2CAN121601, Response to Request for Additional Information License Amendment Request for Adoption of TSTF-545, TS Inservice Testing Program & Clarify SR Usage Rule Application to Section 5.5.

Response to Request for Additional Information License Amendment Request for Adoption of TSTF-545, TS Inservice Testing Program & Clarify SR Usage Rule Application to Section 5.5.

ML16342B191
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/07/2016
From:	Richard Anderson Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN121601
Download: ML16342B191 (25)

Text

s Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Richard L. Anderson ANO Site Vice President 2CAN121601 December 7, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Request for Additional Information License Amendment Request for Adoption of TSTF-545, TS Inservice Testing Program & Clarify SR Usage Rule Application to Section 5.5 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter dated March 25, 2016, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code - Arkansas Nuclear One, Unit 2 (2CAN031602) (ML16088A186)

2. NRC email dated November 10, 2016, Request for Additional Information - License Amendment Request for Adoption of TSTF-545, TS Inservice Testing Program & Clarify SR Usage Rule Application to Section 5.5 (2CNA111601) (ML16326A007)

Dear Sir or Madam:

By letter dated March 25, 2016, and pursuant to 10 CFR 50.90, Entergy Operations, Inc.

(Entergy) submitted a request (Reference 1) for an amendment to the Technical Specifications (TS) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed change would revise the TSs to eliminate the Section 6.5, Inservice Testing Program (TS Section 5.5 of NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4, is referred to as TS Section 6.5 in the ANO-2 TSs). A new defined term, Inservice Testing Program, would be added to the TS Definitions section. The request was consistent with TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing.

During the course of review, the NRC determined that additional information is required to support approval of the Reference 1 request. The request for additional information (RAI) was communicated to Entergy via Reference 2. Attachment 1 to this letter contains Entergys response to the RAI and Attachment 2 contains program and procedure references.

2CAN121601 Page 2 of 2 Entergy has determined that the attached RAI response does not affect or invalidate the No Significant Hazards Determination present in the Reference 1 original request.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Arkansas state official.

No new commitments have been identified in this letter.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 7, 2016.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

Sincerely, ORIGINAL SIGNED BY BARRY F. DAVIS FOR RICHARD L. ANDERSON RLA/dbb Attachments:

1. Response to Request for Additional Information - Adoption of TSTF-545

2. Supporting Program/Procedure Excerpts cc: Mr. Kriss M. Kennedy Regional Administrator U. S. Nuclear Regulatory Commission RGN-IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Thomas Wengert MS O-08B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment to 2CAN121601 Response to Request for Additional Information - Adoption of TSTF-545 to 2CAN121601 Page 1 of 5 Response to Request for Additional Information - Adoption of TSTF-545 By letter dated March 25, 2016, and pursuant to 10 CFR 50.90, Entergy Operations, Inc.

(Entergy) submitted a request (Reference 1) for an amendment to the Technical Specifications (TS) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed change would revise the TSs to eliminate the Section 6.5, Inservice Testing Program (TS Section 5.5 of NUREG 1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4, is referred to as TS Section 6.5 in the ANO-2 TSs). A new defined term, Inservice Testing Program, would be added to the TS Definitions section. The request was consistent with TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing.

During the course of review, the NRC determined that additional information is required to support approval of the Reference 1 request. The request for additional information (RAI) was communicated to Entergy via Reference 2. The attachment to this letter contains Entergys response to the RAI.

The following includes the question presented in the NRCs RAI (Reference 2) followed by Entergys response.

RAI During the review of the LAR, the NRC staff noted that ANO-2 TS 4.4.1.3.1 states that the required shutdown cooling loop(s) shall be determined OPERABLE per the Inservice Testing Program. In addition, TS 4.9.8.2 states that the required shutdown cooling loops shall be determined OPERABLE per the Inservice Testing Program.

In general, an IST program that fulfills the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(f) does not contain specific criteria or requirements to verify that systems loops are operable. Therefore, the NRC staff request a detailed explanation (including specific testing requirements and acceptance criteria contained in the IST program) as to how these two surveillance requirements assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

RESPONSE

History IST program references were added to the ANO-2 TSs in 1982 (Reference 3). At the time, the program description was contained in TS 4.0.5. Related TS SRs were updated stating that the component or system required by the respective TS Limiting Condition for Operation (LCO) be determined to be operable per Specification 4.0.5. This was the terminology included in changes to the subject SRs, 4.4.1.3.1 and 4.9.8.2. This wording matched the wording recommended by the NRC in a letter to all U.S. pressurized water reactor licensees, dated June 11, 1980 (Reference 4).

to 2CAN121601 Page 2 of 5 In 2001, TS Amendment 233 relocated the IST requirements previously contained in TS 4.0.5 to the Administrative Section of the TSs as a program element (Reference 5). This required a change to the subject (and other) SRs in order to replace the words Specification 4.0.5 with the Inservice Testing Program. No reduction in program requirements resulted from this relocation.

Entergy concurs that, in general, TS Surveillance Requirements (SRs) today contain specific values, even when referring to the IST program. However, there are examples in the improved standard NUREGs where values are not stated. One example is contained in Revision 4 of NUREG 1432, Standard Technical Specifications for Combustion Engineering Plants, where only reference to the IST program is included:

SR 3.6.12.1 Verify each vacuum relief line OPERABLE in accordance with the Inservice Testing Program.

System Operation In Modes 1, 2, and 3, the LPSI pump takes suction from the Refueling Water Tank (RWT). The suction is automatically transferred to the Containment Sump when the RWT is depleted. LPSI injects through four separate paths into each of the RCS cold legs upon receipt of an Engineered Safety Features (ESF) signal. The Containment Spray pump also takes suction from the RWT and discharges through the SDC heat exchanger before being sprayed into the dome region of the Containment Building.

SDC alignment utilizes a LPSI (normal) or CS (alternate) pump taking suction from the B RCS hot leg and discharging through the Service Water cooled SDC heat exchanger before the fluid is returned to the RCS via the four normal LPSI injection paths.

B RCS M Hot Leg RCS M

M RCS RWT/

2P60A SUMP M

M RCS M LPSI M

RCS M

RWT/

Containment SUMP 2P60B SW 2E-35B M RWT/

SDC HT EXCHS SUMP 2P35A Containment SPRAY SW 2E-35B RWT/

SUMP 2P35B to 2CAN121601 Page 3 of 5 Current Program Requirements The subject SRs are associated with verification of Shutdown Cooling (SDC) loop operability in shutdown Modes 4, 5, and 6. As stated previously, both SRs point to the IST program to demonstrate operability. Operability of a SDC loop requires the capability to establish a minimum recirculation flow to ensure decay heat can be removed from the reactor. The definition of operability in the TSs states that necessary supporting equipment must also be operable. In order for the SDC loop to perform its intended function, supporting features would include a cooling medium (in this case, Service Water available to the SDC heat exchanger) and electrical power to the SDC pump. The SDC pump is normally the Low Pressure Safety Injection (LPSI) pump, although under low Reactor Coolant System (RCS) pressure conditions, a Containment Spray (CS) pump can be utilized as a SDC pump. Because SDC operations are not associated with Design Basis Accidents (DBAs), the system operability requirements are much reduced from that required of the LPSI pumps in Modes 1, 2, and 3 (with RCS pressure

> 1700 psia) or the CS pumps in Modes 1, 2, and 3.

The ANO-2 IST program is controlled by SEP-ANO-2-IST-2, ANO Unit 2 IST Plan. The IST Plan is designed to contain the information necessary to identify the pumps and valves subject to IST, categorization of components, identification of tests to be performed and the frequencies of those tests. It also provides relief requests, justifications for cold shutdown and refueling testing, and positions taken with respect to the prescribed testing in 10 CFR 50.55a. The ANO Unit 2 IST Plan is just one part of the Entergy IST Program. The IST Plan is controlled and implemented in accordance with Entergy fleet procedures EN-DC-332, Inservice Testing and EN-DC-174, Engineering Program Sections. For the ANO Unit 2 IST Plan, the applicable Code is the ASME OM Code 2004 Edition with no addenda.

ANO-2 is in its 4th 120-month IST interval (March 26, 2010 through March 25, 2020). This IST Plan was provided to the NRC in letter dated March 25, 2010 (Reference 6) which included a relief request associated with the LPSI pumps:

LPSI Pump Group Classification - The LPSI pumps will be tested as stand-by pumps (Group B) during Modes 1-4 and continuously or routinely operated pumps (Group A) during Modes 5-6.

This relief request (PRR-ANO2-2009-1) was approved for the ANO-2 4th 120-month interval in NRC letter dated October 10, 2009 (Reference 7).

Although system requirements are greatly reduced for SDC, the IST program does not differentiate between the systems modes of operation with respect to testing. LPSI system testing is addressed in OP-2104.040, LSPI System Operation, which includes quarterly and refueling outage testing requirements. The system is tested to ensure the LPSI system meets the full requirements for ESF actuation and DBA mitigation. The quarterly test and outage-related full flow test refer directly to the IST program which ensures testing methods and criteria are not revised without first verifying IST program requirements will continue to be met.

The LPSI quarterly tests are split into separate supplements to account for the different system alignments when aligned for LPSI and when aligned for SDC. Either supplement verifies proper oil levels, pump cooling, room cooling, pump head, and operation of the discharge check valve.

Pump/component leakage is also documented, if any. System automatic valves are also stroke to 2CAN121601 Page 4 of 5 tested and timed every quarter, along with verifying proper operation of other check valves in the system. Supplement 6 of the procedure also tests the Automatic Closure Interlock designed to prevent over-pressurization of the LPSI/SDC piping (verifies respective suction valves from the B RCS hot leg automatic close on simulated high RCS pressure signal).

The full flow tests, besides verifying ESF required flow, records much of the same data and verifies acceptable vibration levels at full flow conditions. The test also verifies proper operation of other check valves in the system. The ESF flow requirements are much more stringent than the flow requirements needed for SDC. The minimum SDC flow requirement is required by SDC TS SR 4.9.8.1 in Mode 6:

A shutdown cooling loop shall be determined to be in operation and circulating reactor coolant at a flow rate of 2000 gpm at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The associated TS Bases states:

The requirement that at least one shutdown cooling loop be in operation ensures that (1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor pressure vessel below 140 °F as required during the REFUELING MODE, and (2) sufficient coolant circulation is maintained through the reactor core to minimize the effects of a boron dilution incident and prevent boron stratification.

In other modes of operation where SDC may be in service, no specific flow requirements are stated in the TSs, although the system must be capable of removing the decay heat load for the given time in core life and time after shutdown. Procedures instruct operators to maintain a flow of at least 2000 gpm. OP-2104.004, Shutdown Cooling System, provides operators guidance for initial flow based on historical operations. The procedure recommends a total initial flow of approximately 4000 gpm, with approximately 1500 gpm of this flow passing through the SDC heat exchanger (i.e., only 1500 gpm is expected to be needed to remove decay heat).

The CS pump, although rarely utilized for SDC, is also tested as if required for ESF standby in accordance with procedure OP-2014.005, Containment Spray, similar to the LPSI pump. As shown in the above simplified diagram, the CS pump recirculates water using the LPSI injection paths. OP-2104.004 provides guidance for using either the LPSI or CS pump for SDC operations.

System procedures also provide detailed guidance with respect to proper system venting to ensure concerns stated in Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems, are appropriately addressed.

Summary The ANO-2 IST test requirements for the SDC system are well beyond those required by the standard TSs. For SDC, NUREG 1432, Revision 4, requires verification that a train is in service with no stated flow criteria and verification of proper breaker alignment (to ensure both trains remain available), with the exception of standard TS 3.9.4 (SDC - High Water Level), which states a bracketed (site-specific) minimum flow requirement.

to 2CAN121601 Page 5 of 5 In addition, the requested adoption of TSTF-545 does not change any IST or code program requirement. The change to the subject ANO-2 SRs only capitalized the terms INSERVICE TESTING PROGRAM since all TS defined terms are required to be capitalized throughout the TSs. No change to the actual testing requirements for either SR has been proposed.

Based on the testing of SDC system components performed in accordance with the ANO Unit 2 IST program described above, which far exceed the SRs contained in standard TSs, the ANO program effectively ensures SDC operability for the various required modes of operation.

Therefore, Entergy believes the proposed changes to the subject SRs are acceptable and meet the intent of TSTF-545.

References

1. Entergy letter dated March 25, 2016, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code

- Arkansas Nuclear One, Unit 2, (2CAN031602) (ML16088A186)

2. NRC email dated November 10, 2016, Request for Additional Information - License Amendment Request for Adoption of TSTF-545, TS Inservice Testing Program & Clarify SR Usage Rule Application to Section 5.5 (2CNA111601) (ML16326A007)

3. NRC letter dated March 4, 1982, Amendment 29 to Facility Operating License NPF-6, Arkansas Nuclear One, Unit 2 (2CNA038203) (ML021490419)

4. NRC letter dated June 11, 1980, Request to all PWRs to amend the Technical Specifications (TSs) for each facility with respect to reactor decay heat removal capability (0CNA068050)

5. NRC letter dated September 24, 2001, Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment RE: Technical Specification 4.0.5 Transfer and Modification (2CNA090101)

(ML012690588)

6. Entergy letter dated March 25, 2010, Inservice Testing Plan for the Fourth 10-Year Interval

- Arkansas Nuclear One, Unit 2 (2CAN031006) (ML100880262)

7. NRC letter dated August 10, 2009, Arkansas Nuclear One - Unit 2 - Request for Relief for the Fourth 10-Year Interval Inservice Testing Program, PRR-ANO2-2009-1 (2CNA080902)

(ML091801039)

Attachment 2 2CAN121601 Supporting Program/Procedure Excerpts

ANO Unit 2 IST Plan PROGRAM SECTION NO. SEP-ANO-2-IST-2 REVISION NO. 2 PAGE: 6 OF 72 Introduction This 10CFR 50.55a Inservice Testing (IST) Plan, hereafter referred to as the IST Plan, is for Arkansas Nuclear One Unit 2 (ANO-2).

The IST Plan is designed to contain the information necessary to identify the pumps and valves subject to IST, categorization of components, identification of tests to be performed and the frequencies of those tests. It also provides relief requests, justifications for cold shutdown and refueling testing, and positions taken with respect to the prescribed testing in 10 CFR 50.55a.

The IST Plan is just one part of the ANO Unit 2 IST Program; other parts include:

o Site Program Section No. SEP-ANO-2-IST-1, ANO Unit 2 IST Bases Document: Primarily used to document the component function reviews performed to determine those components that are subject to IST.

o Site Program Section No. SEP-ANO-2-IST-3, ANO Unit 2 IST Cross-Reference Document: Primarily used to provide identification of the implementing test procedure for each of the tests listed in the IST Plan.

o Program Section No. CEP-IST-4, Standard on IST: Primarily used to provide the consolidated and standardized technical requirements, including Entergy positions, for compliance with the regulatory requirements governing pump and valve IST.

o ANO Unit 2 IST Program Files: Defined as all of the elements (Microsoft Word files and Microsoft Access databases) used to produce the IST Program.

The IST Plan is controlled and implemented in accordance with NMM Procedure EN-DC-332, Inservice Testing and NMM Procedure EN-DC-174, Engineering Program Sections. Program Change Notices (PCNs), which may be used to request changes to this IST Plan, are initiated and processed per EN-DC-174.

This document constitutes the IST Plan for that plant. This document contains the following information:

o Valve Relief Requests and Valve Position Statements o Pump Relief Requests and Pump Position Statements o Cold Shutdown Justifications, Refueling Outage Justifications, and Check Valve Condition Monitoring Justifications, as applicable o Valve Summary Listings o Pump Summary Listings This IST plan meets the rules in set forth in the applicable ASME Code as required by 10CFR50.55a. The applicable ASME Codes are based on the start of the 10-Year Intervals, unless an alternative is specifically approved otherwise.

The current 10-Year Intervals for ANO Unit 2 is as noted below:

10-Year Interval Dates and References Site Interval Start Date End Date Reference ANO-2 Fourth 3-26-2010 3-25-2020 Letter (2CAN031006) dated 3-25-2010 For the ANO-2 IST Plan, the applicable Code is the ASME OM Code-2004 Edition with no addenda.

The term the Code is used in this plan to call out both of these sets of rules. Where necessary, OM-2004 will be listed at the bottom of a page or specially called out to indicate that a section is only applicable to a specific Code.

IST PLAN PROGRAM SECTION NO.: CEP-IST-2 ANO-2 APPENDIX REVISION: 313 PAGE: 11 OF 17 PUMP RELIEF REQUESTS (PRR) 10 CFR 50.55a Request Number PRR-ANO2-2009-1 REASON FOR The ANO-2 LPSI pumps (and motors) are located in areas which are both RELIEF radiation areas and contamination areas. Dose rates for these locations REQUEST: vary depending upon the current location of radiological hot spots. This (cont:) results in ALARA issues as well as contamination control issues to obtain quarterly vibration data.

In addition to the areas being radiological concerns, the areas are also difficult to access and require the use of a ladder to access the top of the LPSI pump motors to monitor upper motor vibration as required on a quarterly basis for Group A vertical line shaft pumps. Personnel safety is compromised because personnel must lean from the ladder to access the upper motor vibration points, resulting in personnel safety issues to acquire this vibration data.

On this basis, we feel that an acceptable level of quality and nuclear safety is still maintained while many of the burdens, costs and concerns associated with quarterly vibration testing, including both ALARA and personnel safety issues, would be eliminated by categorizing the ANO-2 LPSI pumps as Category B during Modes 1-4, and as Category A during Modes 5-6 as was approved for the Calvert Cliffs Nuclear Power Plant by Safety Evaluation dated June 18, 2008.

With the LPSI pumps categorized as Group B during Modes 1-4, the two minute minimum pump run time for quarterly tests is also eliminated.

Elimination of the minimum pump run time requirement and the requirement to record vibration levels will reduce the pump run time required for each quarterly test. This will help reduce the cumulative run time for each LPSI pump under low flow conditions to support testing, with a commensurate reduction in pump wear.

PROPOSED Perform inservice testing of the LPSI Pumps per the 2004 Edition of the ALTERNATIVE OM Code Subsection ISTB, "Inservice Testing of Pumps in Light-Water AND BASIS: Reactor Power Plants," with the following modifications:

LPSI Pump Group Classification - The LPSI pumps will be tested as stand-by pumps (Group B) during Modes 1-4 and continuously or routinely operated pumps (Group A) during Modes 5-6.

Based upon the determination that the proposed alternative to the ASME OM Code-2004 Edition requirements would provide an acceptable level of quality and safety, it is requested that the alternative be granted pursuant to 10 CFR 50.55a(a)(3)(i).

IST CROSS-REFERENCE DOCUMENT PROGRAM SECTION NO. SEP-ANO-2-IST-3 ANO UNIT 2 REVISION NO. 3 LISTING OF PROCEDURES BY PUMP PAGE 1 OF 3 Pump Procedure Frequency Test 2P-35A 2104.005, Supp. 1 or 1A dP Q 2P-35A* 2104.005, Supp. 7 or 7A dP 2Y 2104.005, Supp. 7 or 7A FR 2Y 2104.005, Supp. 7 or 7A V 2Y 2P-35B 2104.005, Supp. 2 or 2A dP Q 2P-35B* 2104.005, Supp. 8 or 8A dP 2Y 2104.005, Supp. 8 or 8A FR 2Y 2104.005, Supp. 8 or 8A V 2Y 2P-36A 2104.002, Supp. 1 FR Q 2104.002, Supp. 1 Pd Q 2104.002, Supp. 1 V Q 2P-36A* 2104.002, Supp. 10 FR 2Y 2104.002, Supp. 10 Pd 2Y 2104.002, Supp. 10 V 2Y 2P-36B 2104.002, Supp. 2 FR Q 2104.002, Supp. 2 Pd Q 2104.002, Supp. 2 V Q 2P-36B* 2104.002, Supp 11 FR 2Y 2104.002, Supp 11 Pd 2Y 2104.002, Supp 11 V 2Y 2P-36C 2104.002, Supp. 3 FR Q 2104.002, Supp. 3 Pd Q 2104.002, Supp. 3 V Q 2P-36C* 2104.002, Supp12 FR 2Y 2104.002, Supp12 Pd 2Y 2104.002, Supp12 V 2Y 2P-39A 2104.003, Supp. 1 (Q) and 2305.006, Supp. 2 (CS) dP Q 2104.003, Supp. 1 (Q) and 2305.006, Supp. 2 (CS) FR Q 2104.003, Supp. 1 (Q) and 2305.006, Supp. 2 (CS) V Q 2P-39A* 2305.006, Supp. 2 dP 2Y 2305.006, Supp. 2 FR 2Y 2305.006, Supp. 2 V 2Y 2P-39B 2104.003, Supp. 2 (Q) and 2305.006, Supp. 2 (CS) dP Q 2104.003, Supp. 2 (Q) and 2305.006, Supp. 2 (CS) FR Q 2104.003, Supp. 2 (Q) and 2305.006, Supp. 2 (CS) V Q 2P-39B* 2305.006, Supp. 2 dP 2Y 2305.006, Supp. 2 FR 2Y 2305.006, Supp. 2 V 2Y 2P-4A 2104.029, Supp. 1A dP Q 2104.029, Supp. 1A FR Q 2104.029, Supp. 1A V Q 2P-4A* 2104.029, Supp. 8A dP 2Y 2104.029, Supp. 8A FR 2Y 2104.029, Supp. 8A V 2Y See IST Plan for explanation of designations used above for Test and Frequency data; Second pump listing (*) is for Comprehensive Test

IST CROSS-REFERENCE DOCUMENT PROGRAM SECTION NO. SEP-ANO-2-IST-3 ANO UNIT 2 REVISION NO. 3 LISTING OF PROCEDURES BY PUMP PAGE 2 OF 3 Pump Procedure Frequency Test 2P-4B 2104.029, Supp. 1B dP Q 2104.029, Supp. 1B FR Q 2104.029, Supp. 1B V Q 2P-4B* 2104.029, Supp. 8B dP 2Y 2104.029, Supp. 8B FR 2Y 2104.029, Supp. 8B V 2Y 2P-4C 2104.029, Supp. 1C dP Q 2104.029, Supp. 1C FR Q 2104.029, Supp. 1C V Q 2P-4C* 2104.029, Supp. 8C dP 2Y 2104.029, Supp. 8C FR 2Y 2104.029, Supp. 8C V 2Y 2P-60A 2104.040, Supp. 1 or 1A (Q) and Supp. 8A (CS) dP Q 2104.040, Supp. 1 or 1A (Q) and Supp. 8A (CS) V Q 2104.040, Supp. 8A (CS) FR Q 2P-60A* 2104.040, Supp. 8A dP 2Y 2104.040, Supp. 8A FR 2Y 2104.040, Supp. 8A V 2Y 2P-60B 2104.040, Supp. 2 or 2A (Q) and Supp. 8B (CS) dP Q 2104.040, Supp. 2 or 2A (Q) and Supp. 8B (CS) V Q 2104.040, Supp. 8B (CS) FR Q 2P-60B* 2104.040, Supp. 8B dP 2Y 2104.040, Supp. 8B FR 2Y 2104.040, Supp. 8B V 2Y 2P-7A 2106.006, Supp. 1 dP Q 2106.006, Supp. 1 FR Q 2106.006, Supp. 1 S Q 2P-7A* 2106.006, Supp. 11 dP 2Y 2106.006, Supp. 11 FR 2Y 2106.006, Supp. 11 S 2Y 2106.006, Supp. 11 V 2Y 2P-7B 2106.006, Supp. 2 dP Q 2106.006, Supp. 2 FR Q 2P-7B* 2106.006, Supp. 12 dP 2Y 2106.006, Supp. 12 FR 2Y 2106.006, Supp. 12 V 2Y 2P-89A 2104.039, Supp. 1(Q) and Supp. 6 (CS) dP Q 2P-89A* 2104.039, Supp. 6 dP 2Y 2104.039, Supp. 6 FR 2Y 2104.039, Supp. 6 V 2Y 2P-89B 2104.039, Supp. 2(Q) and Supp. 6 (CS) dP Q 2P-89B* 2104.039, Supp. 6 dP 2Y 2104.039, Supp. 6 FR 2Y 2104.039, Supp. 6 V 2Y See IST Plan for explanation of designations used above for Test and Frequency data; Second pump listing (*) is for Comprehensive Test

PROC./WORK PLAN N

O. PROCEDURE

/WORK PLAN TITLE: PAGE: 72 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 1 PAGE 1 OF 8 2P-60A QUARTERLY TEST This supplement tests LPSI Pump (2P-60A) IAW Tech Specs 4.5.2.f.2 and In-service Test (IST) Program.

This supplement performed anytime Shutdown Cooling is secured.

Supplement 1A performed when SDC in service.

This test meets requirements for Group B In-Service Test during plant Modes 1-4 only.

Supplement 8A shall be performed during the following plant conditions:

Mode 5, if plant conditions allow Mode 6 NOTE LPSI pump (2P-60A) is periodically tested IAW ESF Response Time Test (2305.003), Attachment H, Acceleration Times for ESF Pumps and Fans.

1.0 INITIAL CONDITIONS LPSI System aligned IAW System Alignment Verification section of Conduct of Operations (1015.001).

Containment Spray System aligned IAW System Alignment Verification section of Conduct of Operations (1015.001).

Document known, quantifiable LPSI Pump 2P-60A oil leaks under Comments in Section 3.0.

• IF new oil leak identified or known oil leak rises, THEN submit a WR/CR and document under Comments in Section 3.0.

• IF anytime during performance of this Supplement a temporary test gauge is needed in place of permanently installed gauge, THEN verify the following:

- Test gauge calibration date current.

- Accuracy of test gauge within +/- 1% of full scale.

- Range of test gauge less than three times normal process value.

- Test gauge number recorded in TEST INST column of Section 3.0.

- Operator remains in area while gauge aligned for use.

- SM notified to enter TS 3.5.2 when gauge aligned.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 73 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 1 PAGE 2 OF 8 2.0 TEST METHOD NOTE Steps 2.1 through 2.4 may be performed in any order.

2.1 Verify the following valves open:

RWT Recirc and Test Line Inlet To RWT (2BS-26)

ESF Mini-Recirc Header Isol 2CV-5628-2 (2HS-5628-2)

LPSI 2P-60A Recirc Isolation 2CV-5123-1 (2HS-5123-1)

RWT Outlet 2CV-5630-1 (2HS-5630-1)

SW ESF Header Isol 2CV-1400-1 (2HS-1400-1)

LPSI Pump 2P-60A Clr 2E-52A SW Inlet 2CV-1445-1 (2HS-1445-1) 2.2 Verify the following for at least TWO available SDC HX Room Coolers:

2VUC-1A Unit secured (2HS-8447-1)

Handswitch (2HS-8447-1) in NORMAL AFTER STOP 2VUC-1B Unit secured (2HS-8449-1)

Handswitch (2HS-8449-1) in NORMAL AFTER STOP 2VUC-1C Unit secured (2HS-8451-1)

Handswitch (2HS-8451-1) in NORMAL AFTER STOP NOTE If any oil level indicated in sight glass, LPSI pump 2P-60A is operable.

2.3 Check LPSI pump 2P-60A upper motor bearing sight glass oil level as follows:

IF sight glass level less than 1/4 full, THEN submit WR/WO to add.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 75 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 1 PAGE 4 OF 8 2.10 Isolate LPSI pump (2P-60A) pressure gauges as follows:

• 2.10.1 IF vibration data required, THEN coordinate with person collecting vibration data to isolate gauges.

2.10.2 IF Supplement 7A being performed in conjunction with this Supplement, THEN verify 2P-60A Disch Press (2PI-5041) isolated as follows:

A. Close 2P-60A Discharge Drain and 2PI-5041 Isol (2SI-1035A).

B. Close 2P-60A Discharge Drain and 2PI-5041 Isol (2SI-1034A).

2.10.3 IF desired to isolate 2P-60A pressure gauges, THEN verify the following valves closed:

A. LPSI 2P-60A Suction 2PI-5039 (2SI-5039C)

B. LPSI 2P-60A Suction 2PI-5039 (2SI-5039B)

C. 2P-60A Discharge Drain and 2PI-5041 Isol (2SI-1035A)

D. 2P-60A Discharge Drain and 2PI-5041 Isol (2SI-1034A) 2.11 Check LPSI pump (2P-60A) mechanical seal leakage as follows:

2.11.1 Verify the following valves open:

LPSI 2P-60A Mech Seal Telltale Drain (2SI-1010A)

LPSI 2P-60A Mech Seal Telltale Drain (2SI-1011A) 2.11.2 Record Seal Leakoff Rate. _________ dpm.

2.11.3 IF seal leakage 10 dpm, THEN initiate WR/WO to repair mechanical seal.

2.11.4 IF seal leakage greater than 17 dpm, THEN initiate Condition Report to evaluate leakage.

2.12 Inspect pump seals, valve packing, and flange gaskets in A ESF room for atmospheric leakage.

2.12.1 Record any discrepancies under Comments in Section 3.0.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 76 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 1 PAGE 5 OF 8 2.13 IF Supplement 7A is being performed in conjunction with this supplement, THEN GO TO Supplement 7A.

2.14 WHEN data collection and inspection complete, THEN verify LPSI 2P-60B Discharge Stop-Check (2SI-3B) closed as follows:

2.14.1 Verify LPSI 2P-60B Suction 2PI-5058 (2SI-5058B) open.

2.14.2 Open LPSI 2P-60B Suction 2PI-5058 (2SI-5058A).

2.14.3 Open LPSI 2P-60B Suction 2PI-5058 (2SI-5058C).

2.14.4 Record 2P-60B suction pressure (2PI-5058). ________ psig 2.14.5 Complete Table 2 for LPSI 2P-60B Discharge Stop-Check (2SI-3B).

2.14.6 Close LPSI 2P-60B Suction 2PI-5058 (2SI-5058C).

2.14.7 Close LPSI 2P-60B Suction 2PI-5058 (2SI-5058A).

2.15 Stop LPSI pump (2P-60A) (2HS-5018-1).

2.15.1 IF LPSI pump (2P-60B) in service, THEN verify LPSI 2P-60A Discharge Stop-Check (2SI-3A) closed by checking LPSI pump 2P-60A NOT rotating backwards.

2.16 IF ALL pressure gauges NOT previously isolated in step 2.10, THEN verify applicable gauges isolated as follows:

2.16.1 LPSI 2P-60A Suction 2PI-5039 (2SI-5039C) closed.

2.16.2 LPSI 2P-60A Suction 2PI-5039 (2SI-5039B) closed.

2.16.3 2P-60A Disch Drain and 2PI-5041 Isol (2SI-1035A) closed.

2.16.4 2P-60A Disch Drain and 2PI-5041 Isol (2SI-1034A) closed.

2.17 IF temporary test gauge used, THEN verify the following:

Gauge isolated Gauge removed Notify SM that TS 3.5.2/3.5.3 may be exited.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 78 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 1 PAGE 7 OF 8 3.0 ACCEPTANCE CRITERIA 3.1 Record values AND compare to LIMITING RANGE FOR OPERABILITY. Do NOT use 2PI-5092 to determine pump operability due to string accuracy of

+/- 1.5%.

TABLE 1 INSTRUMENT LIMITING IS DATA IN MEASURED TEST QUANTITY (INCLUDE RANGE FOR LIMITING VALUE TEST INST) OPERABILITY RANGE?

Running Suction 2PI-5039 Pressure (local) psig 12 psig YES NO 2PI-5041 Discharge (local) psig N/A N/A 2PI-5092 Pressure psig N/A N/A (2C17) 2TIS-5675 RWT Temperature (2C17) F 40 to 110F N/A 2PI-5041 _____(1) to Pump P -2PI-5039 psid 190.8 psid YES NO Note 1: For RWT temperature (T), minimum acceptable pump P is (CALC-93-E-0037-01 Rev 01):

158 + 2.405 (Instrument error) -[(T-40)/28.6] psid Minimum P = 160.405 -[(______ -40)/28.6] = ________ psid Performed By: ___________________________________

3.2 Independently verify pump P calculation.

IV Performed By: ___________________________________

TABLE 2 CHECK VALVE TEST TEST CRITERIA IS PROPER VALVE DIRECTION STROKE INDICATED?

2SI-3B Closed Suction pressure < 50 psig YES NO 3.3 IF NO circled in Table 1 or 2, THEN perform the following:

Notify Shift Manager.

Declare affected component inoperable.

Refer to Tech Specs 3.5.2.

Initiate WR/WO.

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 104 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 3A RED PAGE 1 OF 12 QUARTERLY RED TRAIN LPSI & RWT VALVE STROKE TEST WITH SDC SECURED Test measures LPSI/SDC motor-operated valve stroke times and compares with limits established in accordance with In-service Test (IST) Program.

Test satisfies In-service Test (IST) Program requirements by verifying Safety Injection Check valves (2SI-14A/B) are closed.

Supplement includes valves that can be stroked during normal power operation without placing plant in an unsafe configuration.

Stroke times are recorded to nearest tenth second.

1.0 INITIAL CONDITIONS Plant in Mode 1, 2 or 3.

Two operable LPSI and Containment Spray pumps.

All HPSI, LPSI, and Containment Spray pumps secured.

Currently calibrated Stopwatch Serial No. ___________.

All SIT check valve leakage pressure indicators on 2C16 AND 2C17 less than 700 psig. Refer to Safety Injection Tank Operations (2104.001):

- 2T-2A (2PIS-5000)

- 2T-2B (2PIS-5020)

- 2T-2C (2PIS-5040)

- 2T-2D (2PIS-5060)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 150 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 6 PAGE 1 OF 5 INTERLOCK TEST OF SDC SYSTEM Supplement verifies the following per TRM 4.3.5:

2K07-E7 (SDC ISOL VLV MISPOS/FAILURE) alarms when SDC RC Isolation valves (2CV-5084-1 and 2CV-5086-2) are open and RCS pressure is greater than 350 psia.

Interlock action prevents opening SDC RC Isolation valves when RCS pressure is 350 psia.

I&C test procedure 2304.200/2304.201 verifies proper setpoint of actuating pressure switches. This supplement tests remainder of circuitry including auxiliary relays.

1.0 INITIAL CONDITIONS (May be performed in any order) 1.1 Plant in Mode 4, 5, 6 or defueled.

1.2 Reactor Coolant System pressure less than 300 psia.

1.3 Reactor Coolant System temperature less than 300°F.

1.4 Shutdown Cooling System secured.

1.5 Each of the following SIT Outlet Valve breakers open:

SIT 2T-2A Outlet 2CV-5003-1 breaker (2B51-F2)

SIT 2T-2B Outlet 2CV-5023-1 breaker (2B51-H1)

SIT 2T-2C Outlet 2CV-5043-2 breaker (2B61-F2)

SIT 2T-2D Outlet 2CV-5063-2 breaker (2B61-H1)

PROC./WORK PLAN NO. PROCEDURE/WORK PLAN TITLE: PAGE: 163 of 188 2104.040 LPSI SYSTEM OPERATIONS CHANGE: 069 SUPPLEMENT 8A PAGE 1 OF 13 LPSI PUMP (2P-60A) FULL FLOW TEST (SHUTDOWN)

Test performed while on Shutdown Cooling to meet requirements of In-service Test (IST) Program for Comprehensive Test and Group A Test.

During refueling outage, needed data collected to confirm LPSI System flow balance per Tech Spec 4.5.2.h.

Test provides trigger to perform LPSI Injection Valve Limit Verifications (1015.016K) to satisfy Tech Spec 4.5.2.g and tests one 2SI-15 check valve as required by Component Engineering.

SDC flow directed through individual LPSI headers to verify LPSI 2P-60A Discharge Stop-Check (2SI-3A) and SI Check valves (2SI-14A/B) fully open and SI Checks (2SI-15A/B) partially open.

Test required to be performed during shutdown of sufficient duration when more than 92 days have elapsed since last performed.

1.0 INITIAL CONDITIONS (May be performed in any order) 1.1 Shutdown Cooling aligned IAW applicable section of Shutdown Cooling System (2104.004).

1.2 RCS NOT in Lowered Inventory IAW Unit 2 SDC Control (1015.008).

1.3 RCS level greater than minimum required IAW Draining the Reactor Coolant System (2103.011), Exhibit 1.

1.4 IF test performed during refueling outage, THEN Notify System Engineer to install ultrasonic flow measuring device to measure LPSI pump (2P-60A) recirc flow.

Serial No. ______________ Calibration Due Date ______________

1.5 Predictive Maintenance or SE/STA available to take vibration data.

1.6 IF test performed during refueling outage, AND required by Component Engineering to perform check valve test for the following valves:

2T-2C to 2P-32C Check (2SI-15C) test ____ YES _____ NO 2T-2D to 2P-32D Check (2SI-15D) test ____ YES _____ NO THEN request Component Engineering to install test equipment.

1.6.1 Component Engineering acknowledges need to perform test.

Component Engineering: ____________________ Date: _______

PAGE: 5 of 149 2104.004 SHUTDOWN COOLING SYSTEM CHANGE: 058 5.0 LIMITS AND PRECAUTIONS 5.1 Maximum LPSI and SDC System suction piping temperature is 300°F.

5.2 Auxiliary Building radiation levels can change during alignment for different Shutdown Cooling System evolutions (i.e. placing SDC in service, removing SDC from service, modifying SDC purification flow, swapping SDC trains, etc.). (CR-AN0-2-1998-0469) 5.3 Containment Spray pumps operating on SDC require SDC suction pressure to be maintained less than 50 psig at 2PIS-5088 to prevent over pressurization of Containment Sump/RWT suction piping.

5.4 The maximum SDC suction pressure for LPSI Pump Suction Pressure transmitters 2PT-5039 and 2PT-5058 is 50 psig.

5.5 SDC pump Motor starts are limited to two starts in succession from ambient or one start from rated temperature. For subsequent starts, allow 30 minutes run time or 60 minutes idle time.

5.6 RCS level less than 65 inches above bottom of hot leg require operating only one SDC pump at a time to prevent high flow rates and subsequent vortexing. (Two pumps may be in operation while shifting SDC pumps.)

5.7 Minimum SDC flow of 2000 gpm must be maintained except as allowed by Tech Specs. Instrument inaccuracies are not included due to large conservative margins in Tech Spec Bases. (CR-ANO-2-1998-0230) 5.8 In Mode 5, SDC flow may be stopped for up to one hour provided:

No operations permitted that could cause RCS dilution.

Core outlet temperature Margin to Sat maintained at greater than or equal to 10°F.

5.9 In Mode 6, SDC flow may be stopped for up to one hour every eight hours during performance of Core Alterations, otherwise refer to TS 3.9.8.1.

5.10 Service Water flow through SDC Heat Exchangers (2E-35A/B) must be established before initially placing SDC in service.

5.11 If LPSI Pump Discharge temperature (T5096) less than 198°F, Service Water flow through heat exchanger may be secured as necessary to limit cooldown or to allow slow heatup to 198°F (T5096).

5.12 LPSI Pump Discharge temperature (T5096) limit of 198°F is based on SDC HX Service Water outlet piping design temperature limit of 198°F.

5.13 If SDC HX SW flow isolated with RCS aligned, SW is reintroduced slowly to limit thermal stresses by maintaining cooldown rate less than 8°F/minute to prevent exceeding SDC HX cooldown limit of 520°F/hr.

PAGE: 20 of 149 2104.004 SHUTDOWN COOLING SYSTEM CHANGE: 058 8.14 IF desired to place BOTH LPSI pumps in service for SDC, THEN PLACE the second LPSI pump in service per Operation of LPSI Pumps/SDC HXs in Parallel for Shutdown Cooling section of this procedure.

NOTE With low Service Water temperatures, lowering Service Water flow to the in-service SDC Heat Exchanger allows better control of SDC Temperature Control Valve (2CV-5093). For example, during the fall forced outage of 2013, SW flow was throttled to 1200 gpm which sent more flow through 2CV-5093 allowing better SDC temperature control.

8.15 IF desired to lower Service Water flow to the in-service SDC HX, THEN PERFORM Service Water Operation Through SDC HX section of this procedure.

8.16 ENSURE SDC HX Tube Side flow (F5610/F5616) within the following limits:

Acceptable limits of Attachment K, SDC Heat Exchanger RCS Flow Limit Curves with RCS Tc greater than or equal to 239°F but less than or equal to 300°F Less than 5320 gpm with RCS Tc less than 239°F NOTE Historical data indicates total flow should be adjusted to 4,000 gpm with 1,500 gpm through the SDC HX, and then adjusted to maximize cooldown rate within Tech Spec limits (goal is 90°F/hour).

Remaining steps may be performed in any order.

CRITICAL STEP 8.17 COMMENCE raising SDC Heat Exchanger flow using Hx Return Flow (2HIC-5093) to maintain RCS cooldown rate within limits of TS 3.4.9.1.

{4.2.6} 8.18 ENSURE the following on LPSI Discharge Header Flow controller (2FIC-5091):

SDC Flow (F5610/F5616) in Acceptable Region of 2103.011, Exhibit 1, SDC Vortex Curve High alarm setpoint within 300 gpm of actual flow (preferred) or as close as possible to actual flow if alarm setpoint cannot be adjusted to within 300 gpm Low alarm setpoint within 300 gpm of actual flow (preferred) or as close as possible to actual flow if alarm setpoint cannot be adjusted to within 300 gpm Low alarm setpoint greater than 2100 gpm

PAGE: 89 of 209 2104.005 CONTAINMENT SPRAY CHANGE: 076 SUPPLEMENT 1 PAGE 1 OF 11 2P-35A QUARTERLY TEST (SDC NOT ALIGNED)

This supplement is performed IAW PMRQ/PMID 50016233 and tests the following:

Demonstrates operability of Containment Spray pump (2P-35A) and associated check valves IAW TS 4.6.2.1 and Group B IST testing.

Ensures RWT Outlet to B ESF Suction Header (2BS-1B) closes when suction header is pressurized through ESF recirc header via HPSI mini-mini recirc header.

1.0 INITIAL CONDITIONS (May be performed in any order) 1.1 ENSURE CSS aligned IAW System Alignment Verification section of 1015.001, Conduct of Operations.

1.2 ENSURE LPSI System aligned IAW System Alignment Verification section of 1015.001, Conduct of Operations.

1.3 IF last scheduled test before Refueling Outage, THEN:

1.3.1 CONTACT Component Engineer to determine if RWT Outlet to A ESF Suction Header (2BS-1A) will be tested during this surveillance.

1.3.2 IF 2BS-1A testing to be performed during this surveillance, THEN NOTIFY Component Engineer to set up to perform non-intrusive testing of 2BS-1A partial open stroke.

1.3.3 IF 2BS-1A testing will NOT be performed during this surveillance, THEN CIRCLE N/A in Table 1.

1.4 ENSURE the following valves closed:

Spray Header #1 Isolation 2CV-5612-1 (2HS-5612-1)

Spray Header #2 Isolation 2CV-5613-2 (2HS-5613-2)

PAGE: 97 of 209 2104.005 CONTAINMENT SPRAY CHANGE: 076 SUPPLEMENT 1 PAGE 9 OF 11 3.0 ACCEPTANCE CRITERIA 3.1 RECORD values observed during 2P-35A operation and COMPARE against Limiting Range for Operability.

3.2 IF 2BS-1A NOT tested, THEN CIRCLE N/A in Table 1.

TABLE 1 TEST QUANTITY INSTRUMENT MEASURED ACCEPTABLE LIMITING IS DATA IN (INCLUDE VALUE NORMAL RANGE FOR LIMITING TEST INST.) RANGE OPERABILITY RANGE?

Running Suction 2PI-5677 psig N/A > 6 psig YES NO Pressure (local) 2PI-5678 psig N/A N/A N/A Discharge (local)

Pressure 2PI-5622 psig N/A N/A N/A (2C17) 2PI-5678 - 214 to Pump P psid N/A YES NO 2PI-5677 245.8 psid 2FIS-5610 2225 to 2315 Flow (1) gpm 2225 gpm YES NO (2C17) gpm Motor Running A ________ amps Amps Ammeter at B ________ amps N/A N/A N/A 2A-304 CR-1-96-0272-07 C ________ amps 2BS-4A Position N/A ( ) if Closed N/A Closed YES NO Partial Open

( ) if Partial Open 2BS-1A per YES NO N/A per Component N/A Partial Open Test Component N/A Engineer Engineer P5058 Initial N/A N/A N/A 2BS-1B Closure P5058 Final N/A N/A N/A

{4.2.4}

Final - Initial N/A > 4 psid YES NO (1) Greater than or equal to 2225 gpm checks partial stroke of 2BS-1A, and full stroke of 2BS-3A and 2BS-4A. {4.2.2}