Text

License Amendment Request - Application to Adopt a Safety Function Determination Program (SFDP)
	ML20322A426
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/17/2020
From:	Gaston R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	2CAN112004
	Download: ML20322A426 (106)
	v • d • e

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 2CAN112004 November 17, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

License Amendment Request Application to Adopt a Safety Function Determination Program (SFDP)

Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 As required by 10 CFR 50.90, Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs).

Entergy requests to incorporate the provisions of Limiting Condition for Operation (LCO) 3.0.6 of the Improved Standard Technical Specifications (ISTS), which provide the actions to be taken when the inoperability of a support system results in the inoperability of a related supported system(s). The proposed change adds a new Safety Function Determination Program to the administrative section of the TSs to ensure that a loss of safety function is detected, and appropriate actions are taken when using the provisions of the subject LCO.

The enclosure provides Entergy's evaluation of the proposed changes. Attachment 1 of the enclosure provides the existing TS pages marked up to illustrate the proposed changes. of the enclosure provides existing TS Bases pages marked up to illustrate the proposed changes, for information only, and will be incorporated in accordance with the plant's TS Bases Control Programs upon implementation of the approved amendment. Attachment 3 of the enclosure provides retyped (revised) TS pages. Attachment 4 of the enclosure provides a table of support system required actions in the ISTS that direct entering the conditions and required actions of supported systems and indicates how these required actions are addressed in the proposed change.

Approval of the proposed amendment is requested by December 31, 2021. Once approved, the amendment shall be implemented within 90 days.

This letter contains no new regulatory commitments.

2CAN112004 Page 2 of 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Entergy is notifying the State of Arkansas of this amendment request by transmitting a copy of this letter and enclosure to the designated State Official.

Should you have any questions or require additional information, please contact Riley Keele, Manager, Regulatory Assurance, at 479-858-7826.

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

Executed on November 17, 2020.

Respectfully, ORIGINAL SIGNED BY RON GASTON Ron Gaston RWG/mar

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1.

Technical Specification Page Markups

2.

Technical Specification Bases Page Markups (for Information Only)

3.

Retyped Technical Specification Pages

4.

Table of Support System Actions that Direct Entering Actions of Supported Systems cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official

Enclosure 2CAN112004 Evaluation of the Proposed Change

2CAN112004 Enclosure Page 1 of 32 Table of Contents 1.0

SUMMARY

DESCRIPTION............................................................................................... 2 2.0 DETAILED DESCRIPTION................................................................................................ 2 2.1 Current Technical Specifications Requirements............................................................. 2 2.2 Reason for the Proposed Change.................................................................................. 2 2.3 Description of the Proposed Change.............................................................................. 2

3.0 TECHNICAL EVALUATION

............................................................................................... 8 3.1 Change to LCO 3.0.2...................................................................................................... 8 3.2 Deletion of LCO 3.0.5 and Adoption of ISTS Definition of Operable.............................. 9 3.3 Addition of LCO 3.0.6................................................................................................... 12 3.4 New Notes that Direct Entering Actions of Supported Systems................................... 14 3.5 Changes to LCO Actions and Surveillance Requirements........................................... 16 3.6 ISTS Support System LCOs that Direct Entry into Supported System Actions that are not applicable to the ANO-2 TSs.................................................................................. 24

4.0 REGULATORY EVALUATION

......................................................................................... 26 4.1 Applicable Regulatory Requirements and Criteria........................................................ 26 4.2 Precedents................................................................................................................... 26 4.3 No Significant Hazards Consideration.......................................................................... 28 4.4 Conclusion.................................................................................................................... 30 5.0 ENVIRONMENTAL EVALUATION.................................................................................. 31

6.0 REFERENCES

................................................................................................................. 31 7.0 ATTACHMENTS.............................................................................................................. 32

2CAN112004 Enclosure Page 2 of 32 EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TSs) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed amendment modifies the TSs to incorporate the provisions of Limiting Condition for Operation (LCO) 3.0.6 of the Improved Standard Technical Specifications (ISTS), which provide the actions to be taken when the inoperability of a support system results in the inoperability of a related supported system(s). The proposed change adds a new Safety Function Determination Program (SFDP) to the administrative section of the TSs to ensure that a loss of safety function is detected, and appropriate actions are taken when using the provisions of the LCO.

2.0 DETAILED DESCRIPTION 2.1 Current Technical Specifications Requirements The ANO-2 TSs, which are based on NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors" (Reference 1), do not include a provision similar to LCO 3.0.6 in NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants" (Reference 3).

2.2 Reason for the Proposed Change This change incorporates the provisions of LCO 3.0.6 in the ISTS, which addresses the issue of cascading when implementing the TSs. The proposed change will eliminate the potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' Actions. The Actions necessary to ensure the plant is maintained in a safe condition are included in the support system's Actions, which may include directions to enter the Actions for the supported system when appropriate.

2.3 Description of the Proposed Change Note: TS additions are underlined.

Specification 3.0.2 is proposed to be revised to include ISTS LCO 3.0.6. The term "Specification" in LCO 3.0.2 is also replaced by the acronym "LCO" as defined in ANO-2 LCO 3.0.1 and the title "Limiting Condition for Operation" is replaced with the LCO acronym for consistency. The current reference to LCO 3.0.6 is revised to LCO 3.0.5 due to the deletion of LCO 3.0.5 resulting in the current LCO 3.0.6 (related to conditions when returning equipment to service) being renumbered as LCO 3.0.5.

3.0.2 Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in LCOSpecification 3.0.56 and LCO 3.0.6. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.

2CAN112004 Enclosure Page 3 of 32 The existing LCO 3.0.5 is proposed for deletion based on changes occurring to LCO 3.8.1.1, "A.C. Sources," (discussed later). These changes permit adoption of the ISTS version of the TS definition of "operable":

A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when.

Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal orand emergency electrical power sources, cooling andor seal water, lubrication, andor other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

Action (b) of LCO 3.4.4, "Pressurizer," is deleted due the adoption of the ISTS definition of "operable" described above:

(b) With the pressurizer inoperable due to an inoperable emergency power supply to the pressurizer heaters, either restore the inoperable emergency power supply in accordance with TS 3.8.1.1, Action b.3, for an inoperable Emergency Diesel Generator, or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Actions (c) and (d) of LCO 3.4.4 are renumbered as Actions (b) and (c), respectively due the deletion of Action (b) above.

In support of this change, Surveillance Requirement (SR) 3.4.4.2.a is deleted and SR 3.4.4.2.b moved into the introductory statement of SR 3.4.4.2:

4.4.4.2 The pressurizer proportional heater groups shall be determined to be OPERABLE.

(a)

In accordance with the Surveillance Frequency Control Program by verifying emergency power is available to the heater groups, and (b) iIn accordance with the Surveillance Frequency Control Program by verifying that the summed power consumption of the two proportional heater groups is 150 KW.

A new LCO 3.0.6 is proposed. ANO-2 currently has an LCO numbered 3.0.6 which corresponds to ISTS LCO 3.0.5. As described above, the current ANO-2 LCO 3.0.5 (associated with power sources) is proposed for deletion. Therefore, the current ANO-2 LCO 3.0.6 is proposed to be renumbered as LCO 3.0.5 and the new SFDP-related LCO will be numbered LCO 3.0.6, consistent with the ISTS.

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

2CAN112004 Enclosure Page 4 of 32 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the ACTIONs associated with this supported system are not required to be entered. Only the support system LCO ACTIONs are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.5.19, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

Action Notes and/or Actions are proposed that direct entering the Actions for supported systems:

1.

LCO 3.3.2.1, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," Table 3.3-3, Functional Unit 7.a, "4.16 kv Emergency Bus Undervoltage (Loss of Voltage)," and 7.b, "460 volt Emergency Bus Undervoltage (Degraded Voltage)," is revised to require entry into applicable Actions of the associated Emergency Diesel Generator (EDG) for inoperable Loss of Voltage (LOV) and Degraded Voltage (DV) channels when any DV relay (channel) or both LOV relays on a respective safety bus are inoperable (discussed later). To address this, a new Action 14 is proposed:

ACTION 14 - With the number of 460 volt Degraded Voltage (Functional Unit 7.b) channels one less than the Total Number of Channels or with both 4.16 kv Loss of Voltage (Functional Unit 7.a) channels inoperable on a single bus:

a.

Immediately declare the affected EDG inoperable, and

b.

Restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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 that while Action 14 is a new action, it was developed from Action 9 and the wording above in bold type is carried forward from the existing Action 9.

2.

An Action Note is added to LCO 3.4.6.2, "Reactor Coolant System Leakage":

Enter applicable ACTION(s) for system(s) made inoperable by an inoperable pressure isolation valve.

2CAN112004 Enclosure Page 5 of 32

3.

Although an SFDP-related Action Note is not required for ANO-2 LCO 3.6.1.3, "Containment Air Locks" (discussed later), LCO 3.6.1.2, "Containment Leakage,"

requires revision to meet the intent of ISTS SFDP-related Action since the current TS 3.6.1.2 Action does not provide appropriate remedial action when in Modes 1, 2, 3, or 4. The LCO 3.6.1.2 Action is proposed to be revised, consistent with ISTS 3.6.1, "Containment (Atmospheric and Dual)," as follows:

With the containment leakage rate exceeding the acceptance criteria of the Containment Leakage Rate Testing Program, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , restore leakage to within limits or 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 COLD SHUTDOWN within the following 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months sWith containment leakage rates not within limits, restore containment leakage to within limits, prior to increasing the Reactor Coolant System temperature above 200 °F.

4.

An Action Note is added to LCO 3.6.3.1, "Containment Isolation Valves":

Enter applicable ACTION(s) for system(s) made inoperable by containment isolation valves.

5.

Action Notes are added to LCO 3.7.3.1, "Service Water System":

Enter applicable ACTION(s) of LCO 3.8.1.1, "A.C. Sources," for EDG made inoperable by service water system.

Enter applicable ACTION(s) of LCO 3.4.1.3, "Reactor Coolant System - Shutdown,"

if a required shutdown cooling loop is made inoperable by service water system.

6.

LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4), Action a (one inoperable offsite source) is revised to include the following:

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s), declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable, and Because Actions are normally listed in the order of the time permitted to perform the action, this new action is numbered Action a.2 and the current Action a.2 is renumbered as Action a.3.

7.

LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4), Action b (one inoperable EDG) is revised to include the following:

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) is inoperable, and Because Actions are normally listed in the order of the time permitted to perform the action, this new action is numbered Action b.2 and the current Actions b.2 and b.3 are renumbered as Actions b.3 and b.4, respectively.

2CAN112004 Enclosure Page 6 of 32

8.

LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4), Action c (one EDG and one offsite source inoperable) is revised to include the following:

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable if its redundant required feature(s) is inoperable, and Because Actions are normally listed in the order of the time permitted to perform the action, this new action is numbered Action c.2 and the current Actions c.2, c.3, and c.4 are renumbered as Actions c.3, c.4, and c.5, respectively.

9.

An Action Note is added to LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4),

Action c (one EDG and one offsite source inoperable) to include the following:

Enter applicable ACTIONs of LCO 3.8.2.1, "A.C. Distribution - Operating," when ACTION c is entered with no AC power to any train.

10. LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4), Action d (two offsite sources inoperable) is revised to include the following:

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , declare required feature(s) inoperable when its redundant required feature(s) is inoperable, and Because Actions are normally listed in the order of the time permitted to perform the action, this new action is numbered Action d.2 and the current Actions d.2 and d.3 are renumbered as Actions d.3 and d.4, respectively.

In addition, Action d is relocated in its entirety from TS Page 3/4 8-2 to Page 3/4 8-2a due to space limitations.

11. Because the sub-bullets of LCO 3.8.1.1, "A.C. Sources" (Modes 1, 2, 3, and 4),

Action b, are renumbered as described above, LCO 3.8.1.1, Action e.3 is revised to refer to Action b.4, Note 1 (vs. Action b.3).

12. An Action Note is added to LCO 3.8.1.2, "A.C. Power Sources - Shutdown":

Enter applicable ACTIONs of LCO 3.8.2.2, "A.C. Distribution - Shutdown," and LCO 3.8.2.4, "D.C. Sources - Shutdown," with one required train de-energized.

13. An Action Note is added to LCO 3.8.2.1, "A.C. Distribution System - Operating":

Enter applicable ACTION(s) of LCO 3.8.2.3, "DC Sources - Operating" for DC train(s) made inoperable by inoperable power distribution subsystems.

14. LCO 3.8.2.2, "A.C. Distribution - Shutdown," Actions are revised as follows:

With less than the above complement of A.C. busses OPERABLE and energized, declare affected required features inoperable OR:

a.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and

2CAN112004 Enclosure Page 7 of 32

b.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

Note that the words that are not underlined are carried forward from the existing Action. Since the original LCO only contained one Action, the Action section was reformatted into Actions a and b, and the original action was moved to Action a.

15. LCO 3.8.2.4, "D.C. Sources - Shutdown," Action b is revised as follows:

b.

With the requirements of ACTION a not met or with the above complement of DC equipment and bus otherwise inoperable, declare affected required features inoperable OR:

i.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and ii.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

Note that the words that are not underlined are carried forward from the existing Action. Since the original LCO only contained one action in Action b, Action b was reformatted into sub-actions i and ii, and the original action was moved to Action b.i.

16. A new administrative TS 6.5.19, "Safety Function Determination Program (SFDP)," is added. The wording is slightly modified to accommodate the old standard wording of the ANO-2 TS (i.e., ISTS "Required Action" replaced with "ACTION" and "Completion Time" replaced with "allowable outage time").

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs. This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:

a.

Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected,

b.

Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists,

c.

Provisions to ensure that an inoperable supported system's allowed outage time is not inappropriately extended as a result of multiple support system inoperabilities, and

d.

Other appropriate limitations and remedial or compensatory actions.

2CAN112004 Enclosure Page 8 of 32 A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a.

A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

b.

A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or

c.

A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate ACTIONs to enter are those of the support system.

There are a number of ISTS LCOs that may have SFDP-related actions or notes, but do not result in modification of a similar ANO-2 LCO (or a similar ANO-2 LCO does not exist). of this enclosure provides a comparison of the ISTS and the ANO-2 TSs that are potentially related to SFDP adoption. The attachment includes those ANO-2 TSs that are not revised in support adopting a SFDP. For example, some ISTS LCOs do not exist in the ANO-2 TSs. These differences are discussed further in Section 3.6 below.

3.0 TECHNICAL EVALUATION

3.1 Change to LCO 3.0.2 Proposed new LCO 3.0.6 is an exception to LCO 3.0.2; therefore, LCO 3.0.2 is modified to include reference to LCO 3.0.6 as an exception, consistent with the ISTS. As discussed below, ANO-2 LCO 3.0.5 is being deleted and the current LCO 3.0.6 is renumbered as LCO 3.0.5, therefore, the LCO 3.0.2 reference to LCO 3.0.6 is revised to refer to LCO 3.0.5.

Other editorial changes that involve no technical change to LCO 3.0.2 include replacing references to "Conditions and Required Actions" with the ANO-2 nomenclature of "ACTIONs".

The ANO-2 TSs are not based on NUREG-1432 and do not use these terms but only refer to the term "ACTION" as defined in Section 1.0 of the ANO-2 TSs. In addition, as the acronym "LCO" is currently defined in ANO-2 LCO 3.0.1, references to "Limiting Conditions for Operation" within LCO 3.0.2 are replaced with the "LCO" acronym.

2CAN112004 Enclosure Page 9 of 32 3.2 Deletion of LCO 3.0.5 and Adoption of ISTS Definition of "Operable" The definition of operability as provided in Section 1.0 of the ANO-2 TSs requires both an operable normal and emergency power source for the supported system to be considered operable. LCO 3.0.5 provides an exception to this definition, permitting a structure, system, or component (SSC) supported by TS-required normal or emergency power sources to be considered operable provided it continues to be supported by either its normal or emergency power source, and its redundant counterpart remains fully operable (having both an operable normal and emergency power source). If these conditions are not met, LCO 3.0.5 requires action to be initiated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to place the unit in at least Mode 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Mode 4 in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Mode 5 within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The ISTS does not contain an LCO equivalent to ANO-2 LCO 3.0.5. Instead, Required Actions A.2, B.2, and C.1 of ISTS LCO 3.8.1, "AC Sources - Operating," address potential cross-train impacts for the conditions where an offsite circuit ("normal" power source), an EDG

("emergency" power source), or both offsite circuits are inoperable, respectively.

In support of the adoption of a SFDP and to gain greater consistency with the ISTS, ANO-2 LCO 3.0.5 is proposed for deletion and the applicable Actions of ANO-2 LCO 3.8.1.1, "A.C.

Sources," modified to address potential operability impacts when a required power source(s) is inoperable. The 2-hour allowable outage time (AOT) of ANO-2 LCO 3.0.5 is equivalent to the 2-hour AOT of ANO-2 LCO 3.8.1.1, Action e.2 (both EDGs inoperable). The ISTS Completion Times related to potential operability impacts of redundant SSCs for other power source inoperabilities (one or both normal power sources, or one EDG) are longer than the current 2-hour AOT of ANO-2 LCO 3.0.5. Therefore, this change is considered less restrictive.

As an example, ISTS 3.8.1, Required Action A.2 (one offsite power source inoperable), requires required feature(s) with no offsite power available to be declared inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when its redundant required feature(s) is inoperable. This Completion Time is greater than the 2-hour AOT provided in ANO-2 LCO 3.0.5. The following discussion provides the ISTS Completion Time for the respective power source configurations relative to supported SSC operability and provides the ISTS Bases supporting the acceptability of these Completion Times (wording modified and paraphrased to reflect ANO-2 TS terminology).

One Normal (Offsite) Power Source Inoperable ISTS Completion Time:

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Acceptability/Bases:

The AOT is intended to allow the operator time to evaluate and repair any discovered inoperabilities. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. The remaining operable offsite circuit and EDGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24-hour AOT takes into account the component operability of the redundant counterpart to the inoperable required feature. Additionally, the 24-hour AOT takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a design basis accident (DBA) occurring during this period.

2CAN112004 Enclosure Page 10 of 32 One Emergency (EDG) Power Source Inoperable ISTS Completion Time:

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Acceptability/Bases:

[This Action] is intended to provide assurance that a loss of offsite power, during the period that an EDG is inoperable, does not result in a complete loss of safety function of critical systems. The [4-hour] AOT is intended to allow the operator time to evaluate and repair any discovered inoperabilities. Four hours from the discovery of these events existing concurrently, is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown. In this condition, the remaining operable EDG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4-hour AOT takes into account the operability of the redundant counterpart to the inoperable required feature. Additionally, the 4-hour AOT takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

One Normal and One Emergency Power Source Inoperable ISTS Completion Time:

ISTS rules require application of the above two Completion Times, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months being the most limiting.

Two Normal Power Sources Inoperable ISTS Completion Time:

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Acceptability/Bases:

[This Action] is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The AOT for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power. The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide (RG) 1.93, "Availability of Electric Power Sources," allows an AOT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are operable. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter AOT of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate.

According to RG 1.93, operation may continue in this condition for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

2CAN112004 Enclosure Page 11 of 32 Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more EDGs inoperable. However, two factors tend to decrease the severity of this level of degradation:

a.

The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and

b.

The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a loss of coolant accident (LOCA), and a worst-case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24-hour AOT provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

For cases where both EDGs are inoperable, both the ISTS and ANO-2 LCO 3.8.1.1 require restoration of at least one EDG within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Therefore, ISTS does not contain a Required Action related to potential impacts on supported SSCs based on the 2-hour requirement to restore an EDG. Note also that neither the ISTS or the ANO-2 TSs permit operation with three or more power sources inoperable.

The above bases for acceptability of applying the ISTS Completion Times regarding potential impacts to SSC operability upon various configurations of power source inoperabilities are generically approved for Combustion Engineering (CE) plants and are applicable to ANO-2.

While the subject AOTs are, in general, less restrictive than the current 2-hour AOT of ANO-2 LCO 3.0.5, sufficient margin to safety is maintained through adoption of the corresponding ISTS AOTs. Because cross-train operability and the monitoring for the loss of a safety function are addressed in the proposed changes (described in detail in the LCO 3.8.1.1 discussion later in this section), Entergy concludes that the proposed change to delete ANO-2 LCO 3.0.5 based on the changes proposed for incorporation into LCO 3.8.1.1 is acceptable.

The current ANO-2 TS definition of "operable" requires both the normal and emergency power supplies supporting an associated TS-required component to be operable. However, LCO 3.0.5 effectively provides an exception to this definition by allowing one of these power supplies to be inoperable while still considering the supported TS component operable, provide the redundant TS component is operable with both a normal and emergency power supply. Entergy proposes to adopt the ISTS definition of "operable", which replaces the aforementioned "and" with "or" as follows (emphasis added):

OPERABLE - OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

2CAN112004 Enclosure Page 12 of 32 Although LCO 3.0.5 is proposed for deletion, the intent of LCO 3.0.5 is maintained by the proposed adoption of ISTS Actions and Notes within ANO-2 LCO 3.8.1.1 (discussed later).

While the ISTS-based revisions to ANO-2 LCO 3.8.1.1 will still require operability of an associated redundant component when one or more AC power sources is inoperable, the redundant component operability will now be based on having at least one power supply (normal or emergency) operable, instead of both its normal and emergency power supplies operable. While this is considered a less restrictive change, it is offset by the time in which AC power sources are permitted to be inoperable and by the adoption of the SFDP, which protects against a loss of safety function. This change is consistent with the ISTS and as approved in the ANO, Unit 1 (ANO-1) TS conversion to the ISTS in 2001, as discussed in Discussion of Change (DOC) A8 (Reference 7).

In addition, the ISTS definition contains the term "safety" in the phrase "specified safety function(s)," which is currently not included in the ANO-2 TS definition of "operable". The addition of the "safety" term within this phrase, along with other administrative differences as illustrated in Section 2.3 above and in the attached TS markup page, does not change the manner in which the TSs are applied, nor does it result in any technical change to an existing requirement. Based the foregoing discussion, Entergy has determined that the adoption of the ISTS definition of "operable" is justified.

3.3 Addition of LCO 3.0.6 The proposed change incorporates ISTS LCO 3.0.6 into the ANO-2 TS as new LCO 3.0.6.

LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the TS. The exception to LCO 3.0.2 is provided because LCO 3.0.2 would require that the Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's Actions. These Actions may include entering the supported system's Actions or may specify other Actions to be entered. The exception to LCO 3.0.2 is provided because otherwise, applying LCO 3.0.6 would result in noncompliance with LCO 3.0.2.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) is required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' Actions unless directed to do so by the support system's Actions. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems LCO Actions are eliminated by providing all the Actions that are necessary to ensure the plant is maintained in a safe condition in the support system's Actions.

However, there are instances where a support system's Action may either direct a supported system to be declared inoperable or direct entry into Actions for the supported system. This may occur immediately or after some specified delay to perform some other Action. Regardless of whether it is immediate or after some delay, when a support system's Action directs a supported system to be declared inoperable or directs entry into Actions for a supported system, the applicable Actions are entered in accordance with LCO 3.0.2.

2CAN112004 Enclosure Page 13 of 32 The proposed new administrative TS, "Safety Function Determination Program (SFDP),"

ensures that a loss of safety function is detected and that appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation is performed to determine if a loss of safety function exists.

Additionally, other appropriate actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system Actions. The SFDP implements the requirements of LCO 3.0.6 as discussed below.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of an onsite EDG(s), a safety function assumed in the accident analysis cannot be performed. If an evaluation determines that a loss of safety function exists, the appropriate Actions of the LCO in which the loss of safety function exists are required to be entered.

When a loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Actions of the LCO in which the loss of safety function exists, consideration is given to the specific type of function affected. Where a loss of function is solely due to a single TS support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level), the appropriate LCO is the LCO for the support system.

The Actions for a support system LCO adequately address the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

The proposed addition of LCO 3.0.6 to the ANO-2 TS would eliminate potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO Actions by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's required actions. The proposed change is consistent with LCO 3.0.6 in the ISTS. Based on these considerations, Entergy concludes that the proposed change is acceptable.

The proposed LCO 3.0.6 is written as follows:

When a supported system LCO is not met solely due to a support system LCO not being met, the ACTIONs associated with this supported system are not required to be entered. Only the support system LCO ACTIONs are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.5.19, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

2CAN112004 Enclosure Page 14 of 32 3.4 New Notes that Direct Entering Actions of Supported Systems Proposed LCO 3.0.6 requires entering the Actions of the LCOs for supported systems when directed by a support systems' Actions, and the ISTS Bases for LCO 3.0.6 discuss that there are instances where a support system's Action may either direct a supported system to be declared inoperable or direct entry into the Actions for the supported system. As a result, this proposed change adds Notes that modify various support system LCOs or Actions to direct entering the Actions of supported systems or other TS systems affected by the inoperable support system or component when application of the SFDP would be inappropriate based on actions that need to be initiated. The proposed notes are consistent with those included in the ISTS that are applicable to ANO-2. Attachment 4 provides a table that identifies the Notes in the ISTS that direct entering the Actions of supported or affected systems and summarizes how the applicable Notes are addressed in this proposed change.

The proposed notes and the corresponding bases are discussed below.

a.

The Actions of ISTS LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," are modified by the following note:

[ISTS Note 2]: Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.

ANO-2 does not have an equivalent LCO; however, ANO-2 LCO 3.4.6.2, "Reactor Coolant System Operational Leakage," requires any leaking PIV to be isolated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if leakage limits are exceeded. Based on the ISTS, the following note is proposed to be added to Action c of ANO-2 LCO 3.4.6.2:

Enter applicable ACTIONs for systems made inoperable by an inoperable pressure isolation valve.

PIV leakage may have affected system operability or isolation of a flow path which may have degraded the ability of the interconnected system to perform its safety function. The subject Note will ensure entry into the appropriate system TS and provide greater consistency with the ISTS.

b.

The Required Actions in ISTS LCO 3.6.3, "Containment Isolation Valves (Atmospheric and Dual)," are modified by the following two Notes.

[ISTS Note 3]: Enter applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves.

[ISTS Note 4]: Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

The corresponding ANO-2 LCO is 3.6.3.1, "Containment Isolation Valves." ISTS LCO 3.6.3 Note 3 requires entering the Actions for systems made inoperable as a result of inoperable containment isolation valves (CIVs) to ensure that appropriate remedial actions are taken.

A similar Note is being incorporated into ANO-2 LCO 3.6.3.1 as part of this proposed change.

2CAN112004 Enclosure Page 15 of 32 ISTS LCO 3.6.3 Note 4 directs entering the Required Action of ISTS LCO 3.6.1, the corresponding ANO-2 LCO being 3.6.1.1, "Containment Integrity," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

ANO-2 LCO 3.6.3.1 does not require CIVs to meet leakrate criteria. For ANO-2, containment leakage requirements are governed by a separate TS (LCO 3.6.1.2, "Containment Leakage"); therefore, ISTS Note 4 does not need to be incorporated into ANO-2 TS 3.6.3.1 in support of adopting a SFDP. However, ANO-2 LCO 3.6.1.2 is being modified to ensure appropriate action is initiated when containment leakage limits are not met (discussed later in section 3.5.b).

c.

Required Action A.1 (one Service Water train inoperable) of ISTS LCO 3.7.8, "Service Water System (SWS)," is modified by the following two Notes:

[ISTS Note 1]: Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by SWS.

[ISTS Note 2]: Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - Mode 4," for shutdown cooling made inoperable by SWS.

The corresponding ANO-2 LCO is 3.7.3.1, "Service Water System." ISTS Note 1 requires entering the Required Actions of ISTS LCO 3.8.1, "AC Sources - Operating," for the EDG made inoperable by the SWS. The corresponding ANO-2 LCO is 3.8.1.1, "AC Sources,"

and a similar Note is being incorporated into ANO-2 LCO 3.7.3.1 as part of this proposed change.

ISTS Note 2 directs entering the applicable Required Actions of ISTS LCO 3.4.6, "RCS Loops - Mode 4", the corresponding ANO-2 LCO being 3.4.1.3, "Reactor Coolant System -

Shutdown," if a required shutdown cooling loop is made inoperable by the SWS. A similar note respective to ISTS Note 2 is also being incorporated into the ANO-2 TSs as part of this proposed change. The Notes are an exception to LCO 3.0.6 that ensures that proper actions are taken for the described condition.

d.

Required Actions D.1 and D.2 (one EDG and one offsite source inoperable) of ISTS LCO 3.8.1, "AC Sources - Operating," is modified by the following Note:

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems -

Operating," when Condition D is entered with no AC power source to any train.

A similar Note is proposed to be added to corresponding Action c of ANO-2 LCO 3.8.1.1, "A.C. Sources," to require entering the applicable Actions of ANO-2 LCO 3.8.2.1, "A.C.

Distribution - Operating," when Action c is entered with no AC power to any train. Pursuant to LCO 3.0.6 (SFDP), the Actions of LCO 3.8.2.1 would not be entered even if all AC sources to the distribution system were inoperable, resulting in de-energization of supported electrical buses. Therefore, Action c is modified by a Note to indicate that with no AC source to any train, the Actions for LCO 3.8.2.1 must be entered. This allows Action c to provide requirements for the loss of one offsite circuit and one EDG without regard to whether a train is de-energized, while LCO 3.8.2.1 provides the appropriate restrictions for a de-energized train.

2CAN112004 Enclosure Page 16 of 32

e.

Required Action A.1 (one offsite power circuit inoperable) of ISTS 3.8.2 "AC Sources -

Shutdown," is modified by the following Note:

Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

ISTS LCO 3.8.10 provides requirements for AC and DC electrical distribution subsystems.

The corresponding ANO-2 LCO is 3.8.1.2 "A.C. Power Sources - Shutdown." A similar Note is proposed to be added to the Action statement of ANO-2 LCO 3.8.1.2 to require entering the applicable Actions of LCO 3.8.2.2, "A.C. Distribution - Shutdown," and LCO 3.8.2.4, "D.C. Sources - Shutdown," with one required train de-energized as a result of an inoperable offsite power circuit. These ANO-2 LCOs correspond to ISTS 3.8.10.

The proposed note is an exception to LCO 3.0.6 by directing entry into both ANO-2 LCOs, if applicable, to ensure that the affected SDC system(s) are declared inoperable such that appropriate restoration actions are taken in response to the condition. The current ANO-2 TSs do not contain the necessary Actions in LCOs 3.8.2.2 and 3.8.2.4 to declare the affected SDC system(s) inoperable; however, changes to correct this condition are proposed in this amendment (discussed in Section 3.5 below).

f.

Required Action A.1 (one or more AC electrical power distribution subsystems inoperable) of ISTS LCO 3.8.9, "Distribution Systems - Operating," is modified by the following Note:

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for DC trains made inoperable by inoperable power distribution subsystems.

A similar Note is proposed to be added to the corresponding Action of LCO 3.8.2.1, "A.C.

Power Distribution - Operating," that directs entering the applicable Actions of LCO 3.8.2.3, "D.C. Sources - Operating," for DC trains made inoperable by inoperable power distribution subsystems. This is an exception to LCO 3.0.6 and ensures that proper actions are taken for these components. Inoperability of a distribution system can result in loss of charging power to station batteries and eventual loss of DC power. This note ensures that the appropriate attention is given to restoring charging power to batteries, if necessary, after loss of distribution subsystems.

3.5 Changes to LCO Actions and Surveillance Requirements Proposed LCO 3.0.6 requires entering the Actions of the LCOs for supported systems when directed by a support systems' Actions, and the ISTS Bases for LCO 3.0.6 discuss that there are instances where a support system's Action may either direct a supported system to be declared inoperable or direct entry into the Actions for the supported system. As a result, this proposed change adds Actions to direct entering the Actions of supported systems or other TS systems affected by the inoperable support system or component when application of the SFDP would be inappropriate based on actions that need to be initiated. The proposed Actions are consistent with those included in the ISTS that are applicable to ANO-2. Attachment 4 provides a table that identifies the Actions in the ISTS that direct entering the Actions of supported or affected systems and summarizes how the applicable Actions are addressed in this proposed change.

2CAN112004 Enclosure Page 17 of 32 The proposed Actions and the corresponding bases are discussed below.

a.

ISTS LCO 3.3.7A, "Diesel Generator (DG) - Loss of Voltage Start (LOVS) (Digital) (Without Setpoint Control Program)," contains actions requiring the associated EDG to be declared inoperable when both LOVS channels are inoperable or if the Required Actions are not met:

Enter applicable Conditions and Required Actions for the associated DG made inoperable by DG - LOVS instrumentation.

The ANO-2 TSs do not contain an equivalent ISTS LCO 3.3.7; however, undervoltage protection is required by ANO-2 LCO 3.3.2.1, "Engineered Safety Feature Actuation System Instrumentation," Table 3.3-3, Functional Units 7.a and 7.b, which require EDG start on loss of voltage (LOV) or degraded voltage (DV).

Two levels of undervoltage protection are provided for the ANO-2 on-site power system.

One level of protection consists of two LOV relays (channels) on each of the 4160 volt (V) safety buses that act to detect loss of voltage, isolate the safety buses, initiate load shedding, and start the associated EDG. Only one of the two relays on a given 4160 V safety bus must actuate to perform the aforementioned functions. An additional level of protection consists of two DV relays provided on each safety related 480 V load center.

The DV relays function to detect an undervoltage condition, isolate the associated safety related 4160 V bus from offsite power, and start and connect the associated EDG.

Although ANO-2 TS 3.3.2.1, Table 3.3-3, states that only one DV channel is required per load center, both DV relays are required to support the specified safety function since both relays are required to actuate to initiate the response described above. The table is in the process of being corrected (Reference 9). Note also that the ANO-2 design does not support bypassing an LOV or DV channel as accommodated in ISTS LCO 3.3.7A; therefore, the loss of any DV relay or the loss of both LOV relays on a respective safety bus should require declaring the associated EDG inoperable.

With any relay inoperable, ANO-2 TS 3.3.2.1, Table 3.3-3, refers to Action 9:

With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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 .

To address the need to declare the associated EDG inoperable a new Action 14 is proposed to be added to Table 3.3-3 (note that there are other Functional Units within Table 3.3-3 that refer to Action 9; therefore, this Action cannot be modified). Action 9 will remain applicable to the LOV relays since only one relay on a given safety bus is required to actuate in support of performing the specified safety functions. The new Action 14 will address cases where both LOV relays or any DV relay is inoperable on a respective safety bus. The existing Action 9 is repeated in the new Action 14 (part b below) with the addition of action to declare the associated EDG inoperable (part a below):

2CAN112004 Enclosure Page 18 of 32 With the number of 460 volt Degraded Voltage (Functional Unit 7.b) channels one less than the Total Number of Channels or with both 4.16 kv Loss of Voltage (Functional Unit 7.a) channels inoperable on a single bus:

a.

Immediately declare the affected EDG inoperable, and

b.

Restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

This action remains consistent with Action 9 while addressing adoption of the SFDP.

Action 14 takes appropriate measures to ensure the effects on the associated EDG are addressed and continues to ensure the condition is corrected in a timely manner.

b.

Action (b) of LCO 3.4.4, "Pressurizer," is deleted due the adoption of the ISTS definition of "operable" described previously:

(b) With the pressurizer inoperable due to an inoperable emergency power supply to the pressurizer heaters, either restore the inoperable emergency power supply in accordance with TS 3.8.1.1, Action b.3, for an inoperable Emergency Diesel Generator, or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Although the Pressurizer proportional heaters are not credited in the accident analyses, the heaters do serve an important function in maintaining Reactor Coolant System (RCS) pressure during loss of offsite power events that may require a natural circulation cooldown. Because the proportional heaters depend on the availability of emergency power to support a natural circulation cooldown (reference ANO-2 Safety Analysis Report Section 5.5.10.2), Action (b) of LCO 3.4.4 was added to the TSs previously (Reference 8) to align the proportional heater bank AOT with the LCO 3.8.1.1 AOT for a single inoperable EDG when the proportional heater bank is inoperable solely due to inoperability of its associated EDG. Given the adoption of the ISTS definition of "operable" and the adoption of the SFDP, Action (b) is no longer necessary since this new definition requires only a normal or emergency power source be operable for each TS-required component. Future inoperability of an EDG will not require cascading TSs and subsequent application of supported system LCOs such as entry into the Actions of LCO 3.4.4.

Actions (c) and (d) of LCO 3.4.4 are renumbered as Actions (b) and (c), respectively due the deletion of Action (b) above. This change is administrative only.

In support of this change, Surveillance Requirement (SR) 3.4.4.2.a is deleted and SR 3.4.4.2.b moved into the introductory statement of SR 3.4.4.2:

4.4.4.2 The pressurizer proportional heater groups shall be determined to be OPERABLE.

(a) In accordance with the Surveillance Frequency Control Program by verifying emergency power is available to the heater groups, and (b) iIn accordance with the Surveillance Frequency Control Program by verifying that the summed power consumption of the two proportional heater groups is 150 KW.

2CAN112004 Enclosure Page 19 of 32 All TS-required components must meet the TS definition of "operable"; therefore, it is not necessary to include an SR that verifies power availability. As discussed above, Action (b) of LCO 3.4.4 permits the emergency power supply to the affected proportional heater bank to be inoperable for a period consistent with the AOT of an inoperable EDG. With the deletion of Action (b), SR 4.4.4.2.a would not be met when an EDG became inoperable and LCO 3.4.4 Action (c) (current numbering) would have to be entered immediately, requiring the EDG to be restored to an operable status within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months (a combination of the 72-hour AOT of Action (c) and the 24-hour AOT of Action (d)) or the unit shutdown in accordance with current LCO 3.4.4 Action (d). Maintaining SR 4.4.4.2.a would effectively defeat the ability to apply the 14-day AOT of LCO 3.8.1.1 Action b.3 (current numbering). With the deletion of SR 4.4.4.2.a, the emergency power supply to the affected heater bank will be restored in conjunction with restoration of the associated EDG in accordance with LCO 3.8.1.1 Action b.3. This change is consistent with the current requirement contained in LCO 3.4.4 Action (b).

ISTS LCO 3.4.9, "Pressurizer," does not contain an equivalent SR but does contain a similar bracketed SR which requires physical verification that the respective emergency power supply is capable of supplying the proportional heater bank once every 18 months (reference ISTS SR 3.4.9.3), Entergy does not believe adoption of a like SR is necessary since the power supply breakers, bus work, and cabling between the 4160 V emergency switchgear and the proportional heater bank is no different than that used when the heaters are powered from offsite power during normal operation. When a loss of offsite power occurs, the offsite power source breaker to the 4160 V emergency switchgear opens and the EDG output breaker to the switchgear closes; no changes between the switchgear and the proportional heater bank occur. In addition, the ANO-2 Safety Analysis Report (SAR) assumes the heater banks may not be re-energized (requires manual manipulation for the Control Room Operator) until as late as 30 minutes following a loss of offsite power.

Because the EDG load calculations account for restoration of the heater bank and the restoration is delayed beyond the short time sequencing of large emergency loads, the adoption of the bracketed ISTS SR 3.4.9.3 is not necessary. Furthermore, the ISTS basis for SR 3.4.9.3 states:

This SR is not applicable if the heaters are permanently powered by 1E power supplies.

Both trains of the ANO-2 proportional heater groups are permanently powered by 1E power supplies and do not have the capability of being powered by non-1E power sources.

c.

The Actions of ISTS LCO 3.6.2, "Containment Air Locks (Atmospheric and Dual)," are modified by Note 3, which states:

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

As stated previously, ANO-2 has a separate TS that governs Containment leakage, namely LCO 3.6.1.2. ANO-2 LCO 3.6.1.3, "Containment Air Locks," Action c states, in part:

c.

With one or more air locks inoperable for reasons other than those addressed in ACTION a. or b.:

1.

Immediately initiate action to evaluate overall containment leakage per LCO 3.6.1.2.

2CAN112004 Enclosure Page 20 of 32 As such, no additional action is necessary for TS 3.6.1.3 in support of adopting a SFDP.

However, the current LCO 3.6.1.2 Action does not drive remedial action when in Modes 1, 2, 3, or 4 as it assumes the plant is in a lower mode. It is currently written as follows:

With containment leakage rates not within limits, restore containment leakage to within limits, prior to increasing the Reactor Coolant System temperature above 200°F.

This Action is proposed to be revised to be consistent with ISTS 3.6.1 and appropriately address Containment leakage that may be identified while operating in Modes 1, 2, 3, or 4:

With the containment leakage rate exceeding the acceptance criteria of the Containment Leakage Rate Testing Program, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , restore leakage to within limits or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Maintaining Containment leakage within limits ensures that the offsite dose consequences remain bounded by the assumptions of the safety analysis. The one-hour AOT provides a period of time to correct the problem commensurate with the importance of maintaining Containment during Modes 1, 2, 3, and 4. This time period also ensures that the probability of an accident (requiring Containment operability) occurring during periods when the Containment is inoperable is minimal.

d.

Required Actions A.2 (one inoperable offsite power source resulting in no offsite power source to a required feature), B.2 (one inoperable EDG), and C.1 (two inoperable offsite power sources) of ISTS LCO 3.8.1, "AC Sources - Operating," require declaring required feature(s) inoperable when its redundant required feature(s) is inoperable. As discussed in Section 3.2 above, the impact of inoperable power sources on required features is currently addressed in ANO-2 LCO 3.0.5, which is proposed for deletion. The deletion of LCO 3.0.5 subsequently requires Actions consistent with the ISTS to be added to the corresponding ANO-2 AC power source TS 3.8.1.1 to address these potential impacts. The following provides a discussion of each action to be added. Note that the bases for and acceptability of each AOT has been previously provided in Section 3.2 above.

1.

Current Action a.2 of LCO 3.8.1.1 is renumbered as Action a.3, and a new Action a.2 is proposed to address potential impacts of an inoperable offsite power source on required features. Renumbering Action a.2 as Action a.3 is necessary to keep the Actions in order of the time permitted to perform the action, from least to greatest.

This change maintains consistency with both the ANO-2 TS and ISTS formats and is administrative only. Proposed new Action a.2 is as follows:

a.

With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, perform the following:

2.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required features(s), declare required features(s) with no offsite power available inoperable when its redundant required features(s) is inoperable, and

2CAN112004 Enclosure Page 21 of 32 This Action addresses the condition where one of the two required offsite circuits is inoperable. The proposed change adds a requirement to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery if no offsite power to one train concurrent with inoperability of redundant required feature(s). The proposed Action applies when required feature of one train has no offsite power supply, and a required feature on the other train is inoperable. The AOT for this Action begins upon discovery that a required feature has no offsite power supply and a redundant required feature subsequently becomes inoperable.

New Action a.2 provides assurance that an event coincident with a single failure of the associated EDG will not result in a complete loss of safety function of critical redundant required features. These features are powered from the redundant AC electrical power train. The 24-hour AOT is intended to allow the operator time to evaluate and repair any discovered inoperabilities and considers the capacity and capability of the remaining AC sources and the low probability of a DBA occurring during this period.

2.

Current Actions b.2 and b.3 of LCO 3.8.1.1 are renumbered as Actions b.3 and b.4, respectively, and a new Action b.2 is proposed to address potential impacts of an inoperable EDG on required features. Renumbering Actions b.2 and b.3 is necessary to keep the Actions in order of the time permitted to perform the action, from least to greatest. This change maintains consistency with both the ANO-2 TS and ISTS formats and is administrative only. Proposed new Action b.2 is as follows:

b.

With one diesel generator of the above required A.C. electrical power source inoperable, perform the following:

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) is inoperable, and Action b.2 is intended to provide assurance that a loss of offsite power, during the period that an EDG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains.

The 4-hour AOT is intended to allow the operator time to evaluate and repair any discovered inoperabilities. Four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this condition, the remaining operable EDG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4-hour AOT considers the operability of the redundant counterpart to the inoperable required feature. Additionally, the 4-hour AOT considers the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The renumbering of current Action b.3 requires an update to Action e.3. Action e.3 refers to Note 1 of Action b.3 and, therefore, will be revised to refer to Note 1 of Action b.4. This change is administrative only in support of the renumbering described above.

2CAN112004 Enclosure Page 22 of 32

3.

Current Actions c.2, c.3, and c.4 of LCO 3.8.1.1 are renumbered as Actions c.3, c.4, and c.5, respectively, and a new Action c.2 is proposed to address potential impacts on required features when an offsite power source and an EDG are inoperable concurrently. Renumbering Actions c.2, c.3, and c.4 is necessary to keep the Actions in order of the time permitted to perform the action, from least to greatest. This change maintains consistency with both the ANO-2 TS and ISTS formats and is administrative only. Proposed new Action c.2 is as follows:

c.

With one offsite A.C. circuit and one diesel generator of the above required A.C. electrical power sources inoperable, perform the following:

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable if its redundant required feature(s) is inoperable, and Although Action c addresses concurrent inoperability of both an offsite power source and an EDG, only the 4-hour Action of an inoperable EDG (see new proposed Action b.2 above) is added since the 4-hour limit bounds that of the 24-hour AOT associated with new proposed Action a.2 (described above). The bases for this new Action have been previously presented above.

4.

Current Actions d.2 and d.3 of LCO 3.8.1.1 are renumbered as Actions d.3 and d.4, respectively, and a new Action d.2 is proposed to address potential impacts on required features during concurrent inoperability of both offsite power sources.

Renumbering Actions d.2 and d.3 is necessary to keep the Actions in order of the time permitted to perform the action, from least to greatest. This change maintains consistency with both the ANO-2 TS and ISTS formats and is administrative only.

Proposed new Action d.2 is as follows:

d.

With two offsite A.C. circuits of the above required A.C. electrical power sources inoperable, perform the following:

2.

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , declare required feature(s) inoperable when its redundant required feature(s) is inoperable, and This Action is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. These features are powered from redundant AC safety trains. The AOT begins upon discovery that both offsite circuits are inoperable, and a required feature is discovered inoperable.

With two offsite circuits inoperable, the AOT for inoperable redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed when only one offsite power source is inoperable. The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that RG 1.93 allows an AOT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are operable. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. The completion time is intended to allow the operator time to evaluate and repair any discovered inoperabilities.

2CAN112004 Enclosure Page 23 of 32

e.

Condition A of ISTS LCO 3.8.10, "Distribution Systems - Shutdown," addresses configurations when one or more AC and/or DC electrical power distribution subsystems are inoperable in Modes 5 and 6, and during movement of recently irradiated fuel assemblies.

Required Action A.1, states:

Declare associated supported required feature(s) inoperable.

Required Action A.2 states:

A.2.1 Suspend movement of [recently] irradiated fuel assemblies.

AND A.2.2 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.3 Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

AND A.2.4 Declare associated required shutdown cooling subsystem(s) inoperable and not in operation.

The ISTS provides an option of declaring associated support features inoperable (Required Action A.1) or suspending fuel movement and positive reactivity additions (Required Action A.2). The latter is currently captured in ANO-2 TS 3.8.2.2, "A.C. Distribution -

Shutdown," and TS 3.8.2.4, "DC Sources - Shutdown." However, ANO-2 TSs do not currently have corresponding Actions in LCO 3.8.2.2 and LCO 3.8.2.4 which initiate actions to restore the required buses electrical power to operable status and which declare the associated required SDC subsystem(s) inoperable as directed by Required Actions A.2.3 and A.2.4 in ISTS LCO 3.8.10.

As such, the single Action of ANO-2 LCO 3.8.2.2 is modified as Action a and an additional Action, Action b, is added as shown below (additions are underlined):

With less than the above complement of A.C. busses OPERABLE and energized, declare affected required features inoperable OR:

a.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and

b.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

2CAN112004 Enclosure Page 24 of 32 In addition, Action b of ANO-2 LCO 3.8.2.4 is modified to allow the option to declare affected required features inoperable, assigns sub-action b.i to address the current requirement to suspend core alterations, fuel movement, and positive reactivity additions, and adds verbiage similar to new Action b of LCO 3.8.2.2 above (additions are underlined):

b.

With the requirements of ACTION a not met or with the above complement of DC equipment and bus otherwise inoperable, declare affected required features inoperable OR:

i.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and ii.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

No specific Action is added regarding the SDC system as the added Action to declare affected required features inoperable in both LCO 3.8.2.2 and LCO 3.8.2.4 envelops this requirement.

3.6 ISTS Support System LCOs that Direct Entry into Supported System Actions that are not applicable to the ANO-2 TSs

a.

ISTS 3.3.8A "Containment Purge Isolation Signal (CPIS) (Digital) (Without Setpoint Control Program)," Required Action A.1 states:

Enter applicable Conditions and Required Actions for affected valves of LCO 3.6.3, "Containment Isolation Valves," made inoperable by CPIS instrumentation.

The above specification is applicable in Modes 1, 2, 3, 4, and during movement of [recently]

irradiated fuel assemblies within the Containment Building. ANO-2 does not have an equivalent LCO 3.3.8A. ANO-2 TS 3.6.1.6, "Containment Ventilation System," requires the Containment Purge valves to be closed with the keys removed from the handswitch in Modes 1, 2, 3, and 4. The containment purge supply and exhaust isolation valves are required to be closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA. Maintaining these valves closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the containment purge system; therefore, entry into ANO-2 TS 3.6.3.1, "Containment Isolation Valves," would be inappropriate as this TS is applicable in Modes 1, 2, 3, and 4 only. Thus, an Action similar to ISTS 3.3.8A, Required Action A.1, is not required to support adopting a SFDP.

b.

ISTS 3.6.2 "Containment Air Locks (Atmospheric and Dual)," Actions Note 3 states:

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

As mentioned previously in Section 3.5.b above, ANO-2 has a separate TS that governs Containment leakage, LCO 3.6.1.2. ANO-2 LCO 3.6.1.3, "Containment Air Locks,"

currently requires entry into LCO 3.6.1.2 if leakage limits are exceeded; therefore, no additional action is necessary for LCO 3.6.1.3 in support of adopting a SFDP.

2CAN112004 Enclosure Page 25 of 32

c.

A Note associated with ISTS 3.7.7, "Component Cooling Water (CCW) System," Required Action A.1, states:

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for shutdown cooling made inoperable by CCW.

The ANO-2 CCW system is not a TS-required system. At ANO-2, SDC and other TS required systems are cooled via the SWS, and CCW provides cooling water to remove heat from components in various reactor auxiliary systems which carry radioactive or potentially radioactive fluids. Therefore, no changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

d.

ISTS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," Required Action F.1, states:

Declare associated DG inoperable.

ANO-2 has a corresponding LCO 3.8.1.3, "Electrical Power Systems," for EDG support systems which is applicable when the associated EDG is required to be operable. ANO-2 LCO 3.8.1.3, Action 4, currently requires declaring the associated EDG inoperable when the AOTs of specified requirements for fuel oil inventory, particulates, and oil properties are not met; therefore, no changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

Note that ANO-2 does not have an LCO for EDG lube oil inventory or starting air; however, station procedures contain specific operability limits for EDG lube oil sump level and starting air capacity within the EDG surveillance tests that are required to be met in order to maintain operability.

e.

ISTS 3.8.6, "Battery Parameters," Required Action F.1, states:

Declare associated battery inoperable.

ANO-2 has a corresponding Action f of LCO 3.8.3, " Battery Parameters." The Actions and AOTs for the ANO-2 TS are essentially the same as the Required Actions and Completion Times for the ISTS; therefore, no changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

f.

A Note associated with ISTS 3.8.7, "Inverters - Operating," Required Action A.1, states:

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems -

Operating," with any vital bus de-energized.

The ANO-2 inverters are not TS-required components. Therefore, no changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

2CAN112004 Enclosure Page 26 of 32

g.

ISTS 3.8.8, "Inverters - Shutdown," Required Action A.1, states:

Declare affected required feature(s) inoperable.

There are no Mode 5 or Mode 6 requirements for the ANO-2 inverters in the ANO-2 TSs; therefore, no changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

The respective TS Bases associated with the proposed TS changes are revised consistent with the corresponding TS Bases of the ISTS. Wording is modified as needed to address differences between the ISTS and the ANO-2 old-standard TSs and usage rules. In addition, the ANO-2 TS Bases do not contain the detail of the ISTS Bases; therefore, the following ANO-2 TS Bases are not updated.

TS 3.4.6.2, Reactor Coolant System Operational Leakage TS 3.6.1.2, Containment Leakage TS 3.8.1.2, A.C. Sources - Shutdown TS 3.8.2.1, A.C. Distribution - Operating TS 3.8.2.2, A.C. Distribution - Shutdown A markup of affected ANO-2 TS Bases pages is included in Attachment 2 of this enclosure, for information only. The TS Bases are updated in conjunction with implementation of this amendment request, once approved, in accordance with ANO-2 TS 6.5.14, "Technical Specifications (TS) Bases Control Program."

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Criteria NUREG-0800, Standard Review Plan - discusses in Section 16, "Technical Specifications," that plants with TS based on the previous standard TS and plants with custom TS may partially adopt ISTS provisions without adopting the ISTS format. TS change requests for facilities with TS based on previous standard TS should comply with comparable provisions in the ISTS to the extent possible or justify deviations from the ISTS.

10 CFR 50.36, "Technical Specifications," establishes the requirements for information that must be included in the TS.

The proposed change is consistent with the above requirements.

4.2 Precedents The proposed changes are consistent with NUREG-1432, Revision 4.0, "Standard Technical Specifications Combustion Engineering Plants" (Reference 3), as demonstrated in Section 3 above.

2CAN112004 Enclosure Page 27 of 32 In September 2015, Limerick Generating Station (LGS) received Amendments 219 and 181 (Reference 5), which among other changes, added LCO 3.0.6 and the SFDP to the TSs. The NRC approved the addition of LCO 3.0.6 to the TS (non-ISTS) on the basis that it would eliminate potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO conditions and required actions by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's required actions.

LGS Units 1 and 2 are General Electric Boiling Water Reactors (BWRs) with non-ITS versions of TSs. Amendments 219 and 181 adopted the SFDP from NUREG-1433, Revision 4.0, "Standard Technical Specifications General Electric BWR/4 Plants" (Reference 4). The verbiage and application of the SFDP between NUREG 1433 and NUREG 1432 is essentially identical; however, in LGS's TS amendments, the only LCOs that were modified were administrative. No system LCOs were modified as was the case in the Florida Power and Light (FP&L) submission (below) or this proposed amendment.

In July 2019, Seabrook Station Unit No. 1 received Amendment 161, St. Lucie Plant Unit Nos. 1 and 2 received Amendments 249 and 200, and Turkey Point Nuclear Generating Unit Nos. 3 and 4 received Amendments 287 and 281 (Reference 6) which among other changes, added LCO 3.0.6 and the SFDP to the TSs. The NRC approved the addition of LCO 3.0.6 to the TSs (non-ISTS) on the basis that it would eliminate the potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' actions to ensure the plant is maintained in a safe condition in the support system's required actions.

Seabrook Station Unit No. 1 and Turkey Point Nuclear Generating Unit Nos. 3 and 4 are Westinghouse reactors with non-ITS versions of TSs. Seabrook TS Amendment 161 and Turkey Point Unit Nos. 3 and 4 TS Amendments 287 and 281 adopted the SFDP from NUREG-1431, Revision 4.0, "Standard Technical Specifications Westinghouse Plants" (Reference 2). The verbiage and application of the SFDP between NUREG 1431 and NUREG 1432 are virtually identical; however, for the purposes of this application, Entergy has chosen to focus on the portion of the FP&L submission pertaining to St. Lucie Unit Nos. 1 and 2, since both of these units are Combustion Engineering units and are the most similar in design to ANO-2.

ANO-2's implementation of the SFDP is largely the same as that of FP&L for St. Lucie Unit Nos. 1 and 2. The following are the major differences between the ANO-2 and St. Lucie implementations:

ANO-2 adopted the ISTS definition of "operable" and deleted a previously existing LCO (LCO 3.0.5) that St. Lucie Units 1 and 2 did not have. This LCO concerned operability of an SSC based on operability of its remaining normal or emergency power supply and was rendered unnecessary due to implementation of the SFDP and by modification of ANO-2 TS 3.8.1.1 under this application. The St. Lucie definition of "operable" did not state specific requirements for normal and/or emergency power. Refer to Section 3.2.

ANO-2 applied ISTS 3.3.7, "Diesel Generator (DG) - Loss of Voltage Start (LOVS)

(Digital) (With Setpoint Control Program)," to ANO-2 ESFAS Functional Units 7.a and 7.b, Loss of Power EDG start relays of LCO 3.3.2.1. Although St. Lucie Units 1 and 2 have a corresponding LCO, FP&L elected not to apply the ISTS Actions since there is not a stand-alone LCO in the original Combustion Engineering TSs that addresses EDG undervoltage start relays. Refer to Section 3.5.a above.

2CAN112004 Enclosure Page 28 of 32 ANO-2 reformatted LCO 3.8.1.1, "A.C. Sources" (Operating), in order to provide greater consistency with the ISTS while maintaining the same written format as the current TS.

This also required the addition of several new sub-Actions and Action Notes that were necessary in order to delete the current LCO 3.0.5 and support the addition of the SFDP.

St. Lucie Unit 1 and 2's LCO 3.8.1.1 did not require as extensive editing to implement the SFDP. FP&L also reformatted the St. Lucie Unit 1 and 2 LCO 3.8.1.1 from a narrative paragraph format to a list of discrete steps; however, the substantive changes were limited to the following (Reference 6):

(a)

Action a.2: Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s), declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

(b)

Note c: Enter applicable ACTIONs of LCO 3.8.2.1, "A.C. Distribution - Operating,"

when ACTION c is entered with no AC power to any train.

(c)

Action d.1: Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of two offsite circuits inoperable concurrent with inoperability of redundant required feature(s), declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

4.3 No Significant Hazards Consideration The proposed amendments modify the Technical Specifications (TS) for Arkansas Nuclear One, Unit 2 (ANO-2) to incorporate the provisions of Limiting Condition for Operation (LCO) 3.0.6 of the Improved Standard Technical Specifications (ISTS), which provide the actions to be taken when the inoperability of a support system results in the inoperability of related supported systems. In addition, the proposed change adds a new Safety Function Determination Program (SFDP) to the administrative section of the TS to ensure that a loss of safety function is detected, and appropriate actions are taken when using the provisions of LCO 3.0.6.

In addition, LCO 3.0.5 is deleted and replaced with changes to ANO-2 LCO 3.8.1.1, "A.C.

Sources," to gain consistency with the ISTS with respect to potential operability impacts when a required power source(s) is inoperable. This change, in turn, permits the adoption of the ISTS version of the definition of "operable," which subsequently supports deletion of an Action and Surveillance Requirement (SR) in LCO 3.4.4, "Pressurizer," associated with emergency power availability to the Pressurizer proportional heater banks. Finally, the Action associated with LCO 3.6.1.2, "Containment Leakage," is modified to provide appropriate remedial actions during operations in Modes 1, 2, 3, and 4, consistent with the ISTS.

Entergy evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

2CAN112004 Enclosure Page 29 of 32

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The changes are associated with the administrative requirements for implementing the TSs which are not initiators of any accidents previously evaluated; therefore, the probability of accidents previously evaluated is unaffected by the proposed change. The proposed changes do not alter the design, function, or operation of any plant structure, system, or component (SSC). The capability of any operable TS-required SSC to perform its specified safety function is not impacted by the proposed change. As a result, the outcomes of accidents previously evaluated are unaffected.

Therefore, the proposed changes do not result in a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not challenge the integrity or performance of any safety-related systems. No plant equipment is installed or removed, and the changes do not alter the design, physical configuration, or method of operation of any plant SSC. No physical changes are made to the plant, so no new causal mechanisms are introduced.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The ability of any operable SSC to perform its designated safety function is unaffected by the proposed changes. The proposed changes do not alter any safety analyses assumptions, safety limits, limiting safety system settings, or method of plant operation.

The changes do not adversely affect plant operating margins or the reliability of equipment credited in the safety analyses.

The proposed change to adopt a SFDP allows not entering the ACTIONs for supported systems that are inoperable solely due to a support system LCO not being met. However, the change also requires implementing a SFDP to determine if a loss of safety function exists. If the SFDP determines that a loss of safety function exists, the appropriate actions of the LCO in which the loss of safety function exists are required to be entered.

Likewise, the deletion of LCO 3.0.5 in conjunction with the modified LCO 3.8.1.1 Actions better ensures that cross-train functional checks are performed and the potential for a loss of safety function is appropriately assessed. While the time permitted to complete the cross-train functional checks is increased in some cases, this is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with a plant shutdown. The remaining operable power sources are adequate to

2CAN112004 Enclosure Page 30 of 32 supply electrical power to the onsite Class 1E Distribution System. The allowable outage times take into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a design basis accident (DBA) occurring during this period. The changes are also consistent with the ISTS.

The above changes associated with LCO 3.0.5, LCO 3.8.1.1, and the adoption of the SFDP support the adoption of the ISTS version of the definition of operability. The current ANO-2 TS definition requires both normal and emergency power to be available in support of TS operability of a given structure, system, or component (SSC). The ISTS version requires either normal or emergency power to be available in support of SSC operability. The ISTS version of "operable" supports the aforementioned changes and does not impact any safety analyses assumptions or method of plant operation. While this change is considered less restrictive, the margin to safety to not significantly impacted based on the controls established by the changes to LCO 3.8.1.1 and adoption of the SFDP.

The Action of LCO 3.4.4 being deleted is associated with restoring an emergency power supply to an affected proportional heater bank consistent with the time allotted to restore the emergency power supply contained in LCO 3.8.1.1. The SR of LCO 3.4.4 being deleted is associated with verification of the availability of emergency power to a respective proportional heater bank. Given the changes to LCO 3.8.1.1 and the adoption of the ISTS definition of "operable", this Action and SR are considered redundant to existing controls and are no longer necessary to ensure heater banks are maintained consistent with current TS requirements; subsequently, this change does not impact the margin to safety.

The Action associated with TS 3.6.1.2 currently does not provide direction should Containment leakage rates be exceeded during operation in Modes 1, 2, 3, or 4. This Action is modified to provide appropriate remedial actions during operations in Modes 1, 2, 3, and 4, consistent with the ISTS, by requiring leakage rates to be restored within one hour or the unit is shutdown. This revised Action is more restrictive and provides direction commensurate with nuclear and public safety objectives.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safe ty of the general public.

2CAN112004 Enclosure Page 31 of 32 5.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

1.

NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Rev. 2, Fall 1980.

2.

NUREG-1431, "Standard Technical Specifications - Westinghouse Plants: Specifications,"

Rev. 4.0, Vol. 1, (ML12100A222), dated April 2012.

3.

NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants:

Specifications," Rev. 4.0, Vol. 1, (ML12102A165), dated April 2012.

4.

NUREG-1433, "Standard Technical Specifications - General Electric BWR/4 Plants:

Specifications," Rev. 4.0, Vol. 1, (ML12104A192), dated April 2012.

5.

U.S. Nuclear Regulatory Commission (NRC) letter to Exelon Nuclear, "Limerick Generating Station, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 219 and 181 Re: Proposed Change to Add New Limiting Conditions for Operation 3.0.5 and 3.0.6 (TAC Nos. MF5133 and MF5134)," (ML15218A501), dated September 15, 2015.

6.

NRC letter to Florida Power & Light Company and NextEra Energy Seabrook, LLC, "Seabrook Station, Unit No. 1; St. Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of Amendment Nos. 161, 249, 200, 287, and 281 to Add Technical Specification Limiting Condition for Operation 4.0.6 (EPID L-2018-LLA-0152)," (ML19148A744), dated July 31, 2019.

7.

NRC letter to Entergy Operations, Inc. (Entergy), "Arkansas Nuclear One, Unit No. 1 -

Issuance of Amendment RE: The Conversion to Improved Technical Specifications (TAC No. MA8082)," (1CNA100102) (ML013050554), dated October 29, 2001.

8.

NRC letter to Entergy, "Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment RE:

One-Time Allowed Outage Time Extension for the Emergency Diesel Generator (TAC No. MB2226)," (2CNA100101) (ML012880265), dated October 15, 2001.

9.

Entergy letter to NRC, "License Amendment Request: Revise Loss of Voltage Relay Allowable Values and Number of Degraded Voltage Channels," (2CAN082001)

(ML20238C004), dated August 24, 2020.

2CAN112004 Enclosure Page 32 of 32 7.0 ATTACHMENTS

1.

Technical Specification Page Markups

2.

Technical Specification Bases Page Markups (for Information Only)

3.

Retyped Technical Specification Pages

4.

Table of Support System Actions that Direct Entering Actions of Supported Systems

Enclosure, Attachment 1 2CAN112004 Technical Specification Page Markups (21 Pages)

ARKANSAS - UNIT 2 1-1 Amendment No. 91,157,244, DEFINITIONS DEFINED TERMS 1.1 The DEFINED TERMS of this section appear in capitalized type and are applicable, throughout these Technical Specifications.

THERMAL POWER 1.2 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

RATED THERMAL POWER 1.3 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 3026 MWt.

OPERATIONAL MODE - MODE 1.4 An OPERATIONAL MODE (i.e. MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

ACTION 1.5 ACTION shall be those additional requirements specified as corollary statements to each principle specification and shall be part of the specifications.

OPERABLE - OPERABILITY 1.6 A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when. Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal orand emergency electrical power sources, cooling andor seal water, lubrication, andor other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

REPORTABLE OCCURRENCE 1.7 A REPORTABLE OCCURRENCE shall be any of those conditions specified in Section 50.73 to 10CFR Part 50.

ARKANSAS - UNIT 2 3/4 0-1 Amendment No. 19,134,207,281, 283,309,316, 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation (LCO) and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification, except as provided in LCO 3.0.2, LCO 3.0.8, and LCO 3.0.9.

3.0.2 Adherence to the requirements of the Limiting Condition for Operation and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in SpecificationLCO 3.0.5 and LCO 3.0.6. In the event the Limiting Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.

3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , action shall be initiated to place the unit in a mode in which the specification does not apply by placing it, as applicable, in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless corrective measures are completed that permit operation under the permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor is placed in a MODE in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specification.

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

a.

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

b.

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

c.

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

This specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONs or that are part of a shutdown of the unit.

ARKANSAS - UNIT 2 3/4 0-1a Amendment No. 281,283,309, 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY (continued)

LIMITING CONDITION FOR OPERATION 3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided:

(1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s), subsystem(s), train(s), component(s), and device(s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it, as applicable, in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This specification is not applicable in MODES 5 or 6.

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

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

Only the support system LCO ACTIONs are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.5.19, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

3.0.7 To be used later.

3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a.

the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b.

the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

ARKANSAS - UNIT 2 3/4 0-1a Amendment No. 281,283,309, At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

ARKANSAS - UNIT 2 3/4 3-13 Amendment No. 134,159,186,289, TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION

7.

LOSS OF POWER

a.

4.16 kv Emergency Bus Undervoltage (Loss of Voltage) 2/Bus 1/Bus 2/Bus 1,2,3 9,14

b.

460 volt Emergency Bus Undervoltage (Degraded Voltage) 1/Bus 1/Bus 1/Bus 1,2,3 914

8.

EMERGENCY FEEDWATER (EFAS)

a.

Manual (Trip Switches) 2 sets of 2 per S/G 2 sets of 2 per S/G 2 sets of 2 per S/G 1,2,3 9

b.

SG Level and Pressure (A/B) -

Low and P (A/B) - High 4/SG 2/SG 3/SG 1,2,3 10,11

c.

SG Level (A/B) - Low and No S/G Pressure - Low Trip (A/B) 4/SG 2/SG 3/SG 1,2,3 10,11

d.

ESFAS Logic

1.

Matrix Logic 6

1 3

1,2,3 12

2.

Initiation Logic 4

2 4

1,2,3 9

e.

Automatic Actuation Logic 2

1 2

1,2,3 13

ARKANSAS - UNIT 2 3/4 3-15a Amendment No. 301, TABLE 3.3-3 (Continued)

TABLE NOTATION ACTION 12 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

ACTION 13 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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 ; however, one channel may be bypassed for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing provided the other channel is OPERABLE. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

ACTION 14 - With the number of 460 volt Degraded Voltage (Functional Unit 7.b) channels one less than the Total Number of Channels or with both 4.16 kv Loss of Voltage (Functional Unit 7.a) channels inoperable on a single bus:

a.

Immediately declare the affected EDG inoperable, and

b.

Restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

ARKANSAS - UNIT 2 3/4 4-5 Amendment No. 20,234,304,315, REACTOR COOLANT SYSTEM PRESSURIZER LIMITING CONDITION FOR OPERATION 3.4.4 The pressurizer shall be OPERABLE with a water volume of 910 cubic feet (equivalent to 82% of wide range indicated level) and both pressurizer proportional heater groups shall be OPERABLE.

APPLICABILITY:

MODES 1, 2 and 3.

ACTION:

(a)

With the pressurizer inoperable due to water volume 910 cubic feet, be in at least HOT SHUTDOWN with the reactor trip breakers open within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(b)

With the pressurizer inoperable due to an inoperable emergency power supply to the pressurizer heaters, either restore the inoperable emergency power supply in accordance with TS 3.8.1.1, Action b.3, for an inoperable Emergency Diesel Generator, or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(bc) With the pressurizer inoperable due to a single proportional heater group having less than a 150 KW capacity, restore the inoperable proportional heater group to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(cd) With the pressurizer inoperable due to both proportional heater groups being inoperable for any reason (Note 1), restore at least one proportional heater group to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4.4.4.1 The pressurizer water volume shall be determined to be within its limits in accordance with the Surveillance Frequency Control Program.

4.4.4.2 The pressurizer proportional heater groups shall be determined to be OPERABLE.

(a)

In accordance with the Surveillance Frequency Control Program by verifying emergency power is available to the heater groups, and (b) iIn accordance with the Surveillance Frequency Control Program by verifying that the summed power consumption of the two proportional heater groups is 150 KW.

Note 1: Action (d) is not applicable when the second group of required pressurizer heaters is intentionally made inoperable.

ARKANSAS - UNIT 2 3/4 4-14 Amendment No. 184,266,280, Order dated 4/20/81 REACTOR COOLANT SYSTEM REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE LIMITING CONDITION FOR OPERATION 3.4.6.2 Reactor Coolant System operational leakage shall be limited to:

a.

No PRESSURE BOUNDARY LEAKAGE,

b.

1 GPM UNIDENTIFIED LEAKAGE,

c.

150 gallons per day primary to secondary leakage through any one steam generator (SG),

d.

10 GPM IDENTIFIED LEAKAGE from the Reactor Coolant System, and

e.

Leakage as specified in Table 3.4.6-1 for those Reactor Coolant System Pressure Isolation Valves identified in Table 3.4.6-1.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With any PRESSURE BOUNDARY LEAKAGE or any primary to secondary leakage not within limit, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

With any Reactor Coolant System operational leakage greater than any one of the above limits, excluding PRESSURE BOUNDARY LEAKAGE and primary to secondary leakage, reduce the leakage rate to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c.

With any Reactor Coolant System Pressure Isolation Valve leakage greater than the above limit, isolate (Note 1) the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least two valves* in each high pressure line having a non-functional valve and 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Note 1:

Enter applicable ACTION(s) for system(s) made inoperable by an inoperable pressure isolation valve.

These valves may include check valves for which the leakage rate has been verified, manual valves or automatic valves. Manual and automatic valves shall be tagged as closed to preclude inadvertent valve opening.

ARKANSAS - UNIT 2 3/4 6-2 Amendment No. 176, CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be in accordance with the Containment Leakage Rate Testing Program.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

With the containment leakage rate exceeding the acceptance criteria of the Containment Leakage Rate Testing Program, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , restore leakage to within limits or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .With containment leakage rates not within limits, restore containment leakage to within limits, prior to increasing the Reactor Coolant System temperature above 200 °F.

SURVEILLANCE REQUIREMENTS 4.6.1.2 The containment leakage rates shall be determined in accordance with the Containment Leakage Rate Testing Program.

ARKANSAS - UNIT 2 3/4 6-16 Amendment No. 121,134,154,255,

301, CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3.1 Each containment isolation valve shall be OPERABLE.*

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Note: Enter applicable ACTION(s) for system(s) made inoperable by containment isolation valves.

With one or more isolation valve(s) inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and either:

a.

Restore the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or

b.

Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one deactivated automatic valve secured in the isolation position, or

c.

Isolate the affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one closed manual valve or blind flange; or

d.

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.

SURVEILLANCE REQUIREMENTS 4.6.3.1.1 Each containment isolation valve shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test and verification of isolation time.

Locked or sealed closed valves may be opened on an intermittent basis under administrative control.

ARKANSAS - UNIT 2 3/4 7-15 Amendment No. 301,315, PLANT SYSTEMS 3/4.7.3 SERVICE WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3.1 At least two independent service water loops shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Notes:

1.

Enter applicable ACTION(s) of LCO 3.8.1.1, "AC Sources - Operating," for EDG made inoperable by service water system.

2.

Enter applicable ACTION(s) of LCO 3.4.1.3, "Reactor Coolant System - Shutdown," if a required shutdown cooling loop is made inoperable by service water system.

With only one service water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 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.

SURVEILLANCE REQUIREMENTS 4.7.3.1 At least two service water loops shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program during shutdown, by verifying that each automatic valve servicing safety related equipment actuates to its correct position on CCAS, MSIS and RAS test signals.

ARKANSAS - UNIT 2 3/4 8-1 Amendment No. 141,215,234,249,255, 281,301, 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system and

b.

Two separate and independent diesel generators each with:

1.

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

2.

A separate fuel storage system, and

3.

A separate fuel transfer pump.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

NOTE: Specification 3.0.4.b is not applicable to diesel generators.

a.

With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, perform the following:

1.

Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required features(s), declare required features(s) with no offsite power available inoperable when its redundant required features(s) is inoperable, and

32. Restore the offsite A.C. circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 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. Startup Transformer No. 2 may be removed from service for up to 30 days as part of a preplanned preventative maintenance schedule. The 30-day allowance may be applied not more than once in a 10-year period.

ARKANSAS - UNIT 2 3/4 8-1a Amendment No. 249,301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

b.

With one diesel generator of the above required A.C. electrical power source inoperable, perform the following:

1.

Demonstrate the OPERABILITY of both the offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) is inoperable, and

32. Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by:

i.

Determining the OPERABLE diesel generator is not inoperable due to a common cause failure, or ii.

Perform Surveillance Requirement 4.8.1.1.2.a.4 unless:

a.

The remaining diesel generator is currently in operation, or

b.

The remaining diesel generator has been demonstrated OPERABLE within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

43. Restore the diesel generator to OPERABLE status within 14 days (See Note 1) or 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 - If the Alternate A.C. Diesel Generator (AACDG) is determined to be inoperable during this period, then a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration period is applicable until either the AACDG or the diesel generator is returned to operable status (not to exceed 14 days from the initial diesel generator inoperability).

ARKANSAS - UNIT 2 3/4 8-2 Amendment No. 141,234,249,255,

301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

c.

With one offsite A.C. circuit and one diesel generator of the above required A.C. electrical power sources inoperable (see Note 2), perform the following:

1.

Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and,

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable if its redundant required feature(s) is inoperable, and

32. If the diesel generator became inoperable due to any cause other than preplanned preventative maintenance or testing, then

i.

Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , except when:

a.

The remaining diesel generator is currently in operation, or

b.

The remaining diesel generator has been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

43. Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and

54. Restore the remaining inoperable A.C. Source to an OPERABLE status (Offsite A.C.

Circuit within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or Diesel Generator within 14 days (see b.43, Note 1)) based on the time of the initiating event that caused the inoperability.

Otherwise, 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 2 - Enter applicable ACTIONs of LCO 3.8.2.1, "A.C. Distribution - Operating," when ACTION c is entered with no AC power to any train.

d.

With two offsite A.C. circuits of the above required A.C. electrical power sources inoperable, perform the following:

1.

Perform Surveillance Requirement 4.8.1.1.2.a.4 on the diesel generators within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months except when:

i.

The diesel generators are currently in operation, or ii.

The diesel generators have been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and Moved to next page

ARKANSAS - UNIT 2 3/4 8-2 Amendment No. 141,234,249,255,

301,

2.

Restore one of the inoperable offsite A.C. circuits to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

3.

Restore both A.C. circuits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the initiating event, Otherwise, 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.

Moved to next page

ARKANSAS - UNIT 2 3/4 8-2a Amendment No. 141,234,249,255,

301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

d.

With two offsite A.C. circuits of the above required A.C. electrical power sources inoperable, perform the following:

1.

Perform Surveillance Requirement 4.8.1.1.2.a.4 on the diesel generators within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months except when:

i.

The diesel generators are currently in operation, or ii.

The diesel generators have been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

2.

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , declare required feature(s) inoperable when its redundant required feature(s) is inoperable, and

32. Restore one of the inoperable offsite A.C. circuits to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

43. Restore both A.C. circuits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the initiating event, Otherwise, 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.

e.

With two diesel generators of the above required A.C. electrical power sources inoperable, perform the following:

1.

Demonstrate the OPERABILITY of the two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and

3.

Restore the remaining inoperable diesel generator within 14 days (see b.43, Note 1) of the initiating event.

Otherwise, 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.

Moved from last page and modified

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

ACTION:

Note: Enter applicable ACTIONs of LCO 3.8.2.2, "A.C. Distribution - Shutdown," and LCO 3.8.2.4, "D.C. Sources - Shutdown," with one required train de-energizedas a result of Condition a.

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

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 8-6 Amendment No. 315, ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 The following A.C. electrical busses shall be OPERABLE and energized with tie breakers open between redundant busses:

4160 volt Emergency Bus # 2A3 4160 volt Emergency Bus # 2A4 480 volt Emergency Bus # 2B5 480 volt Emergency Bus # 2B6 120 volt A.C. Vital Bus # 2RS1 120 volt A.C. Vital Bus # 2RS2 120 volt A.C. Vital Bus # 2RS3 120 volt A.C. Vital Bus # 2RS4 APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Note: Enter applicable ACTIONs of LCO 3.8.2.3, "DC Sources - Operating" for DC train(s) made inoperable by inoperable power distribution subsystems.

With less than the above complement of A.C. busses OPERABLE, restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.2.1 The specified A.C. busses shall be determined OPERABLE with tie breakers open between redundant busses 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, 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 ACTION:

With less than the above complement of A.C. busses OPERABLE and energized, declare affected required features inoperable OR:

a.

Iimmediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and.

b.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

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 8-10 Amendment No. 94,227,297,315, 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.

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, declare affected required features inoperable OR:

i.

iImmediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and ii. Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

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 6-18b Amendment No.

ADMINISTRATIVE CONTROLS 6.5.19 Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs.

This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:

a.

Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected,

b.

Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists,

c.

Provisions to ensure that an inoperable supported system's allowed outage time is not inappropriately extended as a result of multiple support system inoperabilities, and

d.

Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a.

A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

b.

A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or

c.

A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate ACTIONs to enter are those of the support system.

Enclosure, Attachment 2 2CAN112004 Technical Specification Bases Page Markups (for Information Only)

(16 Pages)

ARKANSAS - UNIT 2 B 3/4 0-6 Amendment No. 134,207 Rev. 33,48,74, LCO APPLICABILITY BASES LCO 3.0.4 (continued)

The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

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

The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result in any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

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

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by Surveillance Requirement (SR) 4.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 4.0.1 or SR 4.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 delineates what additional conditions must be satisfied to permit operation to continue, consistent with the ACTIONS for power sources, when a normal or emergency power source is inoperable. It specifically prohibits operation when one train is inoperable because its normal or emergency power source is inoperable and a system, subsystem, train, component or device in another train is inoperable for another reason.

The provisions of this specification permit the ACTIONS associated with individual systems, subsystems, trains, components, or devices to be consistent with the ACTIONS of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION associated with the LCO for the normal or emergency power source, not the individual ACTIONS for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source.

ARKANSAS - UNIT 2 B 3/4 0-7 Amendment No. 103,134,207,233,246 Rev. 33,36,48,74, LCO APPLICABILITY BASES LCO 3.0.5 (continued)

For example, LCO 3.8.1.1 requires, in part, two Emergency Diesel Generators (EDGs) be OPERABLE. The ACTION provides an AOT when one EDG is inoperable. If the definition of OPERABLE were applied without consideration of LCO 3.0.5, all systems, subsystems, trains, components, and devices supplied by the inoperable emergency power source would also be inoperable. This would dictate invoking the applicable ACTION statements for each of the applicable LCOs. However, the provisions of LCO 3.0.5 permit the time limits for continued operation to be consistent with the ACTIONS for the inoperable EDG instead, provided the other specified conditions are satisfied.

In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems, subsystems, trains, components, and devices must be OPERABLE, or otherwise satisfy LCO 3.0.5 (i.e., be capable of performing their design function and have at least one normal or one emergency power source OPERABLE). If they are not satisfied, action is required in accordance with this Specification.

As a further example, LCO 3.8.1.1 requires, in part, two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system to be OPERABLE. The ACTION provides a 24-hour AOT when both required offsite circuits are inoperable. If the definition of OPERABLE were applied without consideration of LCO 3.0.5, all systems, subsystems, trains, components and devices supplied by the inoperable normal power sources, both of the offsite circuits, would also be inoperable. This would dictate invoking the applicable ACTIONS for each of the applicable LCOs. However, the provisions of LCO 3.0.5 permit the time limits for continued operation to be consistent with the ACTION for the inoperable normal power sources instead, provided the other specified conditions are satisfied. In this case, this would mean that for one train the emergency power source must be OPERABLE (as need be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in the other train must be OPERABLE, or likewise satisfy LCO 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both trains must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this Specification.

In MODES 5 OR 6, LCO 3.0.5 is not applicable, and thus the individual ACTIONS for each applicable LCO in these MODES must be adhered to.

ARKANSAS - UNIT 2 B 3/4 0-8 Amendment No. 246 Rev. 33,36,38,48,74, LCO APPLICABILITY BASES LCO 3.0.56 LCO 3.0.56 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable ACTIONS) to allow the performance of required testing to demonstrate either:

a.

The OPERABILITY of the equipment being returned to service; or

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance. LCO 3.0.56 should not be used in lieu of other practicable alternatives that comply with ACTIONS and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE. LCO 3.0.56 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the ACTIONS not met is opening a manual valve that was closed to comply with ACTIONS to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by an ACTION, if there is no ACTION Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel.

Examples of demonstrating the OPERABILITY of other equipment are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system, or 2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

The administrative controls in LCO 3.0.56 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the ACTIONS. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

ARKANSAS - UNIT 2 B 3/4 0-8 Amendment No. 246 Rev. 33,36,38,48,74, LCO APPLICABILITY BASES LCO 3.0.6 LCO 3.0.6 establishes an exception to LCO 3.0.2 for supported systems that have a support system LCO specified in the TSs. This exception is provided because LCO 3.0.2 would require that the ACTIONs of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's ACTIONs. These ACTIONs may include entering the supported system's ACTIONs or may specify other ACTIONs.

When a support system is inoperable and there is an LCO specified for it in the TS, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability. However, it is not necessary to enter into the supported systems' ACTIONs unless directed to do so by the support system's ACTIONs. The potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCOs' ACTIONs are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's ACTIONs.

However, there are instances where a support system's ACTION may either direct a supported system to be declared inoperable or direct entry into ACTIONs for the supported system. This may occur immediately or after some specified delay to perform some other ACTION. Regardless of whether it is immediate or after some delay, when a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

Specification 6.5.19, "Safety Function Determination Program (SFDP)," ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other limitations, remedial actions, or compensatory actions may be identified as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs. The SFDP implements the requirements of LCO 3.0.6.

The following examples use Figure B 3.0-1 to illustrate loss of safety function conditions that may result when a TS support system is inoperable. In this figure, the fifteen systems that comprise Train A are independent and redundant to the fifteen systems that comprise Train B. To correctly use the figure to illustrate the SFDP provisions for a cross train check, the figure establishes a relationship between support and supported systems as follows: the figure shows System 1 as a support system for System 2 and System 3; System 2 as a support system for System 4 and System 5; and System 4 as a support system for System 8 and System 9. Specifically, a loss of safety function may exist when a support system is inoperable and:

a.

A system redundant to system(s) supported by the inoperable support system is also inoperable (Example B 3.0.6-1),

ARKANSAS - UNIT 2 B 3/4 0-8 Amendment No. 246 Rev. 33,36,38,48,74,

b.

A system redundant to system(s) in turn supported by the inoperable supported system is also inoperable (Example B 3.0.6-2), or

c.

A system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable (Example B 3.0.6-3).

For the following examples, refer to Figure B 3.0-1.

EXAMPLE B 3.0.6-1 If System 2 of Train A is inoperable and System 5 of Train B is inoperable, a loss of safety function exists in Systems 5, 10, and 11.

EXAMPLE B 3.0.6-2 If System 2 of Train A is inoperable, and System 11 of Train B is inoperable, a loss of safety function exists in System 11.

EXAMPLE B 3.0.6-3 If System 2 of Train A is inoperable, and System 1 of Train B is inoperable, a loss of safety function exists in Systems 2, 4, 5, 8, 9, 10 and 11.

If an evaluation determines that a loss of safety function exists, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

Figure B 3.0-1 Configuration of Trains and Systems TRAIN A TRAIN B System 8 System 8 System 4 System 4 System 9 System 9 System 2 System 2 System 10 System 10 System 5 System 5 System 11 System 11 System 1 System 1 System 12 System 12 System 6 System 6 System 13 System 13 System 3 System 3 System 14 System 14 System 7 System 7 System 15 System 15 This loss of safety function does not require the assumption of additional single failures or loss of offsite power. Since operations are being restricted in accordance with the ACTIONs of the support system, any resulting temporary loss of redundancy or single failure protection is taken into account. Similarly, the ACTIONs for inoperable offsite circuit(s) and inoperable diesel generator(s) provide the necessary restriction for cross train inoperabilities. This explicit cross

ARKANSAS - UNIT 2 B 3/4 0-8 Amendment No. 246 Rev. 33,36,38,48,74, train verification for inoperable AC electrical power sources also acknowledges that supported system(s) are not declared inoperable solely as a result of inoperability of a normal or emergency electrical power source (refer to the ACTIONs of LCO 3.8.1.1).

When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate ACTIONs of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected.

Where a loss of function is solely due to a single TS support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level), the appropriate LCO is the LCO for the support system.

The ACTIONS for a support system LCO adequately address the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

ARKANSAS - UNIT 2 B 3/4 3-2 Amendment No. 33,110,130,163,191,206 Rev. 10,11,17,40,56,60, 3/4.3 INSTRUMENTATION BASES The bistable for the operating bypasses for the CPC and Logarithmic Power Level - High trips is required to be set within the two decade range allowed by Table 3.3-1 notations (a) and (c) and Table 2.2-1 notations (1) and (5). These limits provide the bistable with the appropriate range to account for the bistable hysteresis and to provide margin for the applicable uncertainties.

Regardless of the actual bistable setpoint within the two decade band, the single bistable design ensures that either the CPC or the Logarithmic Power Level - High trips are available to provide reactor trip protection. During testing pursuant to Special Test Exception 3.10.3, the bistable setpoint for these operating bypasses is increased to automatically remove the CPCs from bypass before the logarithmic power level exceeds 1% power.

Tables 2.2-1 notation (2), 3.3-1 notation (b), 3.3-3 notation (a), and 3.3-4 notation (1) allow the Pressurizer Pressure - Low function to be manually bypassed below 400 psia when the operating bypass permissive has been enabled. The margin between the pressurizer pressure and the setpoint is maintained 200 psia as pressurizer pressure is reduced during controlled plant cooldowns. This allows for controlled depressurization of the RCS while still maintaining an active trip setpoint until the trip is no longer needed to protect the plant. Since the Pressurizer Pressure - Low bistable is shared with RPS, SIAS, and CCAS an inadvertent actuation of these systems due to low pressurizer pressure is prevented while bypassed. The Pressurizer Pressure - Low bypass is required to be automatically removed before RCS pressure exceeds 500 psia. The difference between the 400 psia allowance for the manual bypass and 500 psia automatic bypass removal feature allows for the bistable hysteresis.

The Table 3.3-4 Allowable Values associated with the Loss of Power relays ensure automatic system response is initiated as presented in the SAR, Section 8.3.1.1.8.8. The selection of these values is such that adequate protection is provided when all sensor and processing time delays are taken into account. A channel is inoperable if its actuation trip setpoint is not within its required Allowable Value or within as-found OPERABILITY limits established in procedures.

The as-found OPERABILITY limits contained in the associated plant procedures may be required to account for the method of relay testing, which is performed on the bench instead of in the normal installed configuration. To ensure OPERABILITY between calibrations, the as-left setting established in procedures accounts for all other instrument uncertainties such as instrument drift/tolerances and MT&E accuracy.

Because only one of the two Loss of Voltage (LOV) relays (channels) on a given 4.16 kv bus is required to actuate, Table 3.3-3, Action 9, permits up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore an inoperable relay to operable status since the remaining relay is capable of performing the specified design function. If both relays on a given 4.16 kv bus are inoperable, the function has been lost.

Therefore, in addition to restoring the relays to an OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the respective Emergency Diesel Generator (EDG) must be immediately declared inoperable in accordance with Action 14 of Table 3.3-3. Action 14 is also applicable to the loss of any Degraded Voltage (DV) channel since both DV relays on a given 460 volt bus must actuate to satisfy the specified safety function. Entry into the EDG LCO ensures appropriate cross-train checks will be performed in order to identify the potential for a loss of safety function.

When required cChannels are not restored to an OPERABLE status in accordance with Actions 9, 12, 13, or 143, the plant must be brought to a MODE in which overall plant risk is minimized.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (reference CE

ARKANSAS - UNIT 2 B 3/4 4-2 Amendment No. 20,158,184,223 Rev. 10,11,19,56,61,63, REACTOR COOLANT SYSTEM BASES 3/4.4.2 and 3/4.4.3 SAFETY VALVES The pressurizer code safety valves operate to prevent the RCS from being pressurized above its Safety Limit of 2750 psia. Each safety valve is designed to relieve 453,817 lbs. per hour of saturated steam at 3% overpressure. The relief capacity of a single safety valve is adequate to relieve any overpressure condition which could occur during shutdown.

Two safety valves are required in MODES 1, 2 and 3. One safety valve is required in MODE 4 with Tc > 220 °F. For the remainder of MODES 4, 5 and 6 with the reactor vessel head in place, overpressure protection is provided by the operating procedures and LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia. The combined relief capacity of these valves is sufficient to limit the Reactor Coolant System pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RATED THERMAL POWER and assuming no reactor trip until the first Reactor Protective System trip setpoint (Pressurizer Pressure-High) is reached (i.e., no credit is taken for a direct reactor trip on the loss of turbine) and also assuming no operation of the steam dump valves.

Demonstration of the safety valves' lift setting will occur only during shutdown and will be performed in accordance with the provisions of the ASME Operation and Maintenance Code.

3/4.4.4 PRESSURIZER A steam bubble in the pressurizer ensures that the RCS is not a hydraulically solid system and is capable of accommodating pressure surges during operation. The steam bubble also protects the pressurizer code safety valves against water relief. The steam bubble functions to relieve RCS pressure during all design transients. To account for instrument uncertainty, the in-plant pressurizer level corresponding to the 910 ft3 TS limit is controlled at 67%.

The requirement that 150 KW of pressurizer proportional heaters per group and the associated controls be capable of being supplied electrical power from an emergency bus provides assurance that at least one bank of these heaters can be energized within 30 minutes followingduring a loss-of-offsite power condition to aid in maintaining subcooling margin during a natural circulation cooldownat HOT STANDBY. ACTION (b) is applicable to conditions when a single proportional heater group is inoperable due to a loss of an emergency power supply.

ACTION (b) requires that Tthe AOT associated with a single inoperable EDG (TS 3.8.1.1 ACTION b.43) restricts the time in which an emergency power source can be unavailable by requiring the respectiveentered when a heater group has an inoperable emergency power supply. This ACTION allows 14 days to restore an inoperable EDG to be restored to an OPERABLE status within 14 days provided the AACDG is available. If the AACDG is not available, the EDG must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In the event the circuit between the AACDG and the proportional heater group is unavailable (480 V Load Center breaker supplying the heater group is open or other similar break in the circuit), ACTION (b) is entered requiring the circuit to be restored to within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .the AACDG cannot be considered available to the heater group. Likewise, if a proportional heater group output capability is known to be < 150 KW, the availability of the AACDG provides no additional capability. Both of these cases require the proportional heater group to be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in accordance with Note 1 of EDG TS 3.8.1.1 ACTION b.3 (Reference Licensing Memo LIC 04-045 and -046) or ACTION (c) below.

ARKANSAS - UNIT 2 B 3/4 4-3 Rev. 19,47,56,63, REACTOR COOLANT SYSTEM BASES 3/4.4.4 PRESSURIZER (continued)

ACTION (bc) is applicable if one group of pressurizer proportional heaters is inoperable due to having less than the required 150 KW capacity, with restoration required within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The AOT of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable considering that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using the redundant group of proportional heaters or the backup heater groups.

If two required groups of pressurizer heaters are inoperable for any reason, restoring at least one group of pressurizer heaters to OPERABLE status is required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ACTION (dc) is modified by a Note stating it is not applicable if the second group of required pressurized heaters is intentionally declared inoperable. ACTION (dc) is not intended for voluntary removal of redundant systems or components from service. The ACTION is only applicable if one group of required pressurized heaters is inoperable for any reason and the second group of required pressurized heaters is discovered to be inoperable, or if both groups of required pressurized heaters are discovered to be inoperable at the same time. If both required groups of pressurizer heaters are inoperable, the pressurizer heaters may not be available to help maintain subcooling in the RCS loops during a natural circulation cooldown following a loss of offsite power. The inoperability of two groups of required pressurizer heaters during the 24-hour AOT has been shown to be acceptable based on the infrequent use of the ACTION and the small incremental effect on plant risk (Reference WCAP-16125-NP-A, Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown, Revision 2, August 2010).

3/4.4.5 STEAM GENERATOR (SG) TUBE INTEGRITY

=

Background===

Steam generator (SG) tubes are small diameter, thin walled tubes that carry primary coolant through the primary to secondary heat exchangers. Steam generator tubes are an integral part of the reactor coolant pressure boundary (RCPB) and, as such, are relied on to maintain the primary systems pressure and inventory. The SG tubes isolate the radioactive fission products in the primary coolant from the secondary system. In addition, as part of the RCPB, the SG tubes are unique in that they act as the heat transfer surface between the primary and secondary systems to remove heat from the primary system. This Specification addresses only the RCPB integrity function of the SG. The SG heat removal function is addressed by LCO 3.4.1.1, STARTUP and POWER OPERATION (MODES 1 and 2), LCO 3.4.1.2, HOT STANDBY (MODE 3), and LCO 3.4.1.3, SHUTDOWN (MODES 4 and 5).

SG tube integrity means that the tubes are capable of performing their intended RCPB safety function consistent with the licensing basis, including applicable regulatory requirements.

Steam generator tubing is subject to a variety of degradation mechanisms. Steam generator tubes may experience tube degradation related to corrosion phenomena, such as wastage, pitting, intergranular attack, and stress corrosion cracking, along with other mechanically induced phenomena such as denting and wear. These degradation mechanisms can impair tube integrity if they are not managed effectively. The SG performance criteria are used to manage SG tube degradation.

ARKANSAS - UNIT 2 B 3/4 6-9 Amendment No. 194,245 Rev. 9,17,23,27,41,44,51,53,56 63,73,75, CONTAINMENT SYSTEMS BASES 3/4.6.3 CONTAINMENT ISOLATION VALVES (continued)

The opening of locked or sealed closed manual and deactivated automatic containment isolation valves on an intermittent basis under administrative control, consistent with Generic Letter (GL) 91-08, includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valve controls, (2) instructing the operator to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside containment. This allowance is acceptable due to the expected infrequent need to apply these administrative controls and because the dedicated individual is assumed to close the penetration, when directed, without delay.

Containment penetration isolation response times are not applicable when these administrative controls are applied. When opening a penetration using the allowance of the LCO Note, LCO entry is delayed during the time period the Note is being applied. It is also acceptable to apply these administrative controls for a valve closed in accordance with ACTION b or c. In addition, in accordance with LCO 3.0.4, a penetration in which this Note is being applied may remain open during MODE changes because TS 3.6.3.1 permits continued plant operation in this configuration, provided the valve is closed when the required administrative controls are withdrawn.

The ACTIONs are modified by a Note which ensures that appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable CIV. With one or more CIVs inoperable in one or more penetrations, the method of penetration isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Examples of isolation barriers that meet this criterion are a closed and de-activated automatic reactor building isolation valve, a closed manual valve, a blind flange, and a check valve (inside containment) with flow through the valve secured. Note that if both CIVs in a given penetration are inoperable while the penetration remains open, LCO 3.0.3 is also applicable until the penetration is isolated by at least one isolation barrier as described above, except as permitted under the aforementioned LCO Note.

With Actions "a", "b", or "c" not met (as applicable), the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (reference CE NPSD-1186-A, Technical Justification for the Risk Informed Modification to Selected Required Action End States for CEOG PWRs, October 2001). In MODE 4 there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. These Actions are modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ARKANSAS - UNIT 2 B 3/4 7-4 Amendment No. 153 Rev. 26,33,56, PLANT SYSTEMS BASES 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION The limitation on steam generator pressure and temperature ensures that the pressure-induced stresses in the steam generators do not exceed the maximum allowable fracture toughness stress limits. The limitations to 90 °F and 275 psig are based on a steam generator RTNDT of 30 °F and are sufficient to prevent brittle fracture.

3/4.7.3 SERVICE WATER SYSTEM The OPERABILITY of the Sservice Wwater Ssystem (SWS) ensures that sufficient cooling capacity is available for continued operation of equipment during normal and accident conditions. The redundant cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the accident analyses.

The ACTIONs are modified by two Notes. The first Note indicates that the applicable ACTIONs of LCO 3.8.1.1, "AC Sources - Operating," should be entered if the inoperable SWS train results in an inoperable Emergency Diesel Generator. The second Note indicates that the applicable ACTIONs of LCO 3.4.1.3, "Reactor Coolant System - Shutdown," should be entered if an inoperable SWS train results in an inoperable Shutdown Cooling train.

If the inoperable Service Water Pump cannot be restored to an OPERABLE status within the allowable outage time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (reference CE NPSD-1186-A, Technical Justification for the Risk Informed Modification to Selected Required Action End States for CEOG PWRs, October, 2001). In MODE 4 there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state. These Actions are modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ARKANSAS - UNIT 2 B 3/4 8-2 Amendment No. 146,198,204,215 Rev. 1,6,17,54,56,63 3/4.8 ELECTRICAL POWER SYSTEMS BASES Since a station blackout is the most affected event that could occur when power sources are inoperable, the steam driven emergency feedwater (EFW) pump will also be maintained available during the evolution.

ACTION a.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated EDG will not result in a complete loss of safety function of critical redundant required features.

These features are powered from the redundant AC electrical power train. The allowable outage time (AOT) for ACTION a.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This AOT also allows for an exception to the normal "time zero" for beginning the AOT "clock." In this ACTION, the AOT only begins on discovery that both:

a.

The train has no offsite power supplying its loads, and

b.

A required feature on the other train is inoperable.

If at any time during conditions when one offsite circuit is inoperable a redundant required feature subsequently becomes inoperable, the 24-hour AOT begins to be tracked. Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the subject AOT.

Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this condition, the remaining OPERABLE offsite circuit and EDGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24-hour AOT takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one redundant set of onsite AC and DC power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite AC source. ACTION requirements are consistent with Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability" and the Revised Standard Technical Specifications (NUREG 1432).

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

ACTION b.2 is intended to provide assurance that a loss of offsite power, during the period that an EDG is inoperable, does not result in a complete loss of safety function of critical systems.

These features are designed with redundant safety related trains. Redundant required feature

ARKANSAS - UNIT 2 B 3/4 8-2 Amendment No. 146,198,204,215 Rev. 1,6,17,54,56,63 failures consist of inoperable features with a train, redundant to the train that has an inoperable EDG.

The AOT for ACTION b.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This AOT also allows for an exception to the normal "time zero" for beginning the AOT "clock." In this ACTION, the AOT only begins on discovery that both:

a.

An inoperable EDG exists, and

b.

A required feature on the other train is inoperable.

If at any time during conditions when one EDG is inoperable a required feature subsequently becomes inoperable, the 4-hour AOT begins to be tracked. Discovering one required EDG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE EDG, results in starting the subject AOT. Four hours from the discovery of these events existing concurrently, is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this condition, the remaining OPERABLE EDG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4-hour AOT takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

ACTIONction b.32 provides an allowance to avoid unnecessary testing of OPERABLE EDGs. If it can be determined that the cause of the inoperable EDG does not exist on the OPERABLE EDG, SR 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on the remaining EDG, the other EDG would be declared inoperable upon discovery and ACTIONction e entered. Once the failure is repaired, the common cause failure no longer exists and ACTIONction b.32 is satisfied. If the cause of the initial inoperable EDG cannot be confirmed not to exist on the remaining EDG, performance of SR 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of that EDG.

In the event the inoperable EDG is restored to OPERABLE status prior to completing ACTIONction b.32, the plant Corrective Action Program (CAP) will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24-hour constraint initially imposed by ACTIONction b.

If while an EDG is inoperable, a new problem with the EDG is discovered that would have prevented the EDG from performing its specified safety function, a separate entry into ACTIONction b is not required. The new EDG problem should be addressed in accordance with the plant CAP.

TS 3.8.1.1 ACTION b.43 allows for the extension of the EDG AOT up to 14 days. Typically, use of the extended AOT will be restricted to once per 18-month cycle per EDG for voluntary planned maintenance or inspections, but it may be used for failures or other corrective maintenance activities provided plant risk is managed. The following contingencies shall be met prior to entering the extended EDG AOT (not applicable to 14-day AOT for Pressurizer Proportional Heater bank inoperability, with the exception of AACDG availability) when pre-planned maintenance activities are scheduled or within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if unplanned entry into the action is required:

ARKANSAS - UNIT 2 B 3/4 8-4 Amendment No. 146,198,204,215 Rev. 1,11,15,17,48,54,56,63, 3/4.8 ELECTRICAL POWER SYSTEMS BASES

13. During the EDG outage, welding and transient combustibles in the following areas will be controlled: the transformer yard; the south Switchgear Room (SS/2100-Z); the Cable Spreading Room (G/2098-L); Intake Structure (OO/IS); Diesel Corridor (JJ/2109-U); Lower South Electrical/Piping Penetration Room (EE/2055SC); and Electrical Equipment Room (TT/2108-S).

14. Prior to the EDG outage, the ANO-2 Operations personnel and ANO-1 fire brigade personnel will be briefed on information related to fighting electrical fires and fires that may occur in the transformer yard. The briefing will include relevant industry operating experience related to fires in these areas and will also include a discussion of equipment restoration.

15. Prior to the EDG outage, the operability of the fire suppression in the transformer yard will be confirmed. This will be accomplished by verifying that surveillances are current and the system is not isolated. If the system is isolated, then fire hoses will be staged to the transformer yard area during the EDG maintenance outage.

Note 1 of TS 3.8.1.1 ACTION "b" requires availability of the AACDG when an EDG is removed from service. If the AACDG becomes unavailable, then the AOT is reduced to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time the AACDG becomes unavailable, not to exceed 14 days from the initial entry related to the inoperable EDG. Either the AACDG or the EDG may be restored within the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the EDG is restored, then TS 3.8.1.1, ACTION "b" is exited. If the AACDG is restored within the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then restoration of the EDG must be accomplished within the initial 14 day AOT (i.e.

14 days from the time the EDG was initially declared inoperable and ACTION "b" was entered).

For the purposes of this specification, AACDG availability (OPERABILITY) is demonstrated by its last test performance and no known AACDG deficiencies that bring into question its ability to accept loads as described in the SAR).

Pursuant to LCO 3.0.6, the distribution system ACTIONs would not be entered even if all AC sources were inoperable resulting in de-energization of buses. Therefore, ACTION c is modified by a Note to indicate that with no AC source to any train (i.e., one or both trains de-energized), the ACTIONs for LCO 3.8.2.1, "A.C. Distribution - Operating," must be immediately entered. This allows ACTION "c" to provide requirements for the loss of one offsite circuit and one EDG without regard to whether a train is de-energized. LCO 3.8.2.1 provides the appropriate restrictions for a deenergized train.

ACTION c.2 requires required feature(s) supported by the inoperable EDG to be declared inoperable if its redundant required feature(s) is inoperable, consistent with ACTION b.2 above.

ACTION d.2, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The AOT for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (ACTION a.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93, "Availability of Electric Power Sources," allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter AOT of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains.

ARKANSAS - UNIT 2 B 3/4 8-4 Amendment No. 146,198,204,215 Rev. 1,11,15,17,48,54,56,63, The AOT for ACTION d.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This AOT also allows for an exception to the normal "time zero" for beginning the AOT "clock." In this ACTION, the AOT only begins on discovery that both:

a.

All required offsite circuits are inoperable, and

b.

A required feature is inoperable.

If at any time during conditions when two offsite circuits are inoperable and a required feature becomes inoperable, the 12-hour AOT begins to be tracked.

TS 3.8.1.1 ACTION c.54 is entered when one of the inoperable AC Sources is restored to an OPERABLE status as required by ACTION c.34 and requires restoration of the remaining inoperable AC Source to an OPERABLE status. The allowable restoration time in ACTION c.45 for the remaining inoperable AC source began when the component initially became inoperable.

If not restored within the AOT, then a plant shutdown is required. The requirement associated with the AACDG (reference ACTION b.43 Note 1) is applicable to the EDG AOT.

TS 3.8.1.1 ACTION e.3 requires restoration of the remaining inoperable EDG to an OPERABLE status. The time allowed for restoration is based on the time at which the remaining inoperable EDG was initially declared inoperable. If not restored within the AOT, then a plant shutdown is required. The requirement associated with the AACDG (reference ACTION b.34, Note 1) is applicable to the EDG AOT.

Note that if a plant shutdown is required in accordance with TS 3.8.1.1 ACTIONs b.43, c.3, c.4, e.2, or e.3 (due to one or more EDGs remaining inoperable), TS 3.4.4 ACTION "b" requires the plant to be in HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Each offsite circuit must be capable of providing three phases of AC power, maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses. This SR 4.8.1.1.1.a verifies correct breaker alignment for each required offsite circuit to ensure that distribution buses and loads are connected to their preferred power source, and that appropriate independence of offsite circuits is maintained. The SR also verifies the indicated availability of three-phase AC electrical power from each required offsite circuit to the onsite distribution network.

ARKANSAS - UNIT 2 B 3/4 8-12 Rev. 54,63, 3/4.8 ELECTRICAL POWER SYSTEMS BASES ACTION "a", similar to that of TS 3.8.2.3, provides the opportunity to place the standby battery charger in service to restore the battery terminal voltage to greater than or equal to the minimum established float voltage, when degradation or inoperability is associated with an in-service battery charger. The ACTION provides a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Refer to TS 3.8.2.3 ACTION "a" Bases for further detail. The 2-hour AOT also may be utilized to place the redundant train or subsystem in service.

With the time requirement of ACTION "a" not met or with the required DC distribution system otherwise inoperable, actions must be taken declare affected features inoperable or to suspend the movement of recently irradiated fuel assemblies (i.e., 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 ), the movement of new fuel assemblies over recently irradiated fuel assemblies, and activities that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6), which act to minimize the probability of the occurrence of postulated events.

By allowing the option to declare affected features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONs. In many instances this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e.,

to suspend movement of recently irradiated fuel assemblies, and operations involving positive reactivity additions).

Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safety operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that what 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. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure that such does not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish placing fuel assemblies in a safe conservative conditionposition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystem(s) and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

The time constraint of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Due to radioactive decay, AC/DC electrical power and associated distribution systems are only required to mitigate fuel handling accidents involving movement of recently irradiated fuel assemblies (i.e., 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 ) or the movement of new fuel assemblies over recently irradiated fuel assemblies.

SR 4.8.2.4.2 relies on SRs 4.8.2.3.1, 4.8.2.3.2, and 4.8.2.3.3 to demonstrate OPERABILITY of the required shutdown DC source. While all three SRs must be met, SRs 4.8.2.3.2 and 4.8.2.3.3 are not required to be performed. Due to the long period of time in which an outage

Enclosure, Attachment 3 2CAN112004 Retyped Technical Specification Pages (19 Pages)

ARKANSAS - UNIT 2 1-1 Amendment No. 91,157,244, DEFINITIONS DEFINED TERMS 1.1 The DEFINED TERMS of this section appear in capitalized type and are applicable, throughout these Technical Specifications.

THERMAL POWER 1.2 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

RATED THERMAL POWER 1.3 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 3026 MWt.

OPERATIONAL MODE - MODE 1.4 An OPERATIONAL MODE (i.e. MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.1.

ACTION 1.5 ACTION shall be those additional requirements specified as corollary statements to each principle specification and shall be part of the specifications.

OPERABLE - OPERABILITY 1.6 A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

REPORTABLE OCCURRENCE 1.7 A REPORTABLE OCCURRENCE shall be any of those conditions specified in Section 50.73 to 10CFR Part 50.

ARKANSAS - UNIT 2 3/4 0-1 Amendment No. 19,134,207,281, 283,309,316, 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation (LCO) and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for each specification, except as provided in LCO 3.0.2, LCO 3.0.8, and LCO 3.0.9.

3.0.2 Adherence to the requirements of the LCO and/or associated ACTION within the specified time interval shall constitute compliance with the specification, except as provided in LCO 3.0.5 and LCO 3.0.6. In the event the LCO is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.

3.0.3 In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , action shall be initiated to place the unit in a mode in which the specification does not apply by placing it, as applicable, in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless corrective measures are completed that permit operation under the permissible ACTION statements for the specified time interval as measured from initial discovery or until the reactor is placed in a MODE in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specification.

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

a.

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

b.

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

c.

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

This specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONs or that are part of a shutdown of the unit.

ARKANSAS - UNIT 2 3/4 0-1a Amendment No. 281,283,309, 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY (continued)

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

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

Only the support system LCO ACTIONs are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.5.19, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered.

When a support system's ACTION directs a supported system to be declared inoperable or directs entry into the ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with LCO 3.0.2.

3.0.7 To be used later.

3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a.

the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b.

the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

ARKANSAS - UNIT 2 3/4 3-13 Amendment No. 134,159,186,289, TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION

7.

LOSS OF POWER

a.

4.16 kv Emergency Bus Undervoltage (Loss of Voltage) 2/Bus 1/Bus 2/Bus 1,2,3 9,14

b.

460 volt Emergency Bus Undervoltage (Degraded Voltage) 1/Bus 1/Bus 1/Bus 1,2,3 14

8.

EMERGENCY FEEDWATER (EFAS)

a.

Manual (Trip Switches) 2 sets of 2 per S/G 2 sets of 2 per S/G 2 sets of 2 per S/G 1,2,3 9

b.

SG Level and Pressure (A/B) -

Low and P (A/B) - High 4/SG 2/SG 3/SG 1,2,3 10,11

c.

SG Level (A/B) - Low and No S/G Pressure - Low Trip (A/B) 4/SG 2/SG 3/SG 1,2,3 10,11

d.

ESFAS Logic

1.

Matrix Logic 6

1 3

1,2,3 12

2.

Initiation Logic 4

2 4

1,2,3 9

e.

Automatic Actuation Logic 2

1 2

1,2,3 13

ARKANSAS - UNIT 2 3/4 3-15a Amendment No. 301, TABLE 3.3-3 (Continued)

TABLE NOTATION ACTION 12 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

ACTION 13 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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 ; however, one channel may be bypassed for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing provided the other channel is OPERABLE. LCO 3.0.4.a is not applicable when entering HOT SHUTDOWN.

ACTION 14 - With the number of 460 volt Degraded Voltage (Functional Unit 7.b) channels one less than the Total Number of Channels or with both 4.16 kv Loss of Voltage (Functional Unit 7.a) channels inoperable on a single bus:

a.

Immediately declare the affected EDG inoperable, and

b.

Restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

ARKANSAS - UNIT 2 3/4 4-5 Amendment No. 20,234,304,315, REACTOR COOLANT SYSTEM PRESSURIZER LIMITING CONDITION FOR OPERATION 3.4.4 The pressurizer shall be OPERABLE with a water volume of 910 cubic feet (equivalent to 82% of wide range indicated level) and both pressurizer proportional heater groups shall be OPERABLE.

APPLICABILITY:

MODES 1, 2 and 3.

ACTION:

(a)

With the pressurizer inoperable due to water volume 910 cubic feet, be in at least HOT SHUTDOWN with the reactor trip breakers open within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(b)

With the pressurizer inoperable due to a single proportional heater group having less than a 150 KW capacity, restore the inoperable proportional heater group to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(c)

With the pressurizer inoperable due to both proportional heater groups being inoperable for any reason (Note 1), restore at least one proportional heater group to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4.4.4.1 The pressurizer water volume shall be determined to be within its limits in accordance with the Surveillance Frequency Control Program.

4.4.4.2 The pressurizer proportional heater groups shall be determined to be OPERABLE in accordance with the Surveillance Frequency Control Program by verifying that the summed power consumption of the two proportional heater groups is 150 KW.

Note 1: Action (d) is not applicable when the second group of required pressurizer heaters is intentionally made inoperable.

ARKANSAS - UNIT 2 3/4 4-14 Amendment No. 184,266,280, Order dated 4/20/81 REACTOR COOLANT SYSTEM REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE LIMITING CONDITION FOR OPERATION 3.4.6.2 Reactor Coolant System operational leakage shall be limited to:

a.

No PRESSURE BOUNDARY LEAKAGE,

b.

1 GPM UNIDENTIFIED LEAKAGE,

c.

150 gallons per day primary to secondary leakage through any one steam generator (SG),

d.

10 GPM IDENTIFIED LEAKAGE from the Reactor Coolant System, and

e.

Leakage as specified in Table 3.4.6-1 for those Reactor Coolant System Pressure Isolation Valves identified in Table 3.4.6-1.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With any PRESSURE BOUNDARY LEAKAGE or any primary to secondary leakage not within limit, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

With any Reactor Coolant System operational leakage greater than any one of the above limits, excluding PRESSURE BOUNDARY LEAKAGE and primary to secondary leakage, reduce the leakage rate to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c.

With any Reactor Coolant System Pressure Isolation Valve leakage greater than the above limit, isolate (Note 1) the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least two valves* in each high pressure line having a non-functional valve and 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Note 1:

Enter applicable ACTION(s) for system(s) made inoperable by an inoperable pressure isolation valve.

These valves may include check valves for which the leakage rate has been verified, manual valves or automatic valves. Manual and automatic valves shall be tagged as closed to preclude inadvertent valve opening.

ARKANSAS - UNIT 2 3/4 6-2 Amendment No. 176, CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be in accordance with the Containment Leakage Rate Testing Program.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

With the containment leakage rate exceeding the acceptance criteria of the Containment Leakage Rate Testing Program, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , restore leakage to within limits or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.6.1.2 The containment leakage rates shall be determined in accordance with the Containment Leakage Rate Testing Program.

ARKANSAS - UNIT 2 3/4 6-16 Amendment No. 121,134,154,255,

301, CONTAINMENT SYSTEMS 3/4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3.1 Each containment isolation valve shall be OPERABLE.*

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Note: Enter applicable ACTION(s) for system(s) made inoperable by containment isolation valves.

With one or more isolation valve(s) inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and either:

a.

Restore the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or

b.

Isolate each affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one deactivated automatic valve secured in the isolation position, or

c.

Isolate the affected penetration within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by use of at least one closed manual valve or blind flange; or

d.

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.

SURVEILLANCE REQUIREMENTS 4.6.3.1.1 Each containment isolation valve shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test and verification of isolation time.

Locked or sealed closed valves may be opened on an intermittent basis under administrative control.

ARKANSAS - UNIT 2 3/4 7-15 Amendment No. 301,315, PLANT SYSTEMS 3/4.7.3 SERVICE WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3.1 At least two independent service water loops shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Notes:

1.

Enter applicable ACTION(s) of LCO 3.8.1.1, "AC Sources - Operating," for EDG made inoperable by service water system.

2.

Enter applicable ACTION(s) of LCO 3.4.1.3, "Reactor Coolant System - Shutdown," if a required shutdown cooling loop is made inoperable by service water system.

With only one service water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 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.

SURVEILLANCE REQUIREMENTS 4.7.3.1 At least two service water loops shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

In accordance with the Surveillance Frequency Control Program during shutdown, by verifying that each automatic valve servicing safety related equipment actuates to its correct position on CCAS, MSIS and RAS test signals.

ARKANSAS - UNIT 2 3/4 8-1 Amendment No. 141,215,234,249,255, 281,301, 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system and

b.

Two separate and independent diesel generators each with:

1.

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

2.

A separate fuel storage system, and

3.

A separate fuel transfer pump.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

NOTE: Specification 3.0.4.b is not applicable to diesel generators.

a.

With one offsite A.C. circuit of the above required A.C. electrical power sources inoperable, perform the following:

1.

Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required features(s), declare required features(s) with no offsite power available inoperable when its redundant required features(s) is inoperable, and

3.

Restore the offsite A.C. circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 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. Startup Transformer No. 2 may be removed from service for up to 30 days as part of a preplanned preventative maintenance schedule. The 30-day allowance may be applied not more than once in a 10-year period.

ARKANSAS - UNIT 2 3/4 8-1a Amendment No. 249,301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

b.

With one diesel generator of the above required A.C. electrical power source inoperable, perform the following:

1.

Demonstrate the OPERABILITY of both the offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) is inoperable, and

3.

Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by:

i.

Determining the OPERABLE diesel generator is not inoperable due to a common cause failure, or ii.

Perform Surveillance Requirement 4.8.1.1.2.a.4 unless:

a.

The remaining diesel generator is currently in operation, or

b.

The remaining diesel generator has been demonstrated OPERABLE within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

4.

Restore the diesel generator to OPERABLE status within 14 days (See Note 1) or 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 - If the Alternate A.C. Diesel Generator (AACDG) is determined to be inoperable during this period, then a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration period is applicable until either the AACDG or the diesel generator is returned to operable status (not to exceed 14 days from the initial diesel generator inoperability).

ARKANSAS - UNIT 2 3/4 8-2 Amendment No. 141,234,249,255,

301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

c.

With one offsite A.C. circuit and one diesel generator of the above required A.C. electrical power sources inoperable (see Note 2), perform the following:

1.

Demonstrate the OPERABILITY of the remaining offsite A.C. circuit by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; and,

2.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable if its redundant required feature(s) is inoperable, and

3.

If the diesel generator became inoperable due to any cause other than preplanned preventative maintenance or testing, then

i.

Demonstrate the OPERABILITY of the remaining OPERABLE diesel generator by performing Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , except when:

a.

The remaining diesel generator is currently in operation, or

b.

The remaining diesel generator has been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

4.

Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and

5.

Restore the remaining inoperable A.C. Source to an OPERABLE status (Offsite A.C.

Circuit within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or Diesel Generator within 14 days (see b.4, Note 1)) based on the time of the initiating event that caused the inoperability.

Otherwise, 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 2 - Enter applicable ACTIONs of LCO 3.8.2.1, "A.C. Distribution - Operating," when ACTION c is entered with no AC power to any train.

ARKANSAS - UNIT 2 3/4 8-2a Amendment No. 141,234,249,255,

301, ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES LIMITING CONDITION FOR OPERATION

d.

With two offsite A.C. circuits of the above required A.C. electrical power sources inoperable, perform the following:

1.

Perform Surveillance Requirement 4.8.1.1.2.a.4 on the diesel generators within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months except when:

i.

The diesel generators are currently in operation, or ii.

The diesel generators have been demonstrated OPERABLE within the previous 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , and

2.

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , declare required feature(s) inoperable when its redundant required feature(s) is inoperable, and

3.

Restore one of the inoperable offsite A.C. circuits to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and

4.

Restore both A.C. circuits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the initiating event, Otherwise, 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.

e.

With two diesel generators of the above required A.C. electrical power sources inoperable, perform the following:

1.

Demonstrate the OPERABILITY of the two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and

2.

Restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and

3.

Restore the remaining inoperable diesel generator within 14 days (see b.4, Note 1) of the initiating event.

Otherwise, 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.

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

ACTION:

Note: Enter applicable ACTIONs of LCO 3.8.2.2, "A.C. Distribution - Shutdown," and LCO 3.8.2.4, "D.C. Sources - Shutdown," with one required train de-energized.

With less than the above minimum required A.C. electrical power sources OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

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 8-6 Amendment No. 315, ELECTRICAL POWER SYSTEMS 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS A.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 The following A.C. electrical busses shall be OPERABLE and energized with tie breakers open between redundant busses:

4160 volt Emergency Bus # 2A3 4160 volt Emergency Bus # 2A4 480 volt Emergency Bus # 2B5 480 volt Emergency Bus # 2B6 120 volt A.C. Vital Bus # 2RS1 120 volt A.C. Vital Bus # 2RS2 120 volt A.C. Vital Bus # 2RS3 120 volt A.C. Vital Bus # 2RS4 APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

Note: Enter applicable ACTIONs of LCO 3.8.2.3, "DC Sources - Operating" for DC train(s) made inoperable by inoperable power distribution subsystems.

With less than the above complement of A.C. busses OPERABLE, restore the inoperable bus to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.8.2.1 The specified A.C. busses shall be determined OPERABLE with tie breakers open between redundant busses 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, 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 ACTION:

With less than the above complement of A.C. busses OPERABLE and energized, declare affected required features inoperable OR:

a.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and

b.

Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

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 8-10 Amendment No. 94,227,297,315, 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.

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, declare affected required features inoperable OR:

i.

Immediately suspend core alterations, the movement of irradiated fuel assemblies, and any operations involving positive reactivity additions, and ii. Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

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 6-18b Amendment No.

ADMINISTRATIVE CONTROLS 6.5.19 Safety Function Determination Program (SFDP)

This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs.

This program implements the requirements of LCO 3.0.6. The SFDP shall contain the following:

a.

Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected,

b.

Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists,

c.

Provisions to ensure that an inoperable supported system's allowed outage time is not inappropriately extended as a result of multiple support system inoperabilities, and

d.

Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a.

A required system redundant to the system(s) supported by the inoperable support system is also inoperable, or

b.

A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or

c.

A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate ACTIONs to enter are those of the support system.

Enclosure, Attachment 4 2CAN112004 Table of Support System Actions that Direct Entering Actions of Supported Systems

2CAN112004 Enclosure, Attachment 4 Page 1 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 1.0, Definition of Operable -

Operability A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

1.6, Definition of Operable -

Operability The Arkansas Nuclear One, Unit 2 (ANO-2) definition of "Operable - Operability" is replaced with the Improved Standard Technical Specification (ISTS) definition of "Operable - Operability" from NUREG 1432, "Standard Technical Specifications Combustion Engineer Plants," Revision 4.

Adoption of the ISTS version is appropriate based on proposed changes to ANO-2 Limiting Conditions for Operation (LCOs) 3.0.5 and 3.8.1.1, and the adoption of the Safety Function Determination Program (SFDP) in LCO 3.0.6. The referenced LCOs are discussed later.

2CAN112004 Enclosure, Attachment 4 Page 2 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.3.7, Diesel Generator -

Loss of Voltage Start B.1 Enter applicable Conditions and Required Actions for the associated DG made inoperable by DG - LOVS instrumentation.

D.1 Enter applicable Conditions and Required Actions for the associated DG made inoperable by DG - LOVS instrumentation.

3.3.2.1, ESFAS Instrumentation, Table 3.3-3, Functional Units 7.a/7.b ANO-2 does not have an LCO 3.3.7 but does have Engineered Safety Features Actuation System (ESFAS) LCO 3.3.2.1, Table 3.3-3, which requires Emergency Diesel Generator (EDG) undervoltage (UV) start on Loss of Voltage (LOV) or Degraded Voltage (DV).

A new Action 14 is created in Table 3.3-3 to require entry into applicable Actions of the associated EDG when both LOV channels or any DV channel is inoperable on a respective safety bus:

With the number of 460 volt Degraded Voltage (Functional Unit 7.b) channels one less than the Total Number of Channels or with both 4.16 kv Loss of Voltage (Functional Unit 7.a) channels inoperable on a single bus:

a.

Immediately declare the affected EDG inoperable, and

b.

Restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or 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.

This action remains consistent with previous Action 9 while addressing adoption of the SFDP.

2CAN112004 Enclosure, Attachment 4 Page 3 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.3.8, Containment Purge Isolation Signal A.1 Enter applicable Conditions and Required Actions for affected valves of LCO 3.6.3, "Containment Isolation Valves," made inoperable by CPIS instrumentation.

N/A ANO-2 does not have an LCO 3.3.7 but does have Radiation Monitoring TS 3.3.3.1, Table 3.3-6, which requires one operable channel of Containment Purge and Exhaust Isolation. Associated Action 16 states:

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

a.

If performing CORE ALTERATIONS or moving irradiated fuel within the reactor building, secure the containment purge system or suspend CORE ALTERATIONS and movement of irradiated fuel within the reactor building.

b.

If a containment PURGE is in progress, secure the containment purge system.

c.

If continuously ventilating, verify the SPING monitor operable or perform the ACTIONS of the Offsite Dose Calculation Manual, Appendix 2, Table 2.2-1, or secure the containment purge system.

ANO-2 TS 3.6.1.6, "Containment Ventilation System,"

requires the Containment Purge valves to be locked closed in Modes 1, 2, 3, and 4. Therefore, entry into ANO-2 TS 3.6.3.1, "Containment Isolation Valves,"

would be inappropriate as this TS is applicable in Modes 1, 2, 3, and 4 only. In addition, the requirements of Action 16 above perform the necessary actions when the subject radiation monitoring instrumentation is inoperable.

No changes to the ANO-2 TSs are necessary in support of adopting a SFDP.

2CAN112004 Enclosure, Attachment 4 Page 4 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.4.9, Pressurizer SR 3.4.9.3 [Verify required pressurizer heaters are capable of being powered from an emergency power supply.]

3.4.4, Pressurizer ANO-2 TS 3.4.4 Action (b) requires a Pressurizer proportional heater bank having no emergency power source to be restored to an operable status commensurate with the allowed outage time (AOT) of the corresponding EDG.

With the pressurizer inoperable due to an inoperable emergency power supply to the pressurizer heaters, either restore the inoperable emergency power supply in accordance with TS 3.8.1.1, Action b.3, for an inoperable Emergency Diesel Generator, or be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Surveillance Requirement (SR) 4.4.4.2.a verifies the availability of the emergency power source.

The pressurizer proportional heater groups shall be determined to be OPERABLE.

(a) In accordance with the Surveillance Frequency Control Program by verifying emergency power is available to the heater groups, and Both Action (b) and SR 4.4.4.2 are proposed to be deleted as these requirements are redundant to other TS requirements when consider changes being made to LCO 3.8.1.1 and the adoption of a SFDP (discussed later).

2CAN112004 Enclosure, Attachment 4 Page 5 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.4.14, RCS Pressure Isolation Valve Leakage (ACTIONS Notes)

NOTES-----------------

2. Enter applicable Conditions and Required Actions for systems made inoperable by an inoperable PIV.

3.4.6.2, Reactor Coolant System Leakage ANO-2 TS 3.4.6.2 requires any pressure isolation valve (PIV) to be isolated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if leakage limits are exceeded. The following Note is added to TS 3.4.6.2, Action c:

Enter applicable ACTIONs for systems made inoperable by an inoperable pressure isolation valve.

The subject Note will ensure appropriate entry into the appropriate system TS and provide greater consistency with the ISTS.

3.6.2, Containment Air Locks (ACTIONS Notes)

NOTES-----------------

3. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

3.6.1.3, Containment Air Locks ANO-2 has a separate TS that governs Containment leakage, TS 3.6.1.2. ANO-2 TS 3.6.1.3, "Air Locks,"

currently requires entry into TS 3.6.1.2 if leakage limits are exceeded; therefore, no additional action is necessary for TS 3.6.1.3 in support of adopting a SFDP.

The current TS 3.6.1.2 Action does not drive remedial action when in Modes 1, 2, 3 or 4; therefore, this Action is proposed to be revised to be consistent with ISTS 3.6.1:

With the containment leakage rate exceeding the acceptance criteria of the Containment Leakage Rate Testing Program, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , restore leakage to within limits or 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

2CAN112004 Enclosure, Attachment 4 Page 6 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.6.3, Containment Isolation Valves (Actions Notes)

NOTES-----------------

3. Enter applicable Conditions and Required Actions for system(s) made inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

3.6.3.1, Containment Isolation Valves One option for continued plant operation when a Containment Isolation Valve (CIV) is inoperable is to isolate the affected penetration. A Note is added to direct entry into any TS where its SSC is made inoperable by isolating the affected penetration in accordance with TS 3.6.3.1.

Enter applicable ACTION(s) for system(s) made inoperable by containment isolation valves.

ANO-2 TS 3.6.3.1 does not require the CIVs to meet leak rate criteria. Leakage requirements are governed by a separate ANO-2 TS 3.6.1.2.

Therefore, Improved Standard Technical Specification (ISTS) Note 4 does not need to be incorporated into ANO-2 TS 3.6.3.1 in support of adopting a SFDP.

3.7.7, Component Cooling Water A.1

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

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for shutdown cooling made inoperable by CCW.

N/A The ANO-2 Component Cooling Water (CCW) system is not a TS-required system. No changes to the ANO-2 TS are required in this respect or in support of adopting a SFDP.

2CAN112004 Enclosure, Attachment 4 Page 7 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.7.8, Service Water System A.1

NOTES--------------

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by SWS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - Mode 4,"

for shutdown cooling made inoperable by SWS.

3.7.3.1, Service Water System A Note to the Action of TS 3.7.3.1 is added:

Enter applicable ACTIONs of LCO 3.8.1.1, "AC Sources" for EDG made inoperable by service water system.

The subject Note will ensure appropriate entry into the ANO-2 AC power sources TS and provide greater consistency with the ISTS.

2CAN112004 Enclosure, Attachment 4 Page 8 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.8.1, AC Sources -

Operating (one offsite power source inoperable)

A.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

3.8.1.1, A.C.

Sources LCO 3.0.5 is deleted and the Actions of TSs 3.8.1.1 and 3.8.1.2 modified to gain consistency with the ISTS. Actions and/or Notes are added as needed to address operability of redundant features for greater consistency with the ISTS and in support of the SFDP adoption.

The following is added to Action a (one offsite power source inoperable):

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , declare required features(s) with no offsite power available inoperable when its redundant required features(s) is inoperable.

ANO-2 LCO 3.0.5 currently controls operability of redundant features with respect to periods when required power AC power sources are inoperable.

The LCO is proposed for deletion and the respective Actions of TS 3.8.1.1 revised for greater consistency with the ISTS.

3.8.1, AC Sources -

Operating (one EDG inoperable)

B.2 Declare required feature(s) supported by the inoperable DG inoperable when its redundant required feature(s) is inoperable.

3.8.1.1, A.C.

Sources The following is added to Action b (one EDG inoperable):

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable when its redundant required feature(s) is inoperable.

See ISTS 3.8.1, Action A.2, entry above.

(two offsite power sources inoperable)

C.1 Declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

3.8.1.1, A.C.

Sources The following is added to Action d (two offsite power sources inoperable):

Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

See ISTS 3.8.1, Action A.2, entry above.

2CAN112004 Enclosure, Attachment 4 Page 9 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.8.1, AC Sources -

Operating (Note to Required Actions D.1 and D.2

- one offsite power source and one EDG inoperable)

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating,"

when Condition D is entered with no AC power source to any train.

3.8.1.1, A.C.

Sources The following is added to Action c (one offsite power source and one EDG inoperable):

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , declare required feature(s) supported by the inoperable diesel generator inoperable if its redundant required feature(s) is inoperable.

Added Note to 3.8.1.1, Action c:

Enter applicable ACTIONs of LCO 3.8.2.1, "A.C. Distribution - Operating," when ACTION c is entered with no AC power to any train.

The subject addition of the Action and Note will address operability of redundant features and ensure appropriate entry into the ANO-2 AC distribution TS, providing greater consistency with the ISTS while supporting adoption of the SFDP.

3.8.2, AC Sources -

Shutdown (Note to Required Actions A.1, A.2.1, A.2.2, and A.2.3)

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

Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

3.8.1.2, A.C.

Sources -

Shutdown Added Note to LCO 3.8.1.2:

Enter applicable ACTIONs of LCO 3.8.2.2, "A.C. Distribution - Shutdown," and LCO 3.8.2.4, "D.C. Sources - Shutdown," with one required train de-energized.

The subject Note will ensure appropriate entry into the ANO-2 AC/DC Shutdown distribution TS and declare affected required features inoperable if applicable and provide greater consistency with the ISTS.

2CAN112004 Enclosure, Attachment 4 Page 10 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air F.1 Declare associated DG Inoperable 3.8.1.3, Stored Diesel Fuel Oil This action is currently captured in ANO-2 TS 3.8.1.3, Action 4. Therefore, no change to TS 3.8.1.3 is required.

3.8.6, Battery Parameters F.1 Declare associated battery inoperable 3.8.3, Battery Parameters This action is currently captured in ANO-2 TS 3.8.3, Action f. Therefore, no change to TS 3.8.3 is required.

3.8.7, Inverters

- Operating A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems -

Operating," with any vital bus de-energized.

N/A The ANO-2 inverters are not TS-required components. No changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

3.8.8, Inverters

- Shutdown A.1 Declare affected required feature(s) inoperable N/A There are no Mode 5 or Mode 6 requirements for the ANO-2 inverters or associated 120 V RS panels in the ANO-2 TSs. No changes to the ANO-2 TS are required in this respect in support of adopting a SFDP.

3.8.9, Distribution Systems -

Operating A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC trains made inoperable by inoperable power distribution subsystems.

3.8.2.1, A.C.

Distribution -

Operating Added Note to 3.8.2.1 to require entry into LCO 3.8.2.3 "DC Sources - Operating:

Enter applicable ACTION(s) of LCO 3.8.2.3, "DC Sources - Operating" for DC train(s) made inoperable by inoperable power distribution subsystems.

The subject Note will ensure appropriate entry into the ANO-2 DC power sources TS and provide greater consistency with the ISTS.

2CAN112004 Enclosure, Attachment 4 Page 11 of 11 Table of Support System Actions that Direct Entering Actions of Supported Systems ISTS LCO ISTS Action or None ANO-2 TS LCO ANO-2 Proposed TS Action or Note 3.8.10, Distribution Systems -

Shutdown A.1 Declare associated supported required feature(s) inoperable 3.8.2.2, A.C.

Distribution -

Shutdown 3.8.2.4, D.C.

Distribution -

Shutdown Steps are added to LCOs 3.8.2.2 and 3.8.2.4 to immediately initiate action to restore affected buses to operable status and to declare associated required shutdown cooling subsystem(s) inoperable, if applicable, when any required bus is inoperable.

The ISTS provides an option of declaring associated support features inoperable OR suspending fuel movement and positive reactivity additions. The latter (A.2.1 and A2.2) are currently captured in ANO-2 TS 3.8.2.2, "A.C. Distribution - Shutdown," and TS 3.8.2.4, "DC Sources - Shutdown." Additional steps to initiate actions to return the inoperable subsystems to service or declare affected required features inoperable, if applicable, are being added as part of this proposed change in order to provide greater consistency with the ISTS.

v t e Letter Sequence Request
EPID:L-2020-LLA-0252, License Amendment Request - Application to Adopt a Safety Function Determination Program (SFDP) (Approved, Closed)
Initiation Request Acceptance Administration Questions 9 April 2021 29 September 2021 Answers 24 May 2021 12 November 2021 Results Approval Other:
MONTHYEAR2021-12-17 [Table View]

2CAN112004, License Amendment Request - Application to Adopt a Safety Function Determination Program (SFDP)

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