Text

Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Revision 2
	ML20024E597
Person / Time
Site:	Grand Gulf, River Bend
Issue date:	01/24/2020
From:	Gaston R; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNRO-2020-00006
	Download: ML20024E597 (62)
	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 CNRO-2020-00006 January 24, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 In accordance with Title 10 of the Code of Federal Regulations (CFR) Part 50, Section 50.90, "Application for amendment of license, construction permit, or early site permit," Entergy Operations, Inc. (Entergy) hereby requests an amendment to Renewed Facility Operating License, Appendix A, "Technical Specifications" (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS).

The proposed change adopts Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO,"

Revision 2 into the GGNS TS and RBS TS.

The enclosure to this letter provides a description and assessment of the proposed changes and is based on the information provided in TSTF-439. Attachments 1.a and 1.b to the enclosure provide the existing TS pages for GGNS and RBS, respectively, marked-up to show the proposed changes. Attachments 2.a and 2.b provide revised (clean) TS pages for GGNS and RBS, respectively. Attachments 3.a and 3.b provide, for information only, marked up versions of existing GGNS and RBS TS Bases pages to show the proposed changes.

Entergy requests approval of the proposed license amendment by February 24, 2021. Once approved, the amendment will be implemented within 90 days of issuance of the amendment.

CNR0-2020-00006 Page 2 of 2 This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact Ron Gaston, Director, Nuclear Licensing, at 601-368-5138.

In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

I declare under penalty of perjury; the foregoing is true and correct. Executed on January 24, 2020.

Ron Gaston RWG/rrn/jls

Enclosure:

Description and Assessment of the Proposed Changes Attachments to

Enclosure:

1.a.

Markup of Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1.

1.b.

Markup of Technical Specification (TS) Pages, River Bend Station, Unit 1.

2.a.

Clean Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1.

2.b.

Clean Technical Specification (TS) Pages, River Bend Station, Unit 1.

3.a.

Markup of Technical Specification (TS) Bases Pages, For Information Only, Grand Gulf Nuclear Station, Unit 1.

3.b.

Markup of Technical Specification (TS) Bases Pages, For Information Only, River Bend Station, Unit 1.

cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - Grand Gulf Nuclear Station, Unit 1 NRC Senior Resident Inspector - River Bend Station, Unit 1 State Health Officer, Mississippi Department of Health Louisiana Department of Environmental Quality NRC Project Manager - Entergy Fleet NRC Project Manager - Grand Gulf Nuclear Station, Unit 1 NRC Project Manager - River Bend Station, Unit 1

Enclosure CNRO-2020-00006 Description and Assessment of the Proposed Changes Application to Revise Technical Specifications to Adopt TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2 Grand Gulf Nuclear Station, Unit 1 River Bend Station, Unit 1 (8 Pages) 1.0 Summary Description 2.0 Assessment 2.1 Proposed Changes 2.2 Variations 2.3 Technical Evaluation 3.0 Regulatory Analysis 3.1 Applicable Regulatory Requirements/Criteria 3.2 Precedent 3.3 No Significant Hazards Consideration Analysis 4.0 Environmental Consideration 5.0 References

Enclosure CNRO-2020-00006 Page 1 of 8 1.0

SUMMARY

DESCRIPTION Entergy Operations, Inc. (Entergy) requests adoption Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2,which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Grand Gulf Nuclear Station, Unit 1 (GGNS) and River Bend Station, Unit 1 (RBS) Technical Specifications (TS).

In previous versions of the Improved Standard Technical Specifications (i.e., NUREG-1430 through NUREG-1434) (ISTS) a second completion time was included for certain required actions to establish a limit on the maximum time allowed for any combination of conditions that result in a single continuous failure to meet the limiting condition for operation (LCO). These completion times (henceforth referred to as "second completion times") are joined by an "AND" logical connector to the condition-specific completion time and state: "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second completion time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

The proposed change deletes these second completion times from the affected required actions. It also revises ISTS Example 1.3-3 to remove the second completion times and to revise the discussion in that example to state that alternating between conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The proposed change is consistent with the basis of the completion times and is appropriate.

2.0 ASSESSMENT

2.1 Proposed Change TSTF-439, Revision 2 (Reference 1), modifies Improved TS (NUREG-1434) Completion Times Example 1.3-3 to eliminate the second completion times and to replace the discussion regarding second completion times with a new discussion. TSTF-439, Revision 2, has been incorporated into NUREG-1434, Volume 1, Revision 4 (Reference 2), as identified by letter from the NRC to the TSTF (Reference 3).

Consistent with TSTF-439, Revision 2, the proposed change: (1) modifies Completion Times Example 1.3-3 to eliminate the second completion times contained within and revises the discussion in the example to state that alternating between conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the bases of the completion times, and (2) removes second completion times contained in the TS. Specifically, for GGNS: TS 3.8.1, Required Actions A.2 and B.4; and, TS 3.8.7 Required Actions A.1 and B.1; and, for RBS: TS 3.1.7, Required Actions A.1 and B.1; and, TS 3.8.1, Required Actions A.3 and C.4; and TS 3.8.9, Required Actions A.1, B.1 and C.1.

The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

Enclosure CNRO-2020-00006 Page 2 of 8 Entergy has reviewed the information provided in TSTF-439, Revision 2 and concluded that the justifications presented in TSTF-439, as accepted by the NRC letter to the TSTF (Reference 3),

are applicable to GGNS and RBS, and justify this amendment request for the incorporation of the changes to the GGNS and RBS TS.

2.2 Variations Entergy is proposing the following variations from the TS changes described in TSTF-439.

These variations do not affect the applicability of TSTF-439 to the proposed license amendments.

References in TSTF-439 to Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," and Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

have been modified to reference RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3, and NUMARC 93-01, Revision 4A. RG 1.182 was withdrawn since it was determined that the document (RG 1.182) was redundant due to the inclusion of its subject matter in Revision 3 of RG 1.160. Withdrawal of RG 1.182 was published in the Federal Register on November 27, 2012 (77 FR 70846). The Federal Register notice also stated that withdrawal of RG 1.182 neither altered any prior or existing licensing commitments based on its use, nor constituted backfitting as defined in 10 CFR 50.109 (i.e., the Backfit Rule) and was not otherwise inconsistent with the issue finality provisions in 10 CFR Part 52. Therefore, this change does not impact the applicability of TSTF-439 to the proposed amendments.

The following table shows plant-specific variations from the BWR/6 STS markups in TSTF-439 and NUREG-1434, Rev. 4 (ISTS):

Plant Variation Discussion Conclusion GGNS "from discovery" completion time is not included in TS 3.1.7, "Standby Liquid Control (SLC) System."

Therefore, no changes are proposed to TS 3.1.7.

This is plant-specific change as a result of License Amendment 190 issued on May 11, 2012 (NRC ADAMS Accession No. ML120860149).

This plant specific variation does not impact the applicability of TSTF-439 to the GGNS TS.

GGNS ISTS 3.8.1, Required Action A.3 is TS 3.8.1, Required Action A.2 in the GGNS TS.

ISTS 3.8.1, Required Action A.2 is not included in the GGNS TS. As a result, the equivalent required action for ISTS 3.8.1, Required Action A.3 is TS 3.8.1, Required Action A.2.

This plant specific variation does not impact the applicability of TSTF-439 to the GGNS TS.

Enclosure CNRO-2020-00006 Page 3 of 8 Plant Variation Discussion Conclusion GGNS The current "from discovery" completion time of TS 3.8.1, Required Actions A.2 and B.4 is 17 days instead of 6 days from discovery These are plant-specific changes as a result of License Amendment 151 issued on July 16,2002 (NRC ADAMS Accession No. ML021860203).

The justification for removal of the "from discovery" provided in TSTF-439 remains the same for these plant-specific completion times. Therefore, this change does not impact the applicability of TSTF-439 to the GGNS TS.

GGNS ISTS 3.8.9, "Distribution Systems -

Operating," is TS 3.8.7, "Distribution Systems -

Operating," in the GGNS TS and ISTS 3.8.9, Condition B is not included in the GGNS TS.

GGNS does not include specifications on inverters (ISTS 3.8.7 and 3.8.8) or requirements in LCO 3.8.7 for vital AC distribution. As a result, the equivalent GGNS specification for ISTS 3.8.9 is TS 3.8.7 and ISTS 3.8.9, Condition B for vital AC does not require removal in the GGNS TS. The equivalent required action for ISTS 3.8.1, Required Action C.1 is TS 3.8.1, Required Action B.1.

This plant specific variation does not impact the applicability of TSTF-439 to the GGNS TS.

RBS ISTS 3.8.1, Required Action B.4 is TS 3.8.1, Required Action C.4 in the RBS TS.

TS 3.8.1, Condition B is a plant specific condition not included in ISTS 3.8.1. As a result, the equivalent required action for ISTS 3.8.1, Required Action B.4 is TS 3.8.1, Required Action C.4.

This plant specific variation does not impact the applicability of TSTF-439 to the RBS TS.

RBS The current "from discovery" completion time of TS 3.8.1, Required Actions A.3 and C.4 is 17 days instead of 6 days from discovery These are plant-specific changes as a result of License Amendment 125 issued on September 25, 2002 (NRC ADAMS Accession No. ML022590314).

The justification for removal of the "from discovery" provided in TSTF-439 remains the same for these plant-specific completion times. Therefore, this change does not impact the applicability of TSTF-439 to the RBS TS.

Enclosure CNRO-2020-00006 Page 4 of 8 The justification for removal of the required actions provided in TSTF-439 remain the same for these plant-specific completion times. Therefore, this change does not impact the applicability of TSTF-439 to the RBS and GGNS TS.

2.3 Technical Evaluation As discussed in TSTF-439, Revision 2, the adoption of a second completion time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the TS. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second completion times were designed to prevent.

Maintenance Rule 10 CFR 50.65(a)(1) requires each licensee to monitor the performance or condition of structures, systems, and components (SSCs) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken.

The NRC monitors the licensee's corrective action process and could take action if the licensees maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65(a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the actions of the TS and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).

Under the TS, the completion time for one system is not affected by other inoperable equipment. The second completion times were an attempt to influence the completion time for one system based on the condition of another system, if the two systems were required by the same LCO. However, 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3 dated May 2012. Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4A, dated April 2011." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This comprehensive program provides much greater assurance of safe plant operation than the second completion times in the TS.

Enclosure CNRO-2020-00006 Page 5 of 8 Reactor Oversight Process NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by Regulatory Issue Summary 2001-11, "Voluntary Submission of Performance Indicator Data." NEI 99-02, Section 2.2, describes the mitigating systems cornerstone. NEI 99-02 specifically addresses emergency AC sources, which encompasses the AC Sources and distribution system LCOs. Extended unavailability of these systems due to multiple entries into the actions would affect the NRC's evaluation of the licensees performance under the ROP.

Administrative Control In addition to these programs, a requirement is added to Section 1.3 of the TS to require licensees to have administrative controls to limit the maximum time allowed for any combination of conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls consider plant risk and limit the maximum contiguous time of failing to meet the LCO. This TS requirement, when considered with the regulatory processes discussed herein, provide an equivalent or superior level of plant safety without the unnecessary complication of the TS by second completion times on some TS.

Furthermore, revised operational procedures that incorporate the new requirement in revised TS Example 1.3-3 (i.e., administrative controls that do not allow entry into and out of the Required Actions for an indefinite period of time without meeting the LCO) will ensure that the Completion Times for those Conditions are not inappropriately extended.

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements/Criteria The following NRC requirements are applicable to the proposed change:

The regulations of Title of the Code of Federal Regulations (10 CFR), "Technical specifications,"

establish the requirements related to the content of the TS. Section 50.36(c)(2) states:

"When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

The regulations of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," establish a performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

The proposed change continues to meet the requirements of these regulations.

Enclosure CNRO-2020-00006 Page 6 of 8 3.2 Precedent Technical Specification Task Force (TSTF) Traveler 439 was approved by the NRC and incorporated into Revision 3.1 of the Improved Standard Technical Specification (ISTS)

NUREGs, (i.e., NUREG-1430 through NUREG-1434), which was also approved by the NRC.

The NRC has approved the adoption of TSTF-439 for other licensees, including:

1. Prairie Island Nuclear Generating Plant, Units 1 and 2, License Amendments No. 227 and 215 (NRC ADAMS Accession No. ML19128A133);

2. Peach Bottom Atomic Power Station, Units 2 and 3, License Amendments 277 and 280 (NRC ADAMS Accession No. ML101940378);

3. Susquehanna Steam Electric Station, Units 1 and 2, License Amendments Nos. 273 and 255 (NRC ADAMS Accession No. ML19155A264);

4. Palo Verde Nuclear Generating Station Units 1, 2 and 3, License Amendments Nos.

197, 197 and 197 (NRC ADAMS Accession No. ML16004A013); and

5. Nine Mile Point Nuclear Station, Unit 2, License Amendment No. 159 (NRC ADAMS Accession No. ML16281A596).

3.3 No Significant Hazards Consideration Analysis Entergy Operations Inc. (Entergy) requests adoption of Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2, which is an approved change to the Improved Standard Technical Specifications (ISTS), into the Grand Gulf Nuclear Station, Unit 1 (GGNS) and the River Bend Station, Unit 1 (RBS) Technical Specifications (TS). The proposed change eliminates second completion times limiting time from discovery of failure to meet a limiting condition for operation (LCO). These changes are consistent with NRC approved TSTF-439, Revision 2.

Entergy has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1.

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

Response: No The proposed change eliminates second completion times from the TS. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised completion time are no different than the consequences of the same accident during the existing completion times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of structures, systems, or components from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an

Enclosure CNRO-2020-00006 Page 7 of 8 accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite nor significant increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No The proposed change does not involve a physical alteration on the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change does not alter any assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from an accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change to delete the second completion times does not alter the way safety limits, limiting safety system settings, or limiting conditions for operations are determined.

The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside of the design basis.

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

Based upon the reasoning presented above, Entergy concludes that the proposed change does not involve a 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 discussed 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Enclosure CNRO-2020-00006 Page 8 of 8

5.0 ENVIRONMENTAL CONSIDERATION

Entergy has determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet 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 Technical Specification Task Force (TSTF) Traveler 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," Revision 2, dated June 20, 2005 (ADAMS Accession No. ML051860296).

2 NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Rev. 4, dated April 2012.

3 Letter from Thomas H. Boyce, Technical Specifications Branch Chief (U.S Nuclear Regulatory Commission) to the Technical Specifications Task Force, "Status of TSTF 439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet An LCO," dated January 11, 2006 (ADAMS Accession No. ML060120272).

ATTACHMENTS 1.a Markup of Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1 1.b Markup of Technical Specification (TS) Pages, River Bend Station, Unit 1 2.a Clean Technical Specification (TS) Pages, Grand Gulf Nuclear Station, Unit 1 2.b Clean Technical Specification (TS) Pages, River Bend Station, Unit 1 3.a Markup of Technical Specification (TS) Bases Pages - For Information Only, Grand Gulf Nuclear Station, Unit 1 3.b Markup of Technical Specification (TS) Bases Pages - For Information Only, River Bend Station, Unit 1

Enclosure, Attachment 1.a CNRO-2020-00006 Markup of Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 TS Pages (6 Pages) 1.0-12 1.0-16 1.0-17 3.8-2 3.8-3 3.8-38

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

GRAND GULF However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition {for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Speci fi cations.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time {i.e.,

"once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and Bin Example 1.3-3 may not be extended.

{continued) 1.0-12 Amendment No. 120

1.3 Completion Times EXAMPLES (continued)

GRAND GULF EXAMPLE 1. 3-3 ACTIONS CONDITION A. One Function X subsystem inoperable.

8. One Function Y subsystem inoperable.

C. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

REQUIRED ACTION A. I Restore Function X subsystem to OPERABLE status.

8.1 Restore Function Y subsystem to OPERABLE status.

C. I Restore Function X subsystem to OPERABLE status.

OR C.2 Restore Function Y subsystem to OPERABLE status.

1.0-16 Completion Times 1.3 COMPLETION TIME 7 days AND 10 days from discovery of failure to meet the LCO 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCO 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Amendment No. 120 I

Completion Times 1.3 1.3 Completion Times EXAMPLES GRAND GULF (continued) 1.0-17 Amendment No. 120 I

EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition Bare concurrently applicable. The Completion Times for Condition A and Condition Bare tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited. If the Completion Time for Required Action A.l has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and Bare modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO.

The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO.

This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as co11111encing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

ACTIONS CONDITION A.

(continued)

A.2 B.

One required DG B.1 inoperable for reasons other than Condition F.

AND B.2 AND GRAND GULF AC Sources-Operating

3. 8.1 REQUIRED ACTION COMPLETION TIME Restore required offsite circuit to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power AND 17 days from discovery of failure to meet LCO Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for OPERABLE required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s), supported discovery of by the inoperable DG, Condition B inoperable when the concurrent with redundant required i noperabi l i ty feature(s) are of redundant inoperable.

required feature Cs)

(continued) 3.8-2 Amendment No. W, 151

ACTIONS CONDITION B.

(continued)

B.3.1 OR B.3.2 AND B.4 C.

Two required offsite C.1 circuits inoperable.

AND C.2 GRAND GULF AC Sources-Operating 3.8.1 REQUIRED ACTION COMPLETION TIME Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG(s) are not inoperable due to common cause failure.

Perform SR 3.8.1.2 for OPERABLE DG(s).

Restore required DG to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 72 hours from discovery of an inoperable Division 3 DG AND 14 days AND 17 days from discovery of failure to meet LCO Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from feature(s) inoperable discovery of when the redundant Condition C required feature(s) concurrent with are inoperable.

inoperability of redundant required feature(s)

Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

(continued) 3.8-3 Amendment No. -+/--2-0-, 151

3.8 ELECTRICAL POWER SYSTEMS Distribution Systems-Operating 3.8.7 3.8.7 Distribution Systems-Operating LCO 3.8.7 Division 1, Division 2, and Division 3 AC and DC electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

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

Division 3 electrical power distribution subsystems are not required to be OPERABLE when High Pressure Core Spray System is inoperable.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Division 1 A. l Restore Division 1 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 2 AC electrical and 2 AC electrical power distribution power distribution AND subsystem(s) subsystems to inoperable.

OPERABLE status.

B.

One or more Division 1 B. l Restore Division 1 or 2 DC electrical and 2 DC electrical power distribution power distribution subsystem(s) subsystems to inoperable.

OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO (continued)

GRAND GULF 3.8-38 Amendment No. 120

Enclosure, Attachment 1.b CNRO-2020-00006 Markup of Technical Specification (TS) Pages River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 TS Pages (8 Pages) 1.0-12a 1.0-16 1.0-17 3.1-20 3.8-2 3.8-3 3.8-38 3.8-39

Completion Times 1.3 RIVER BEND 1.0-12a Amendment No. 199 1.3 Completion Times DESCRIPTION The above Completion Time extension does not apply to a Completion (continued)

Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

(continued)

Completion Times 1.3 RIVER BEND 1.0-16 Amendment No. 81 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Function X subsystem inoperable.

A.1 Restore Function X subsystem to OPERABLE status.

7 days AND 10 days from discovery of failure to meet the LCO B. One Function Y subsystem inoperable.

B.1 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCO C. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

C.1 Restore Function X subsystem to OPERABLE status.

OR C.2 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Completion Times 1.3 RIVER BEND 1.0-17 Amendment No. 81 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

The Completion Times of Conditions A and B are modified by a logical connector, with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock". In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered.

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

SLC System 3.1.7 RIVER BEND 3.1-20 Amendment No. 81, 114 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(C)(E) < 570.

A.1 Restore (C)(E) 570.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 10 days from discovery of failure to meet the LCO B.

One SLC subsystem inoperable for reasons other than Condition A.

B.1 Restore SLC subsystem to OPERABLE status.

7 days AND 10 days from discovery of failure to meet the LCO C.

Two SLC subsystems inoperable for reasons other than Condition A.

C.1 Restore one SLC subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D.

Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

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

AC SourcesOperating 3.8.1 RIVER BEND 3.8-2 Amendment No. 81 125, 176 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

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

Verification is only required if 22 kV onsite circuit is supplying Division III safety related bus E22-S004 from normal power transformer STX-XNS1C.

A.2 Verify E22-S004 is aligned to transfer to the preferred station transformer powered by the OPERABLE offsite circuit.

AND A.3 Restore required offsite circuit to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power AND 17 days from discovery of failure to meet LCO B.

Automatic transfer function not OPERABLE B.1 Restore Division III power source to the preferred station service transformers 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

AC SourcesOperating 3.8.1 RIVER BEND 3.8-3 Amendment No. 81 125, 176 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.

OR C.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).

AND C.4 Restore required DG to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of an inoperable Division III DG AND 14 days AND 17 days from discovery of failure to meet LCO D.

Two required offsite circuits inoperable.

D.1 Declare required feature(s) inoperable when the redundant required feature(s) are inoperable.

AND D.2 Restore one required offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition D concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Distribution SystemsOperating 3.8.9 RIVER BEND 3.8-38 Amendment No. 81 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution SystemsOperating LCO 3.8.9 Division I, Division II, and Division III AC and DC, and Division I and II AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

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

Division III electrical power distribution subsystems are not required to be OPERABLE when High Pressure Core Spray System and Standby Service Water pump 2C are inoperable.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Division I or II AC electrical power distribution subsystems inoperable.

A.1 Restore Division I and II AC electrical power distribution subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO B.

One or more Division I or II AC vital bus distribution subsystems inoperable.

B.1 Restore Division I and II AC vital bus distribution subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO (continued)

Distribution SystemsOperating 3.8.9 RIVER BEND 3.8-39 Amendment No. 81 95 185 ACTION (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more Division I or II DC electrical power distribution subsystems inoperable.

C.1 Restore Division I and II DC electrical power distribution subsystems to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 -----------NOTE-------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E.

One or more Division III AC or DC electrical power distribution subsystems inoperable.

E.1 Declare High Pressure Core Spray System and Standby Service Water System pump 2C inoperable.

Immediately F.

Two or more divisions with inoperable distribution subsystems that result in a loss of function.

F.1 Enter LCO 3.0.3.

Immediately

Enclosure, Attachment 2.a CNRO-2020-00006 Clean Technical Specification (TS) Pages Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 TS Pages (6 Pages) 1.0-12 1.0-16 1.0-17 3.8-2 3.8-3 3.8-38

Completion Times 1.3 GRAND GULF 1.0-12 Amendment No. 120, 1.3 Completion Times DESCRIPTION However, when a subsequent division, subsystem, component, (continued) or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..."

(continued)

Completion Times 1.3 GRAND GULF 1.0-16 Amendment No. 120, 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Function X subsystem inoperable.

A.1 Restore Function X subsystem to OPERABLE status.

7 days B. One Function Y subsystem inoperable.

B.1 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

C.1 Restore Function X subsystem to OPERABLE status.

OR C.2 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Completion Times 1.3 GRAND GULF 1.0-17 Amendment No. 120, 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

AC SourcesOperating 3.8.1 GRAND GULF 3.8-2 Amendment No. 120, 151, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.2 Restore required offsite circuit to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power B.

One required DG inoperable for reasons other than Condition F.

B.1 Perform SR 3.8.1.1 for OPERABLE required offsite circuit(s).

AND B.2 Declare required feature(s), supported by the inoperable DG, inoperable when the redundant required feature(s) are inoperable.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s)

(continued)

AC SourcesOperating 3.8.1 GRAND GULF 3.8-3 Amendment No. 120, 151, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).

AND B.4 Restore required DG to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of an inoperable Division 3 DG AND 14 days C.

Two required offsite circuits inoperable.

C.1 Declare required feature(s) inoperable when the redundant required feature(s) are inoperable.

AND C.2 Restore one required offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Distribution SystemsOperating 3.8.7 GRAND GULF 3.8-38 Amendment No. 120, 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution SystemsOperating LCO 3.8.7 Division 1, Division 2, and Division 3 AC and DC electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

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

Division 3 electrical power distribution subsystems are not required to be OPERABLE when High Pressure Core Spray System is inoperable.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Division 1 or 2 AC electrical power distribution subsystem(s) inoperable.

A.1 Restore Division 1 and 2 AC electrical power distribution subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B.

One or more Division 1 or 2 DC electrical power distribution subsystem(s) inoperable.

B.1 Restore Division 1 and 2 DC electrical power distribution subsystems to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (continued)

Enclosure, Attachment 2.b CNRO-2020-00006 Clean Technical Specification (TS) Pages River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 TS Pages (8 Pages) 1.0-12a 1.0-16 1.0-17 3.1-20 3.8-2 3.8-3 3.8-38 3.8-39

Completion Times 1.3 RIVER BEND 1.0-12a Amendment No. 199 1.3 Completion Times DESCRIPTION The above Completion Time extension does not apply to a Completion (continued)

Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..."

(continued)

Completion Times 1.3 RIVER BEND 1.0-16 Amendment No. 81 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Function X subsystem inoperable.

A.1 Restore Function X subsystem to OPERABLE status.

7 days B. One Function Y subsystem inoperable.

B.1 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months C. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

C.1 Restore Function X subsystem to OPERABLE status.

OR C.2 Restore Function Y subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours (continued)

Completion Times 1.3 RIVER BEND 1.0-17 Amendment No. 81 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued)

SLC System 3.1.7 RIVER BEND 3.1-20 Amendment No. 81, 114 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(C)(E) < 570.

A.1 Restore (C)(E) 570.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.

One SLC subsystem inoperable for reasons other than Condition A.

B.1 Restore SLC subsystem to OPERABLE status.

7 days C.

Two SLC subsystems inoperable for reasons other than Condition A.

C.1 Restore one SLC subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D.

Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

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

AC SourcesOperating 3.8.1 RIVER BEND 3.8-2 Amendment No. 81, 125, 176 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

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

Verification is only required if 22 kV onsite circuit is supplying Division III safety related bus E22-S004 from normal power transformer STX-XNS1C.

A.2 Verify E22-S004 is aligned to transfer to the preferred station transformer powered by the OPERABLE offsite circuit.

AND A.3 Restore required offsite circuit to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of two divisions with no offsite power B.

Automatic transfer function not OPERABLE B.1 Restore Division III power source to the preferred station service transformers 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

AC SourcesOperating 3.8.1 RIVER BEND 3.8-3 Amendment No. 81 125, 176 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

(continued)

C.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.

OR C.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).

AND C.4 Restore required DG to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of an inoperable Division III DG D.

Two required offsite circuits inoperable.

D.1 Declare required feature(s) inoperable when the redundant required feature(s) are inoperable.

AND D.2 Restore one required offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition D concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Distribution SystemsOperating 3.8.9 RIVER BEND 3.8-38 Amendment No. 81 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution SystemsOperating LCO 3.8.9 Division I, Division II, and Division III AC and DC, and Division I and II AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

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

Division III electrical power distribution subsystems are not required to be OPERABLE when High Pressure Core Spray System and Standby Service Water pump 2C are inoperable.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Division I or II AC electrical power distribution subsystems inoperable.

A.1 Restore Division I and II AC electrical power distribution subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B.

One or more Division I or II AC vital bus distribution subsystems inoperable.

B.1 Restore Division I and II AC vital bus distribution subsystems to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

Distribution SystemsOperating 3.8.9 RIVER BEND 3.8-39 Amendment No. 81 95 185 ACTION (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more Division I or II DC electrical power distribution subsystems inoperable.

C.1 Restore Division I and II DC electrical power distribution subsystems to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 -----------NOTE-------------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E.

One or more Division III AC or DC electrical power distribution subsystems inoperable.

E.1 Declare High Pressure Core Spray System and Standby Service Water System pump 2C inoperable.

Immediately F.

Two or more divisions with inoperable distribution subsystems that result in a loss of function.

F.1 Enter LCO 3.0.3.

Immediately

Enclosure, Attachment 3.a CNRO-2020-00006 FOR INFORMATION ONLY Markup of Technical Specification (TS) Bases Pages - For Information Only Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 TS Bases Pages (7 Pages)

B 3.8-5a B 3.8-6 B 3.8-8c B 3.8-9 B 3.8-75 B 3.8-76 B 3.8-77

BASES ACTIONS GRAND GULF Ll (continued)

AC Sources - Operating B 3.8.1 The Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the 1ow probability of a OBA occurring during this period.

The third Completion Time for Required Action A.2 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet B 3.8-5a LDC 07028 (continued)

BASES ACTIONS GRAND GULF AC Sources Operating B 3.8.1 A.2 (continued) the LCO.

If Condition A is entered while, for instance, a DG is inoperable and that DG is subsequently returned OPERABLE, the LCO may already have been not met for up to 14 days.

This situation could lead to a total of 17 days, since initial failure to meet the LCO, to restore the offsite circuit.

At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 14 days (for a total of 31 days) allowed prior to complete restoration of the LCO.

The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently.

The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition A was entered.

To ensure a highly reliable power source remains, it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the @equired Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions must then be entered.

Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related divisions (i.e., single continued B 3.8-6 LDC 01192

BASES ACTIONS GRAND GULF B.4 (continued)

AC Sources - Operating B 3.8.1 5.

High pressure injection systems (HPCS and RCIC) and the Division 3 DG (HPCS DG) will not be taken out of service for planned maintenance while DG Division 1 or 2 is out of service for extended maintenance.

The third Completion Time for Required Action B.4 established a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO.

If Condition Bis entered while, for instance, an

<continued)

B 3.8-Sc LDC 03008

BASES ACTIONS GRANO GULF (continued)

AC Sources - Operating B 3.8.1 offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This situation could lead to a total of 17 days, since initial failure to meet the LCO, to restore the OG.

At this time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to complete restoration of the LCO.

The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which Conditions A and B are entered concurrently.

The "AND" connector between the Completion Times means that the three Completion Times apply simultaneously, and the most restrictive Completion Time must be met.

As in Required Action B.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered.

C.l and C.2 Required Action C.l addresses actions to be taken in the event of concurrent failure of redundant required features.

Required Action C.l reduces the vulnerability to a loss of function.

The rationale for the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) 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 divisions 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.

These features are designed with redundant safety related divisions (i.e., single division systems are not included in the list, although, for this Required Action, Division 3 is considered redundant to Division 1 and 2 ECCS).

Redundant required features failures consist of any of these features that are inoperable, because any inoperability is on a division redundant to a division with inoperable offsite circuits.

continued B 3.8-9 LDC 02109 B.4

BASES ACTIONS GRAND GULF Di stri buti on Systems - Operating B 3.8.7 A.l (continued)

The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimi ng the potential for loss of power to remaining division by stabilizing the unit, and on restoring power to the affected division.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because:

a.

There is potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.

b.

The potential for an event in conjunction with a single failure of a redundant component in the division with AC power.

(The redundant component is veri ed OPERAB in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP).")

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO.

If Condition A is entered while, for instance, a DC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an (continued)

B 3.8-75 LDC 01078 (continued) zi the fi LE

BASES ACTIONS GRAND GULF A.1 (continued)

Di stri buti on Systems - Operating B 3.8.7 acceptable limitation on this potential to fail to meet the LCO indefinitely.

With one or more Division 1 or 2 DC electrical power distribution subsystems inoperable, the remaining DC ectrical power distribution subsystems are capable of supporting the minimum s functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure.

The overall reliability is reduced, however, because a single failure in the remaining DC ectrical power distribution subsystems could result in the minimum required F functions not being supported.

Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition B may represent one division without adequate DC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning.

In this situation, the plant is significantly more vulnerable to a complete loss of all DC power.

It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimi ng the potential for loss of power to the remaining divisions, and restoring power to the affected division.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Compl on Times allowed for the majority of components that could be without power.

Taking exception to LCO 3.0.2 for components without adequate DC power, that would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue; b.

The potential for decreased safety when requ1r1ng entry into numerous applicable Conditions and Required Actions for components without DC power while not (continued)

B 3.8-76 Revision No. 0 el afety el ES zi eti

Distribution Systems Operating B 3.8.7 GRAND GULF B 3.8-77 LBDCR 14043 BASES ACTIONS B.1 (continued) providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; and c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC division could again become inoperable, and DC distribution could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

C.1 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, the plant must be bought 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

(continued)

Enclosure, Attachment 3.b CNRO-2020-00006 FOR INFORMATION ONLY Markup of Technical Specification (TS) Bases Pages - For Information Only River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 TS Bases Pages (10 Pages)

B 3.1-39 B 3.1-40 B 3.8-5 B 3.8-8a B 3.8-9 B 3.8-81 B 3.8-82 B 3.8-83 B 3.8-84 B 3.8-85

SLC System B 3.1.7 RIVER BEND B 3.1-39 Revision No. 0 BASES ACTIONS A.1 (continued)

Condition C for both SLC subsystems inoperable, since they are capable of performing their original design basis function. Because of the low probability of an ATWS event and that the SLC System capability still exists for vessel injection under these conditions, the allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is acceptable and provides adequate time to restore concentration to within limits. The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of concentration out of limits or inoperable SLC subsystems during any single continuous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, an SLC subsystem is inoperable and that subsystem is subsequently returned to OPERABLE, the LCO may already have been not met for up to 7 days. This situation could lead to a total duration of 10 days (7 days in Condition B, followed by 3 days in Condition A), since initial failure of the LCO, to restore the SLC System. Then an SLC subsystem could be found inoperable again, and concentration could be restored to within limits. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock," resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition A was entered. The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

B.1 If one SLC subsystem is inoperable for reasons other than Condition A, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this condition, the remaining OPERABLE subsystem is adequate to perform the shutdown function. However, the overall reliability is reduced because a single failure in the remaining OPERABLE subsystem could result in reduced SLC System shutdown capability. The 7 day Completion Time is based on the availability of an OPERABLE subsystem capable of performing the intended SLC System function and the low probability of a Design Basis Accident (DBA) or severe transient occurring concurrent with the failure of the Control Rod Drive System (continued)

SLC System B 3.1.7 RIVER BEND B 3.1-40 Revision No. 0 BASES ACTIONS B.1 (continued) to shut down the plant. The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of concentration out of limits or inoperable SLC subsystems during any single continuous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, concentration is out of limits, and is subsequently returned to within limits, the LCO may already have been not met for up to 3 days. This situation could lead to a total duration of 10 days (3 days in Condition A, followed by 7 days in Condition B), since initial failure of the LCO, to restore the SLC System. Then concentration could be found out of limits again, and the SLC subsystem could be restored to OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock," resulting in establishing the "time zero" at the time the LCO was initially not met instead of at the time Condition B was entered. The 10 day Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

C.1 If both SLC subsystems are inoperable for reasons other than Condition A, at least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is considered acceptable, given the low probability of a DBA or transient occurring concurrent with the failure of the control rods to shut down the reactor.

D.1 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The allowed Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

(continued)

AC Sources Operating B 3.8.1 RIVER BEND B 3.8-5 Revision No. 169 BASES ACTIONS A.3 (continued)

The Completion Time takes into account the capacity and capability of the remaining AC sources, reasonable time for repairs, and the low probability of a DBA occurring during this period.

The third Completion Time for Required Action A.3 establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DG is inoperable and that DG is subsequently returned OPERABLE, the LCO may already have been not met for up to 14 days. This situation could lead to a total of 17 days, since initial failure to meet the LCO, to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 14 days (for a total of 31 days) allowed prior to complete restoration of the LCO.

The 17 day Completion Time provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and C are entered concurrently. The "AND" connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 14 day Completion Times means that both Completion Times apply simultaneously, and the more restrictive must be met.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time that Condition A was entered.

B.1 This action applies when the auto transfer function from the 22 kV onsite circuit to the 230 kV offsite circuit through transformers RTX-XSR1C or RTX-XSR1D is found inoperable. This action will require placing the 4.16 kV Division III safety related bus E22-S004, powered from NNS-SWG1A or NNS-SWG1B, through transformers RTX-XSR1C or RTX-XSR1D.

This action will ensure the automatic transfer feature is no longer required and the 230 kV offsite circuit is supplying 4.16 kV buses NNS-SWG1A or NNS-SWG1B through transformers RTX-XNS1C or RTX-XNS1D.

The COMPLETION TIME of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is bounded by the allowed outage times of the supported equipment.

(continued)

AC Sources Operating B 3.8.1 RIVER BEND B 3.8-8a Revision No. 154 BASES ACTIONS C.4 (continued)

2. The condition of the offsite power supply and switchyard, including transmission lines and ring bus breakers, will be evaluated.

3. No elective maintenance will be scheduled within the switchyard that would challenge offsite power availability during the proposed extended DG AOT.

4. Operating crews will be briefed on the DG work plan, with consideration given to key procedural actions that would be required in the event of a LOOP or SBO.

5. High pressure injection systems will not be taken OOS for maintenance while DG Division I or II is out of service for extended maintenance.

The third Completion Time for Required Action C.4 established a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an offsite circuit is inoperable and that circuit is subsequently restored OPERABLE, the LCO may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This situation could lead to a total of 17 days, since initial failure to meet the LCO, to restore the DG. At this time, an offsite circuit could again become inoperable, the DG restored OPERABLE, and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 20 days) allowed prior to complete restoration of the LCO. The 17 day Completion Time provides a limit on the time allowed in a specified (continued)

AC Sources Operating B 3.8.1 RIVER BEND B 3.8-9 Revision No. 154 BASES ACTIONS C.4 (continued) condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and C are entered concurrently. The "AND" connector between the Completion Times means that the three Completion Times apply simultaneously, and the most restrictive Completion Time must be met.

As in Required Action C.2, the Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered.

D.1 and D.2 Required Action D.1 addresses actions to be taken in the event of concurrent failure of redundant required features. Required Action D.1 reduces the vulnerability to a loss of function. The rationale for the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) 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 divisions 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.

These features are designed with redundant safety related divisions (i.e.,

single division systems are not included in the list, although, for this Required Action, Division III is considered redundant to Division I and II ECCS. Additionally, the Division III powered SSW pump 2C is considered redundant to SSW pumps 2B and 2D powered from Division II). Redundant required features failures consist of any of these features that are inoperable, because any inoperability is on a division redundant to a division with inoperable offsite circuits.

The Completion Time for Required Action D.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required (continued)

Distribution SystemsOperating B 3.8.9 RIVER BEND B 3.8-81 Revision No. 0 BASES (continued)

ACTIONS A.1 With one or more Division I or II required AC buses, load centers, motor control centers, or distribution panels (except AC vital buses), in one division inoperable, the remaining AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The Condition A worst scenario is one division without AC power (i.e., no offsite power to the division and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operators' attention be focused on minimizing the potential for loss of power to the remaining division by stabilizing the unit, and on restoring power to the affected division. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because:

a.

There is potential for decreased safety if the unit operators' attention is diverted from the evaluations and actions necessary to restore power to the affected division to the actions associated with taking the unit to shutdown within this time limit.

b.

The potential for an event in conjunction with a single failure of a redundant component in the division with AC power. (The redundant component is verified OPERABLE in accordance with Specification 5.5.10, "Safety Function Determination Program (SFDP).")

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition A is entered while, for instance, a DC bus is inoperable and subsequently (continued)

Distribution SystemsOperating B 3.8.9 RIVER BEND B 3.8-82 Revision No. 0 BASES ACTIONS A.1 (continued) returned OPERABLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the AC distribution system. At this time, a DC circuit could again become inoperable, and AC distribution could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

B.1 With one Division I or II AC vital bus distribution subsystem inoperable, the remaining OPERABLE AC vital bus is capable of supporting the minimum safety functions necessary to shut down and maintain the unit in the safe shutdown condition. Overall reliability is reduced, however, because an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC vital bus distribution subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months by powering the bus from one of the associated Class 1E AC sources.

Condition B may represent one AC vital bus distribution subsystem without power; potentially both the DC source and the associated AC source nonfunctioning. In this situation, the plant is significantly more vulnerable to a complete loss of all noninterruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining vital bus, and restoring power to the affected vital buses.

This 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit is more conservative than Completion Times allowed for the majority of components that are without adequate vital AC power.

Taking exception to LCO 3.0.2 for (continued)

Distribution SystemsOperating B 3.8.9 RIVER BEND B 3.8-83 Revision No. 0 BASES ACTIONS B.1 (continued) components without adequate AC vital power, that would have Required Action Completion Times shorter than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if declared inoperable, is acceptable because of:

a.

The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue;

b.

The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without adequate vital AC power, while not providing sufficient time for the operators to perform the necessary evaluations and actions to restore power to the affected division;

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , since initial failure of the LCO, for restoring the vital bus distribution system. At this time, an AC division could again become inoperable, and vital bus distribution could be restored to OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the (continued)

Distribution SystemsOperating B 3.8.9 RIVER BEND B 3.8-84 Revision No. 0 BASES ACTIONS B.1 (continued) time that Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

C.1 With Division I or II DC electrical power distribution subsystem inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystems could result in the minimum required ESF functions not being supported.

Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Condition C may represent one division without adequate DC power, potentially with both the battery significantly degraded and the associated charger nonfunctioning. In this situation, the plant is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the plant, minimizing the potential for loss of power to the remaining divisions, and restoring power to the affected division.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the majority of components that could be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, that would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety when requiring a change in plant conditions (i.e., requiring a shutdown) while not allowing stable operations to continue; (continued)

Distribution SystemsOperating B 3.8.9 RIVER BEND B 3.8-85 Revision No. 161 BASES ACTIONS C.1 (continued)

b.

The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without DC power while not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected division; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This situation could lead to a total duration of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC division could again become inoperable, and DC distribution could be restored OPERABLE. This could continue indefinitely.

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely.

D.1 If the inoperable electrical power distribution system cannot be restored to OPERABLE status within the associated Completion Times, 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

(continued)

v t e Letter Sequence Request
EPID:L-2020-LLA-0009, TSTF 439 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2020-02-24 [Table View]

CNRO-2020-00006, Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Revision 2

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SUMMARY

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

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CNRO-2020-00006, Application to Revise Technical Specifications to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Revision 2

Text

Subject:

Enclosure:

Enclosure:

SUMMARY

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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