance with ANO-2 TS 6.5.14, Technical Specifications (TS)

Bases Control Program.

3.3 Conclusion of the NRC Staff Evaluation The NRC staff has reviewed the licensees application with the supporting documentation.

Based on its review, the NRC staff determined that the proposed changes to the TSs are acceptable because the proposed changes address the non-conservatisms in the existing TSs by revising TS statements to include the movement of new and irradiated fuel over irradiated fuel. The NRC staff also determined that these changes are consistent with the TSTF travelers adopted in this LAR. Therefore, the NRC staff concludes that the proposed changes as discussed in Sections 2.0 and 3.0 of this SE are acceptable and that there is reasonable assurance that 10 CFR 50.36(c) will continue to be met.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Arkansas State official was notified of the proposed issuance of the amendment on September 24, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on December 3, 2019 (84 FR 66228), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by

operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: K. Bucholtz D. Garmon-Candelaria S. Sun T. Wengert Date: October 30, 2020

ML20240A280 *By e-mail **By memorandum OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA* NRR/DSS/STSB/BC** NRR/DRA/ARCB/BC**

NAME TWengert PBlechman w/comments VCusumano KHsueh DATE 10/8/20 9/23/2020 2/21/20 7/14/20 OFFICE NRR/DSS/SNSB/BC** NRR/DSS/SCPB/BC* NRR/DE/EEOB/BC* NRR/DE/EICB/BC*

NAME SKrepel BWittick BTitus (RMathew for) MWaters DATE 5/19/20 9/28/20 10/13/20 9/29/20 OFFICE OGC NLO* NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JWachutka JDixon-Herrity TWengert DATE 10/28/20 10/30/20 10/30/20

v t e Letter Sequence Approval
EPID:L-2019-LLA-0188, TSTF-205, TSTF-563, TSTF-286, TSTF-471, TSTF-272, TSTF-268, TSTF-051, TSTF-563, TSTF-571 (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2019-04-30 [Table View]

NUREG-1432, Issuance of Amendment No. 322 Technical Specification Changes Related to Revised Fuel Handling Accident Analysis and Adoption of Technical Specification Improvements Consistent with NUREG-1432

Text

SUBJECT:

Dear Sir or Madam:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Navigation menu

NUREG-1432, Issuance of Amendment No. 322 Technical Specification Changes Related to Revised Fuel Handling Accident Analysis and Adoption of Technical Specification Improvements Consistent with NUREG-1432

Text

SUBJECT:

Dear Sir or Madam:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Navigation menu

Search